Collection of employee vaccination information

Over the past month, the Enquiries Service has seen a significant increase in queries from agencies about collecting COVID-19 employee vaccination information. We have updated our COVID-19 vaccination resources to include some common issues, but it is important to remember that whether an employee has been vaccinated against COVID-19 is their personal information.

Agencies can only collect personal information in compliance with the privacy principles in the Information Privacy Act 2009 (Qld) (IP Act). This means agencies cannot ask employees for their vaccination status because they think the information may be useful or it might be needed in the future. There must be a clear, justifiable reason why the information is necessary for one of the agency's functions before it can be collected.

Agencies considering collecting employee vaccine status information should refer to the updated COVID-19 vaccination resources and the personal information collection guideline to ensure they meet their privacy obligations.

Where agencies can lawfully collect their employees’ vaccination status, agencies should preference sighting an employee's evidence of their vaccination status and make a record of this action, rather than retaining a copy of the evidence. This approach minimises the collection of personal information.

The updated resources can be found here:

• COVID-19 – Agency privacy obligations and employee vaccination status
• COVID-19 – Health agency privacy obligations and employee vaccination status
• COVID-19 – Vaccination and my privacy rights as a Queensland health employee
• COVID-19 – Vaccination and my privacy rights as a Queensland public sector employee

For more information, contact the Enquiries Service on 07 3234 7373 (select option 1) or enquiries@oic.qld.gov.au.