From 11 November 2021, anyone working or volunteering in a care home will need to be fully vaccinated against coronavirus (COVID-19), unless they are exempt under the regulations.
The regulations say that a care home may process information about vaccination or medical exemption status, but this must be done in a way that is consistent with data protection legislation. This includes updating your information asset register, record of processing activity, and privacy notice. You will also be required to complete a data protection impact assessment (DPIA) because the Information Commissioner’s Office Guidance on Vaccination and Covid Pass Checks states
“If the use of this data is likely to result in a high risk to individuals (eg denial of employment opportunities) or you will be processing health data on a large scale, then you need to complete a data protection impact assessment before you start processing the data.”
Care homes will not be able to employ individuals who have not received 2 vaccinations or who don’t have an exemption, therefore this can result in the denial of employment opportunities and so a DPIA is required.
For general advice on vaccination as a condition of deployment, please see the compiled guidance from the Care Provider Alliance.
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