Do you know your staff’s vaccination status?


Close up: Arm being tended after vaccination by gloved hand. Stamp indication person has been vaccinated.

Updated 10 June 2021


Amidst recent events in Victoria, the Federal Government has asked The Australian Health Protection Principal Committee to reconsider making COVID-19 vaccination mandatory for aged care workers.


In response, an e-alert issued by Leading Age Services Australia (LASA) to their members is encouraging age care providers to be proactive in anticipation of a new vaccine mandate by considering how to engage with their workforce to discuss the collection of employee information. You can read LASA’s full e-alert at the bottom of this article >


[ Update: From 15 June 2021, all residential aged care approved providers will be required to report via My Aged Care on a weekly basis. Read the media release by The Hon Greg Hunt MP, Minister for Health and Aged Care > ]


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. It is crucial for employers to consider their privacy policy in relation to vaccination records, including how you will handle any client or patient requests for proof of vaccination.


The Office of the Australian Information Commissioner (OAIC) offer the following general advice for employers:

  • Employers will only be able to collect information about employee’s vaccination status in very limited circumstances

  • Only the minimum amount of personal information reasonably necessary to maintain a safe workplace should be collected, used or disclosed

  • You must only collect vaccination status information if the employee consents and the collection is reasonably necessary for your functions and activities, unless an exception applies

  • One exception that may allow collection without the employee’s consent is circumstances where the collection is required or authorised by law

  • If vaccination status information is collected, you must advise employees how this information will be handled

  • Vaccination status information should be used or disclosed on a ‘need-to-know’ basis

  • Ensure you take reasonable steps to keep employee vaccination status and related health information secure

The OAIC also points that privacy is only one of many factors to consider when asking employees their COVID-19 vaccination status, and encourages employers to seek further information from the Fair Work Ombudsman and Safe Work Australia websites.


There are already some limited circumstances where employers may collect health information without consent, such as where the collection is required or authorised by Australian law. For example, the Queensland COVID-19 Testing and Vaccination Requirements (Contact by Health Workers with Cases) Direction of 31 March 2021 requires ‘relevant employees’ to be vaccinated against COVID-19. ‘Relevant employees’ includes health service employees, ambulance employees and contractors engaged to perform clinical or non-clinical services within hospitals and health services whose work takes them within close proximity to persons who have been diagnosed with COVID-19. Under Part 5 of this Direction, a public health emergency officer can direct a relevant employee to provide evidence of vaccination.


State and territory public health orders are continually being updated to respond to the COVID-19 pandemic. With mandatory COVID-19 vaccination now on the discussion table for the aged care sector, it is important that employers review your workplace vaccination policy.


Your workplace vaccination policy needs to cover how you will manage recordkeeping and privacy. It should also include your processes for managing various refusal scenarios and any potential employment pathways, options or outcomes.


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



LASA E-Alert dated Wednesday 3 June 2021:


Recording and reporting of staff COVID-19 vaccinations


The current situation in Victoria has firmly put vaccination in the spotlight, with some welcome sense of urgency regarding access to vaccination for the residential aged care workforce.

Protecting residents and staff from serious illness through vaccination is an important feature of infection and prevention controls against COVID-19.

Providers will be familiar with the expectations on recording and reporting of staff uptake of influenza vaccination annually. The events of recent days indicate that it is highly probable that providers will be asked to extend this to the recording, and potentially reporting, of COVID-19 vaccination uptake.

Taking reasonable steps to understand staff vaccination status should be part of a provider’s IPC program. However, LASA has also made clear to government and others that providers cannot require employees to provide this information.

Having information about employee vaccination status will also help bring greater public confidence to IPC arrangements in aged care and help prompt further action to support staff vaccination.

No details are yet available on what is likely to be requested through a formal reporting mechanism, but we are aware that the Department of Health has been calling facilities to seek verbal information.

LASA encourages all Members to be proactive in anticipation of this requirement and consider now how to engage with their workforce to discuss the collection of information on:

  • Employees who have received a first dose

  • Employees who have received a second dose

It is possible this could be extended to home care providers, so Members in all settings are encouraged to prepare for this potential development.


For more information Leading Age Services Australia (LASA) p: 1300 111 636 w: www.lasa.asn.au