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Do you have a workplace vaccination policy?

Mandatory COVID-19 vaccination is becoming the norm for a growing number of Australian workplaces. This creates a new suite of HR considerations for employers, including development and/or review of a vaccination policy.

Employers should seek tailored employment relations advice before issuing any vaccine mandate.

3 key actions for employers to consider:

1. Develop a vaccination policy. This will need to include your processes for managing various refusal scenarios, such as for medical/health reasons or for ideological/political reasons, and any potential employment pathways, options or outcomes. Your vaccination policy will also need to cover how you will manage record-keeping and privacy.

2. Consult with your employees. Under WHS laws, employers who are making changes to the workplace to help slow the spread of COVID-19 must consult their workers. Your communication plan should include information about the COVID-19 vaccine, why a mandate may be reasonable and necessary in your workplace, and how you plan to implement your vaccination policy. You also need to give your staff ample opportunity to ask questions and discuss any concerns.

3. Keep records. As most healthcare, aged care and disability workers are already required to receive the flu vaccine, employers will be familiar with the importance of keeping accurate and up-to-date staff vaccination records. You will need to consider your privacy policy in relation to these vaccination records, including how you will handle any client or patient requests for proof of vaccination.

A tailored vaccination policy is the appropriate way for employers to establish their approach to COVID-19 vaccination and provide clear guidance to your staff on the measures taken to reduce the work health and safety risks relating to infectious diseases such as influenza and COVID-19.

Your vaccination policy will usually be a component of your existing infection control policy. It could be a stand-alone document, or it could be linked to other relevant workplace literature e.g. other policies, employment contracts or Enterprise Bargaining Agreements.

Your vaccination policy should include:

✏️ Information about your organisation’s vaccination program and implementation plan

✏️ How you will manage communications, record-keeping and privacy

✏️ Your processes for managing scenarios whereby an employee chooses not to be vaccinated

✏️ Employer and employee rights and responsibilities

Workplace policies and procedures help shape the work culture and mitigate business risk by outlining clear expectations and providing a consistent approach to managing workplace issues. It is important to provide employees with regular opportunities to review the workplace policies and procedures, especially when changes or updates are implemented.

Employers planning to mandate COVID-19 vaccination in their workplace should also review their recruitment and onboarding processes to ensure you include the mandatory vaccination of staff (includes contractor, agency staff, volunteers, anyone who attends the workplace) as a condition of employment.

For more information and tailored advice, please contact us today.


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