Investigation into COVID-19 vaccination attestation requirements established by certain separate employers of the federal public service

This investigation examined whether COVID-19 vaccination attestation requirements implemented by several federal separate employers for their employees complied with the Privacy Act. The OPC found that the collection and use of vaccination status information, including for accommodation requests, was authorized under the Act and directly related to the employers' operating programs, specifically workplace health and safety during the pandemic. While not a strict legal requirement of the Act, the OPC also assessed the necessity and proportionality of these measures and found them to be reasonable given the exceptional circumstances of the pandemic.

• Whether the collection of COVID-19 vaccination status information was directly related to an operating program or activity of the institutions.
• Whether the use and disclosure of vaccination status information, including for accommodation requests, was authorized under the Privacy Act.
• The necessity and proportionality of the vaccination attestation measures in the context of the COVID-19 pandemic.