07 JunTime to remove your on-site COVID vaccination records

Posted on 07 Jun 2023

Do you have a COVID-19 mandatory vaccination policy (Vic) in place? It’s time to remove your on-site COVID vaccination records.

Have you retained old COVID-19 vaccination records used for the Pandemic Orders in Early Childhood Education and Care (ECEC) (pre-October 2022)?

The Occupational Health and Safety Amendment (COVID-19 Vaccination Information) Regulations 2022 (Vic) will expire on 12 July 2023.

This temporary amendment to the Occupational Health and Safety Act 2004 (Vic), introduced in 2022, permitted employers to collect and store COVID-19 vaccination information.

As these were temporary guidelines (in effect for 12 months), they will be revoked on 12 July 2023. As a result, employers are no longer permitted to collect or retain COVID-19 vaccination information from their employees.

Please note that this does not affect collecting or storing vaccination information relating to a child’s enrolment details at your service/s (i.e. immunisation history statements).

What are COVID-19 vaccination records?

Vaccination information or records specific to COVID-19 for staff, committee members, contractors, students, or volunteers may include:

  • COVID-19 digital records (including PDF screenshots or files)
  • printed copies or PDF files/folders of COVID-19 vaccination certificates
  • immunisation history statements
  • an internal COVID-19 vaccination register/s or documents (including with HR)
  • any other private or confidential records relating to COVID-19 vaccinations, such as copies of Medicare cards or numbers.

What do employers need to do?

1. Review your existing COVID-19 Mandatory Vaccination Policy before 12 July 2023

Employers are strongly encouraged to review any existing COVID-19 mandatory vaccination policies to determine their current suitability. This may include conducting a risk assessment to determine whether a mandatory policy can be removed or transitioned into a voluntary policy.

PolicyWorks subscribers are also advised that the ELAA COVID-19 Mandatory Vaccination Policy (QA7) is no longer available and has been incorporated into the Dealing with Infectious Diseases Policy (QA2).

2. Remove all on-site (digital and printed) COVID-19 vaccination records within 30 days

The COVID-19 Vaccination Information Regulations 2022 will be revoked on 12 July 2023, and within 30 days of this date, employers must remove any COVID-19 vaccination information records.

Any questions about these changes?

Please contact Member Solutions (phone operating hours between 10a.m and 3p.m) on (03) 9489 3500 (Press 2) Monday to Friday or email us at: membersolutions@elaa.org.au.

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