The Italian Data Protection Authority ("DPA") has
issued guidelines on data protection rules applying to COVID-19
vaccinations at the workplace.
On May 13, 2021, the Italian DPA issued guidelines on data
protection rules applying to COVID-19 vaccinations at the workplace that
can be organized by employers in accordance with a national
protocol on workplace vaccinations adopted on April 6, 2021.
The DPA confirmed that employers may not collect, either
directly or indirectly (including through healthcare
professionals), any personal data of employees participating in the
workplace vaccination campaign, including their participation in
such campaign, vaccination status and any other information about
employees' health conditions. Unless otherwise provided by law
(e.g., healthcare professionals subject to mandatory vaccination
requirements), employees can freely decide whether or not to
participate in the vaccination campaign without incurring any
positive or negative
