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OTHER NAMES Vaccination Policy Coronavirus (COVID-19) Vaccination Policy Covid-19 vaccine policy Coronavirus vaccine policy Coronavirus workplace vaccine policy Covid-19 workplace vaccine policy

What is an Employee Vaccination Policy?

An Employee Vaccination Policy sets out an employer's approach to staff Coronavirus (COVID-19) vaccinations. Employee Vaccination Policies supplement employers’ existing Health and safety and Sickness policies and encourage staff members to be vaccinated against Coronavirus (COVID-19) where possible.

This document is GDPR compliant.

When should I use an Employee Vaccination Policy?

Use this Employee Vaccination Policy if you:

  • are a business engaging staff 

  • want to encourage staff to get vaccinated against Coronavirus (COVID-19), where possible, and

  • your staff are based in England, Wales or Scotland

Sample Employee Vaccination Policy

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Employee Coronavirus (COVID-19) Vaccination Policy

Statement and purpose of policy

  1. This policy sets out 's approach to staff vaccination against coronavirus (COVID-19).
  2. It supplements but does not replace our policies on health and safety and sickness.
  3. This policy applies to all employees, irrespective of seniority, tenure and working hours, including all directors and officers, casual or agency staff, trainees, interns, fixed-term staff and volunteers, and workers and contractors (Staff).
  4. The purpose of this policy is to provide information about the COVID-19 vaccination and to encourage Staff to get vaccinated against coronavirus. It does not form part of any contract of employment.
  5. The information set out in this policy is taken from guidance on the NHS and other government websites. We recommend that Staff familiarise themselves with the relevant guidance and check regularly for updates.

The importance of the COVID-19 vaccination

  1. The COVID-19 vaccination is currently available free of charge to eligible groups through the NHS.
  2. As we cannot provide medical or scientific advice on the COVID-19 vaccine, please see the relevant NHS guidance (www.nhs.uk/conditions/coronavirus-covid-19/coronavirus-vaccination/safety-and-side-effects/).
  3. If you have any questions or concerns about receiving the vaccine, you should speak to a healthcare professional. If you have any non-medical questions or concerns, please raise them with your line manager or HR department.

Why the COVID-19 vaccination is important

  1. We believe the vaccination is important to stop the spread of coronavirus, to avoid pressure on the NHS and to keep all Staff healthy. As a result, we encourage Staff to get the vaccine if they are able to do so.
  2. According to the government:
    1. due to vaccination, fewer people will catch coronavirus and those that do are less likely to be hospitalised or pass away;
    2. not all who are offered the vaccine will receive it, and there are certain groups (e.g. children) for whom the vaccine is not yet authorised and/or available;
    3. even if a person is vaccinated, a chance remains that they contract and pass on the COVID-19 virus; and
    4. no vaccine is completely effective and, like all viruses, coronavirus can mutate.
  3. We recognise that vaccines are not an immediate and complete fix, however, together with increased testing, the vaccination programme will allow us to return to a more normal life, including enabling Staff to return to the physical workplace.

What this means for you

  1. While we encourage Staff to get the vaccine if they are able to do so, we recognise that some Staff may have concerns about the COVID-19 vaccine for a number of reasons, for example:
    1. they have a health condition, or are worried about an allergic reaction (or other side effects);
    2. they are pregnant, thinking about getting pregnant or breastfeeding;
    3. they do not believe the vaccine to be safe, or effective, or necessary; or
    4. for religious or ethical reasons.
  2. As part of our Return to Work Risk Assessment, the government's vaccination programme has been considered.
  3. The government has not made COVID-19 vaccines mandatory, and does not consider it necessary or appropriate for most businesses to require that every member of staff be vaccinated in order to return to the physical workplace or to carry out any particular kind of work
  4. Due to the risk that a vaccinated individual may still catch and spread coronavirus, the risk mitigations set out in the Return to Work Risk Assessment will need to continue. We will continuously review the situation in ongoing risk assessments.
  5. We, therefore, do not currently require Staff to have the vaccine, however, it is our  policy to encourage and support Staff to have the vaccine, by:
    1. providing accurate information on the COVID-19 vaccine, based on the available NHS guidance (www.nhs.uk/conditions/coronavirus-covid-19/coronavirus-vaccination/coronavirus-vaccine/);
    2. signposting any other relevant guidance;
    3. seeking to alleviate the concerns about the possible negative vaccination effects; and
    4. providing information on taking time off to have the vaccine, and what to do if you experience side effects after having the vaccine.
  6. We will not tolerate any bullying, harassment or victimisation of Staff in relation to their vaccination choices. Any such conduct will be dealt with under our equal opportunities and bullying policies.

Time off for vaccination

  1. If you are invited to have your dose of the COVID-19 vaccine during normal working hours, you may take reasonable time off work to attend your vaccination appointment.
  2. As soon as possible, you should inform us of the time and date of any vaccination appointment.

Time off for vaccine side effects

  1. If you are unwell and prevented from working due to any side effects of the COVID-19 vaccine:
    1. report your sickness using the standard sickness reporting procedure;
    2. you will be entitled to sick pay in accordance with our Sickness Policy; and
    3. these absences will count in your absence records or towards HR 'trigger' points in our Sickness Policy.

Processing your personal data

  1. Information relating to vaccination status is health data, i.e. special category ('sensitive') personal data. We  may need to process such data to record:
    1. time taken off (if any) to get the vaccine;
    2. time taken off (if any) due to side effects of the COVID-19 vaccine and to process your pay for time off (if any)
  2. Any such health data processing will take place in accordance with our Data Protection and Data Security Policy which is available.

Changes to the policy

  1. As set out in the section entitled ‘What this means for you’, we will continue to keep the situation in relation to vaccinations under review in ongoing coronavirus risk assessments.
  2. We reserve the right to modify this policy at any time in our sole discretion to adapt to changing circumstances, government guidance and/or business needs, consistent with our commitment to maintaining a safe and healthy workplace. This may, for example, include the introduction of mandatory vaccinations for certain roles or restricting certain roles to staff who have been vaccinated.

Attribution

  1. This employee vaccination policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).

 

Looking for something else?

FAQs about making Employee Vaccination Policies

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  • What is included in an Employee Vaccination Policy?

    This Employee Vaccination Policy template covers:

    • the importance of Coronavirus (COVID-19) vaccines

    • the employer’s position regarding Coronavirus (COVID-19) vaccinations

    • steps taken to reduce the risks related to Coronavirus (COVID-19) 

    • time off for vaccinations

    • time off due to vaccination side effects 

    • the processing of staff personal data

  • Why do I need an Employee Vaccination Policy?

    Employers have a duty to ensure the health and safety of staff. This includes the obligation to ensure the safety of staff returning to work during the Coronavirus (COVID-19) pandemic, which may include encouraging staff vaccinations. Having a written Vaccination Policy in place demonstrates that employers are complying with these obligations.

  • Can I require staff to be vaccinated?

    While employers can encourage staff to be vaccinated where possible, employers cannot require staff (or potential staff) to be vaccinated. Even if an employer prefers staff to be vaccinated, care must be taken not to discriminate when discussing or dealing with staff vaccination (eg some individuals may be advised not to have the vaccine due to health reasons).

    If a staff member does not get vaccinated, their employer should listen to their concerns, bearing in mind that some individuals may not be able to get the vaccination (eg because of health reasons, such as a compromised immune system) or they may have health concerns (eg regarding a potential allergic reaction to the vaccine). 

    Employers should remain sensitive to personal situations and should keep concerns (especially those relating to health) confidential.

    For more information, read Coronavirus (COVID-19) vaccinations in the workplace.

  • Can I ask staff about their vaccine status?

    Employers can ask staff if they have or have not been vaccinated, provided they have a good reason for needing to know. An example of a good reason for needing to know is to ensure the health and safety of the wider workforce. 

    An employer’s reason for checking (or recording) vaccination status must be clear and transparent. This means that, if an employer cannot provide a specific use for this information and is recording it ‘just in case’, or if they can achieve their goal without collecting this data, employers are unlikely to be able to justify collecting it.

    To decide whether or not you have a justified reason for checking vaccination statuses, consider:

    • the sector you operate in

    • the kind of work your staff do

    • relevant workplace health and safety risks

    • sector-specific Government guidance

    For more information, read How to record the Coronavirus (COVID-19) vaccination status of staff.

  • Do I need a return to work risk assessment?

    To comply with staff health and safety obligations, employers need to assess any risks created or posed in the course of their business, which may include the risk of Coronavirus (COVID-19) infection. The legal requirement to explicitly consider COVID-19 in risk assessments ended on 1 April 2022, but considering related risks is still good practice for many employers. Employers should complete a Return to work risk assessment to identify and implement measures for avoiding or mitigating any risks. 

    Considering the Government’s vaccination programme and encouraging staff to be vaccinated is an example of a step that may be taken to reduce the risks posed by Coronavirus (COVID-19). 

    For more information read Employee health and safety in the workplace during Coronavirus (COVID-19) and Risk assessments at work.

  • Can I process data relating to staff vaccinations?

    Information about staff vaccination status constitutes 'special category sensitive personal data' (as it relates to personal health) and employers who decide to keep a record of this data must do so in accordance with data protection laws (eg the UK General Data Protection Regulations (GDPR) and the Data Protection Act 2018). This is especially important as sensitive personal data is awarded greater protection under data protection law than other forms of personal data (eg names and contact details). 

    The processing (eg obtaining and recording) of sensitive personal data is not permitted unless the use of the data is fair, relevant and necessary for a specific purpose. For example, employers may ask staff members about their vaccination status in reliance on the employer’s having a legitimate interest in doing this in order to protect people’s health and safety. 

    When collecting and recording staff vaccination status data, employers should: 

    • undertake a Data protection impact assessment (DPIA) where necessary

    • identify a lawful basis for processing (eg ‘legitimate interest’ for health and safety reasons)

    • consider and document why other methods of protection are insufficient (eg social distancing and face coverings) and determine why it is necessary to collect data on staff members’ vaccination statuses

    • inform staff about what personal data they want to process, what this data will be used for, who the data will be shared with, how long the data will be stored for, and what decisions will be made based on the data held

    For more information, read How to record the Coronavirus (COVID-19) status of staff.

  • Do I need to complete a data protection impact assessment?

    A Data protection impact assessment (DPIA) needs to be completed before data is collected if the use of the data is likely to result in a high risk being posed to staff (eg denial of work opportunities). This is likely to be the case with health data such as vaccination statuses.

    A DPIA is a process that helps to identify and minimise data protection risks, by analysing the processing to be carried out. 

    For more information, read How to record the Coronavirus (COVID-19) vaccination status of staff and Data protection impact assessments.

  • Do I need a data protection and data security policy?

    A Data protection and data security policy sets out the policies and procedures a business will comply with when dealing with staff personal information and personal data. Where an employer is processing personal data (eg recording or storing information relating to staff vaccination statuses), a data protection and data security policy: 

    • ensures that employers have a systematic approach to complying with any laws and regulations

    • informs staff about the employer’s duties in relation to staff personal data

    • clearly sets out the procedures for collecting, storing and processing staff data

    For more information, read How to record the Coronavirus (COVID-19) vaccination status of staff.

  • What if staff members refuse to be vaccinated?

    If staff members refuse vaccination, employers will need to consider other steps that can be taken to ensure the health and safety of all staff.

    Where staff refuse an employer’s reasonable instruction regarding vaccination, the employer may consider disciplinary action. However, this is not without risk as it has not yet been established in the courts that requiring a Coronavirus (COVID-19) vaccine is reasonable.

    As a result, any disciplinary action carries with it risks of unfair dismissal, discrimination, or other claims being brought against the employer. Employers should be very careful when considering taking steps towards a disciplinary process and dismissal.

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About Employee Vaccination Policies

Learn more about making your Employee Vaccination Policy

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  • How to make an Employee Vaccination Policy

    Making an Employee Vaccination Policy online is simple. Just answer a few questions and Rocket Lawyer will build your document for you. When you have all of the details prepared in advance, making your document is a quick and easy process.

    To make your Employee Vaccination Policy you will need the following information:

    Employer details

    • What is the employer’s name?

    Vaccination

    • Are staff members required to inform the employer whether they’ve been (or intend to be) vaccinated?

    • Will time taken off for vaccination appointments be paid or unpaid?

      • If paid, is there a maximum amount of paid hours that staff can take off work to get their vaccination?

    • Will time taken off due to vaccine side effects count towards staff absence records?

    Data protection

  • Common terms in an Employee Vaccination Policy

    An Employee Vaccination Policy sets out a business’ approach towards Coronavirus (COVID-19) vaccines in the workplace. As a result, this Employee Vaccination Policy covers:

    Statement and purpose of Policy

    This section explains why the Employee Vaccination Policy is important, what it covers, and who it applies to. It also highlights that the Employee Vaccination Policy is a statement of policy only and it can, therefore, be amended by the employer as and when this is deemed necessary.

    The importance of the Coronavirus (COVID-19) vaccination

    This section sets out that Coronavirus (COVID-19) vaccinations are currently available for free to eligible groups through the NHS. It explains where information about vaccination safety and side effects can be found and encourages staff to speak to healthcare professionals (for any vaccine-related questions) and/or their line managers or the HR department (for any non-medical questions or concerns).

    Why the Coronavirus (COVID-19) vaccination is important

    This section explains why staff receiving Coronavirus (COVID-19) vaccinations is important, both outside and within the workplace.

    What this means for you

    This section encourages staff to get vaccinated against Coronavirus (COVID-19) and sets out reasons for this. It also clarifies that staff members are not required to be vaccinated and clearly states that the employer will not tolerate any bullying, harassment or victimisation of staff members in relation to their vaccination choices.

    Time off for vaccination

    This section clarifies that staff members are allowed reasonable time off work to attend their vaccination appointments. This section also sets out whether or not this is paid time off. 

    Time off for vaccine side effects

    This section sets out how staff members should report any absences from work due to vaccine side effects (eg in accordance with the employer’s Sickness policy). 

    Processing your personal data

    This section explains that the employer may have to process staff members’ personal data under this Policy and why. It clarifies that this will be done in accordance with the employer’s Data protection and data security policy.

    Changes to the Policy

    This section clarifies that due to its nature, the Employee Vaccination Policy can be changed at any time by the employer. 

    If you want your Employee Vaccination Policy to include further or more detailed provisions, you can edit your document. However, if you do this, you may want a lawyer to review or change the Employee Vaccination Policy for you to ensure it complies with all relevant laws and meets your specific needs. Ask a lawyer for assistance.

  • Legal tips for making an Employee Vaccination Policy

    Avoid discrimination in relation to staff members’ vaccination statuses

    You must take care not to discriminate against anyone because of their vaccination status. Receiving a vaccine requires someone’s informed and voluntary consent and this can, therefore, not be forced. You should listen to the concerns of any staff members who do not get vaccinated and should bear in mind that some individuals may not be able to get vaccinated (eg because of a compromised immune system) or may have concerns about getting vaccines (eg concerns about allergic reactions). 

    For more information, see the FAQ ‘Can I require staff to be vaccinated?’ and read Coronavirus (COVID-19) vaccinations in the workplace. You can Ask a lawyer if you have any questions or concerns.

    Understand when you need to carry out a DPIA

    You will need to carry out and complete a Data protection impact assessment (DPIA) if your use of your staff members’ personal data (eg their vaccination statuses) is likely to result in a high risk to staff members. For example, if they’re likely to be denied a work opportunity if they’ve not been vaccinated. Where this is the case, you will need to carry out your DPIA before processing any personal data. 

    For more information, see the FAQ ‘Do I need to complete a data protection impact assessment?’ and read How to record the Coronavirus (COVID-19) vaccination status of staff. If you have any questions or concerns, do not hesitate to Ask a lawyer.

    Consider what other policies you should adopt

    Adopting and implementing a clear Employee Vaccination Policy is a good way to ensure the health and safety of your workforce. This Employee Vaccination Policy is designed to support your existing workplace policies. These should usually include:

    If you do not already have these employment policies in place, you should consider making them. For more information on the different types of employment policies you may wish to adopt, read HR policies and procedures.

    Understand when to seek advice from a lawyer

    Ask a lawyer for advice if:

    • the Employee Vaccination Policy doesn't meet your needs or doesn’t cover what you want

    • employees don't agree with the Employee Vaccination Policy

    • you want your Employee Vaccination Policy to cover different vaccinations

    • your business operates in a sector with specific vaccination requirements

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