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Employee Vaccination Mandates and collection of sensitive information: Seven considerations

If employee vaccinations for COVID-19 are mandated as part of re-opening your business, or you’re choosing to make it compulsory (or still deciding!), then you are likely looking at the accompanying logistics to ensure you can safely and securely request the vaccination status of your employees now and continue to monitor that status in the future.

There is a lot to think about, and it’s a new space that the business community is navigating. Here are seven things that you may not have considered to help guide your planning as we follow the roadmap to recovery:

  • Monitoring will be ongoing. Once you confirm the vaccination status of an employee, it’s not likely that the process will end there, so plan to continue the process for some time. COVID-19 vaccinations will be part of managing the ‘new normal’, and management of booster shots will be the next phase businesses will need to tackle. You will need to monitor when boosters are due for each staff member and ensure he/she provides the relevant proof within the required timeframe. 
  • Uncertainty is the new normal – so plan for it. Whatever method you adopt to track the employees’ vaccination status, keep in mind that things are likely to change.Try to factor some flexibility into your system as best you can, so your records are searchable and can be segmented by date, vaccine type, worksite etc. For example, what if  a new variant is resistant to one of the current vaccines and a section of your workforce needs to re-vaccinate? What if booster schedules vary by vaccine type? If you set your records up well, these developments will be easier to manage.
  • Reminders will become part of your internal communications. With monitoring comes engagement with employees as key dates and requirements regarding vaccination approach. Much of this communication can be pre-written and automated to make it easier, and language should be factual and respectful. Most of these reminders will be pinned to key dates, including an employee’s initial vaccination date, booster due dates and key business dates (like when an employee may be required to work at a certain project site).
  • Exemptions and personal objections recorded. It’s just as important to keep a record of those employees who are not required to be vaccinated.  This may affect rostering for certain jobs and this means those employees need to be excluded from reminder communications.
  • Remember that the Privacy Act applies. Employers can only collect information about an employee’s vaccination status in particular circumstances where the employee consents and the collection is reasonably necessary for your workplace’s functions and activities. Only collect the information that is required, and only keep it for as long as you need it. Once you have collected sensitive information, the security of that information is paramount. So, you need to think about where it is being stored, who has access to it, and how and when it will be securely deleted.
  • Your workforce may be affected indirectly (or partially). Although you may not be mandated or enforcing vaccination, what if some of your clients require vaccination for your employees to be onsite? Or perhaps the Government mandates vaccination in a sector you work in. Some businesses may end up being indirectly affected in this way and may have to monitor vaccination for a portion of their workforce, even if it’s just for a short-term contract your business may secure.
  • Do you use transient labour? For those industries using transient labour, like agriculture and retail, once Visa Holiday Workers are allowed to return, workers will arrive with International Vaccination Certificates. They will also need to be managed and monitored effectively. If this will affect you, a system that has been specifically built to cater for this situation should be on your radar.

Read more: Five things every employer needs to know about mandatory vaccinations

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Will Aldous

Will Aldous

Will Aldous has spent more than 15 years in the employment/immigration space and has developed CheckVax by CheckWorkRights to help businesses large and small manage workforce vaccine status. https://checkworkrights.com.au/features/checkvax/

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