Investigation into COVID-19 vaccination attestation requirements established by Department of National Defence for members of the Canadian Armed Forces

This investigation examined the COVID-19 vaccination attestation requirements established by the Department of National Defence (DND) for members of the Canadian Armed Forces (CAF). The Office of the Privacy Commissioner of Canada (OPC) found that DND/CAF had the authority to collect this information under the National Defence Act and Part II of the Canada Labour Code. The use and disclosure of the information were generally consistent with the purposes for which it was collected. Although DND declined to implement a recommendation to strengthen oversight of access controls in the Monitor MASS system, the OPC found no instances of inappropriate access or disclosure. The OPC also determined that DND took reasonable steps to ensure the accuracy of the vaccination status information collected.

• Whether DND/CAF's collection of COVID-19 vaccination status information directly related to an operating program or activity of the institution.
• Whether the use of collected vaccination status information was authorized under section 7 of the Privacy Act.
• Whether the use of the Monitor MASS system resulted in unauthorized disclosure of information.
• Whether DND/CAF took reasonable steps to ensure the accuracy of vaccination status information.