ARTICLE · 08 DECEMBER 2021

Data Protection Commission Issues Updated Guidance On Processing COVID-19 Vaccination Data

Arthur Cox

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The Data Protection Commission has issued updated Guidance on Processing COVID-19 Vaccination Data in the context of Employment and the Work Safely Protocol here.

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Seamus Given

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The Data Protection Commission has issued updated Guidance on Processing COVID-19 Vaccination Data in the context of Employment and the Work Safely Protocol here.

While the substantive advice on processing vaccination status data has not changed (it is not necessary and legitimate to process vaccination status in order to manage COVID-19 in the workplace), the Guidance now specifically states that if the public health advice was to change in this regard, then that could potentially provide a legitimate basis for such processing by employers. Helpfully, it also notes that the primary source of public health advice in this context is the Work Safely Protocol here. It also states that the Guidance will be further updated should public health advice change.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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