The Data Protection Commission has issued guidance on Processing COVID-19 Vaccination Data in the context of Employment. The full guidance note can be downloaded here.
The general position of the Data Protection Commission is that in the absence of clear advice from public health authorities in Ireland that it is necessary for all employers and managers of workplaces to establish vaccination status of employees and workers, the processing of vaccine data is likely to represent unnecessary and excessive data collection for which no clear legal basis exists.
The DPC guidance considers the voluntary nature of vaccination and confirms that information on a persons vaccination status is special category personal data for the purpose of GDPR.
