Ahead of the introduction of mandatory vaccination and COVID status checks (also referred to as COVID pass checks) in Scotland and Wales, the UK Information Commissioner, Elizabeth Denham, said:
“While it is for the governments across the UK to decide if and how mandatory vaccination and COVID status checks are introduced, my office has always been clear that data protection law does not stand in the way. Instead, it allows for the trusted and responsible sharing of personal data where it is necessary to protect public health.
“That trust is key to the success of these schemes. People should be able to enjoy a night out on the dance floor without wondering if their data is at risk.
“To that end, my office has been advising governments across the UK on how to ensure privacy is considered from the outset. We expect to see high standards of governance and accountability to ensure compliance with data protection principles, including transparency, fairness, data minimisation and storage limitation, and utilising a ‘data protection by design’ approach as part of their planning. We have also highlighted the need for clear and practical guidance to support nightclubs and other venues required to carry out these checks.”
We have more information on vaccination and COVID status checks on our dedicated coronavirus information hub that includes a simple introductory guide to help venues responsible for carrying out the checks.