As vaccine passports begin to rollout in the UK and EU, Lawyer Monthly spoke with London managing partner Christopher Hitchins on potential issues employers face as they navigate the vaccination statuses of their employees. Christopher Hitchins notes that in addition to watching for discrimination pitfalls, employers need to be mindful of how the management and storage of this personal data intersects with General Data Protection Regulation (GDPR). "According to the UK data protection regulator (the ICO), the reason for recording your employees' vaccination status must be clear and necessary. If you have no specified use for this information and are recording it on a 'just in case' basis, or if the employer can achieve their goal without collecting this data, they are unlikely to be able to justify collecting it." And for employers looking to mandate vaccine passports, he added that they will need to take all due care to avoid altering the treatment of employees based on their COVID-19 records. ("Vaccine Passports: What Are the Implications?," August 2, 2021)
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