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Employee vaccine records — where you stand

By Hugh Halloran

As COVID-19 vaccination deadlines loom, WA employers need to make sure they take their record-keeping practices seriously and maintain employees’ privacy.

covid vaccine

In a phased approach through until January 31, 2022, employees in most industries will need to provide either proof of vaccination (full or partial) or a medical exemption to their employers.

This means that, unlike in some other states, WA employers will be obliged to ask their employees about their vaccination status and keep a record of that information, should the State Government wish to access it to confirm businesses and individuals are complying with the policy.

CCIWA’s Workplace Relations Director Ryan Martin says the fact the Government has issued directions for those occupations where workers need to be vaccinated was helpful.

“Put simply, if your business is covered by a State Government direction, such as community care services, then you’re on pretty strong ground to ask your employees for evidence they’re vaccinated,” Martin says.

Where businesses are not covered by a government direction, they will need to consider whether they have any obligations under the federal Privacy Act around collection of this information.

Learn more: COVID-19 Business Continuity Assessment

“My advice to employers would be to, where possible, just sight your employees’ evidence, such as vaccination certificates, and keep your own records,” Martin says.

“It may be as straightforward as writing down employees’ names, their types of vaccine and the dates of their doses, and if you keep this information securely on each employee’s personnel file, it’s exempt from the Australian Privacy Principles as an employee record.

“Where this isn’t possible because a third party is asking for a copy of an employee’s certificate, presumably to let that person go on site or onto premises, you’ll need to ensure you have that employee’s consent — and to be extra careful, you should redact the employee’s Individual Health Identifier number.”

If it all sounds too complicated, there are some solutions available.

Special CCIWA Member offers

CCIWA members Industry OneCARD and CredShare each offer businesses the ability to store employee information securely.

The Industry OneCARD platform, which verifies and maintains employee records such as licences, certificates and safety inductions, has recently been expanded to collecting and tracking the COVID vaccination status of employees.

If a company needs to collect and track its employees’ vaccination statuses, the requirement can simply be added to the list of records, maintained and mapped to the company’s unique requirements.

To support CCIWA members, Industry OneCARD is offering members a limited number of obligation-free audits to check a business’s current record management process and a health check of data integrity. The management of COVID vaccination status is also available to CCIWA members for a small administration fee and is free to all Industry OneCARD clients.

Meanwhile, CredShare is offering CCIWA members and their workers a SmartCredTM COVID-19 Vaccination Certificate solution.

The CredShare service is forever free of charge to individuals for the COVID vax requirement, or for any other important online document safe storage needs. The CredShare Covid Vax Compliance service is also free of charge to member businesses when used for the vaccination mandate purpose.

CEO Andrew McMillan said workers could use a personally managed CredShare service to advise employers of their status.

“Your privacy and security are guaranteed on the CredShare Repository platform. Simply upload your PDF certificate into your individual CredShare account and the system will automatically encrypt your information and do the rest for you,” he said.

“Member businesses similarly can receive a real-time, easy to use, compliance tool to record worker vaccination results. This will enable your business to meet the needs of Western Australian Government mandates without impinging on the privacy rights of the individual.”

Go to the CCIWA Credshare page for this special offer.

For advice on vaccinations and the workplace contact CCIWA’s Workplace Relations team on 1300 422 492 or via

As COVID-19 vaccination deadlines loom, WA employers need to make sure they take their record-keeping practices seriously and maintain employees’ privacy.

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