Best practice questions answered by Evelyn Rodrigues, VCTH Training and Best Practice Manager.
Q: Can we require volunteers to have had both COVID vaccinations before they resume face-to-face volunteering with clients, or come onto our premises? Should we even ask volunteers if they have had the vaccine?
A: When resuming face-to-face volunteering you should conduct a thorough risk assessment for each volunteer role, both risks to the volunteers and to your clients. Requiring volunteers to be vaccinated is one possible mitigation, but there could be many other less intrusive measures to keep volunteers and clients safe, such as being outdoors, social distancing, face coverings, hand washing, etc. A policy requiring staff and/or volunteers to be vaccinated should only be implemented after careful consideration (there is ACAS guidance on this) and after taking legal advice to avoid the risk of discrimination. Although volunteers are not covered directly by equalities legislation, it is good practice to treat them fairly and avoid discrimination. Remember, many younger people have not yet been offered both jabs.
Currently there is no law that requires people to have the vaccine, even if an organisation would prefer someone to have it. There may be some people who are advised not to have the vaccine, for example for health reasons. If a volunteer does not want to be vaccinated, you should listen to their concerns and be sensitive towards personal situations. You can talk through the reasons why they don’t want to be vaccinated and why your organisation thinks it is necessary. If they still don’t agree, perhaps they can volunteer in a different role (assuming that the risk assessment of their current role deems vaccination to be essential).
If your risk assessment requires volunteers to be vaccinated for certain roles, then you can ask those volunteers for their vaccination history. If vaccination is not considered necessary, then it is better not to ask. Vaccination information is private health information and is therefore special category data. Your reason for collecting and storing volunteers’ vaccination status must be clear and compelling. The data on a person’s vaccination history should be kept confidential and secure. This information from the ICO on collecting employee data on vaccination is useful.