Covid: guidelines for vaccination in the workplace from the Privacy Guarantor

Rome, May 14 (beraking latest news Health) – The Privacy Guarantor has adopted a policy document on vaccination in the workplace, to provide general information on the processing of personal data, pending a definitive regulatory framework. “The implementation of vaccination plans – reads the note – for the activation of extraordinary anti-Covid-19 vaccination points in the workplace, provided for by the national protocol of April 6, 2021, constitutes a public health initiative, reason for the which the general responsibility and supervision of the entire process remain with the Regional Health Service and must be implemented in compliance with the regulations on data protection “.

“Even for vaccination in the workplace – continues the Guarantor – compliance with the traditional division of skills between the competent doctor and the employer must be ensured, highlighted in the document on the role of the competent doctor in matters of safety in the workplace. of work, now available on the Authority’s website “. In the address document, the Guarantor specifies that2 the main data processing activities – from the collection of subscriptions, to the administration, to the registration in the regional systems of the vaccination – must be carried out by the competent doctor or by other health personnel specifically identified “.

In fact, within the framework of the rules protecting the dignity and freedom of data subjects in the workplace, the employer is not allowed to collect information relating to the intention directly from employees, the competent doctor, or other health professionals or health facilities. of the worker to adhere to the campaign or to the administration (or not) of the vaccine and other data relating to his health conditions.

Taking into account the imbalance in the relationship between employer and employee, the consent of the worker cannot in these cases constitute a valid prerequisite for processing vaccination data, just as it is not allowed to derive any consequence, neither positive nor negative, from membership. or not at the vaccination campaign.