
Investigation into COVID-19 vaccination attestation requirements established by the Treasury Board of Canada for employees of the core public administration
This investigation examined the COVID-19 vaccination attestation requirements for federal public servants. The OPC found that the collection of vaccination status was directly related to the employer's health and safety obligations. However, the Treasury Board of Canada Secretariat (TBS) contravened the Act by failing to update its index of personal information banks within the required timeframe. The OPC also assessed the necessity and proportionality of the measures, concluding they were justified given the pandemic context, though TBS's documentation and response during the investigation were found to be lacking.
- Whether the collection of employee vaccination status was directly related to an operating program or activity.
- Whether institutions met transparency requirements under the Act.
- Whether disclosures of personal information were authorized.
- Necessity and proportionality of the vaccination attestation measures.
Complaint largely well-founded; one transparency requirement contravened and resolved.
The collection of vaccination information was found to be directly related to the employer's health and safety duties. A contravention was found regarding the delayed update of the personal information index, which has since been resolved. The necessity and proportionality of the measures were deemed acceptable given the pandemic circumstances.
AI-generated summary for reference only. Always verify against the official decision ↗
The Treasury Board of Canada Secretariat was advised to assess future vaccination measures against a four-part test for necessity and proportionality and to ensure timely updates to its personal information index.
- section 4 Privacy Act
- subsection 5(2) Privacy Act
- section 11 Privacy Act
- subsection 11(1) Privacy Act
- section 8 Privacy Act
- subsection 8(1) Privacy Act
- paragraph 8(2)(a) Privacy Act
- sections 7 and 11.1 Financial Administration Act
- section 124 Canada Labour Code
- section 3.1.1 Policy on COVID-19 Vaccination for the Core Public Administration
This summary is informational only and not legal advice.

