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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Staff Vaccination Policy

1. Purpose

The purpose of this policy is to establish a clear and proportionate framework for assessing occupational infection risks, offering and facilitating appropriate staff immunisation, and managing relevant vaccination information at {{org_field_name}}. This policy supports compliance with the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, particularly Regulation 56 on hygiene and infection control, together with applicable health and safety, equality and data protection legislation.

This policy ensures that:

• All staff are aware of the importance of vaccinations in protecting themselves and service users.
• Clear procedures are in place for carrying out role-based infection-risk assessments, offering or facilitating appropriate immunisation, and recording only the minimum vaccination information that is necessary and lawful.
• Staff receive appropriate guidance, education, and support regarding vaccinations.
• Infection prevention measures are aligned with Welsh Government and CIW guidelines.

This policy aligns with:

• The Regulation and Inspection of Social Care (Wales) Act 2016​.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, particularly Regulations 12, 34, 35, 36, 56 and 57.
• The Health and Safety at Work Act 1974, ensuring a safe working environment.
• The Control of Substances Hazardous to Health Regulations 2002, including the requirement to assess and control occupational exposure to biological agents and, where the risk assessment identifies a relevant risk and an effective vaccine is available, to offer appropriate immunisation as a protective measure.
• Public Health Wales guidance on infection control in health and social care settings.
• The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999.
• The Equality Act 2010, including the duty to avoid unlawful discrimination and to make reasonable adjustments for disabled workers.
• The UK General Data Protection Regulation and the Data Protection Act 2018, because vaccination status and medical exemption information are special-category health data.

2. Scope

This policy applies to:

• All employees of {{org_field_name}}, including care staff, management, and administrative personnel.
• Agency and temporary staff working within the organisation.
• Volunteers, agency workers and contractors who may be exposed to infection risks through their duties or who may present a foreseeable infection risk to individuals receiving care and support, subject to the organisation’s legal responsibilities and the contractual responsibilities of their employer or agency.

It covers:

• Role-specific immunisation recommendations identified through current national guidance and occupational infection-risk assessment.
• Record-keeping and monitoring of vaccinations.
• Procedures for supporting staff with vaccinations.
• Managing a decision not to accept an offered vaccination, or circumstances in which vaccination is clinically unsuitable, through a confidential and individual risk-assessment process.

3. Policy Statement

{{org_field_name}} is committed to maintaining a safe and healthy working environment by preventing and controlling occupational exposure to infection. Where a suitable and effective vaccine is recommended for a worker following consideration of current national guidance and the risks associated with their role, the organisation will arrange or facilitate access to that vaccination.

We will:

• Offer or facilitate appropriate vaccination, free of charge to the worker where the organisation is required to provide it as an occupational protective measure, when indicated by the worker’s role, the occupational risk assessment and current national immunisation guidance.
• Provide up-to-date information and guidance on recommended vaccines.
• Respect each worker’s informed decision while assessing and managing any residual infection risk to the worker, colleagues and individuals receiving care and support. No worker will be subjected to automatic detriment solely because they have declined a vaccination; any action will be lawful, necessary, proportionate and based on an individual risk assessment.
• Process only vaccination information that is necessary for a clearly identified occupational-health, employment or infection-control purpose. Before processing this information, the organisation will identify and document an Article 6 lawful basis, an applicable Article 9 special-category condition and, where required, a Data Protection Act 2018 Schedule 1 condition. Access will be restricted, the information will be retained only for an authorised period, and staff will be provided with appropriate privacy information.
• Support staff with exemptions through alternative infection control measures.

4. Managing Staff Vaccinations Efficiently

4.1 Role-specific immunisation assessment

There is no single list of occupational vaccinations that automatically applies to every employee of a domiciliary support service. The vaccinations that should be offered or recommended will be determined by:

• the duties undertaken by the worker;
• the type and degree of contact with individuals receiving care and support;
• foreseeable exposure to blood, body fluids, respiratory infection or other biological agents;
• the needs and vulnerabilities of individuals supported by the service;
• the worker’s documented immunisation history, where it is necessary and lawful to consider it;
• advice from an appropriately qualified occupational-health professional; and
• current Welsh Government, Public Health Wales, UK Health Security Agency and Green Book guidance.

Annual influenza vaccination will be actively offered or facilitated for eligible frontline health and social care workers with direct contact with individuals receiving care and support, in accordance with the current Welsh seasonal influenza programme.

COVID-19 vaccination will be promoted and facilitated only for those staff who are eligible under the current Welsh vaccination programme. Eligibility and recommended doses may change and must not be assumed solely from the worker’s job title.

Hepatitis B vaccination will be offered where the occupational risk assessment identifies a foreseeable risk of exposure to blood or body fluids and current clinical guidance indicates that vaccination is appropriate. Appropriate arrangements will also be made for post-vaccination testing or follow-up where recommended.

Evidence of immunity or vaccination for measles, mumps and rubella, varicella or other infections will be sought only where this is justified by the worker’s role, current national guidance and an occupational-health assessment.

Routine childhood vaccinations, including tetanus, diphtheria and polio, will not be described as an occupational requirement for all care staff. Workers may be signposted to their GP or NHS vaccination service where routine immunisation is incomplete, while occupational vaccination will be provided by the organisation where required by the work-related risk assessment.

4.2. Vaccination Record-Keeping and Monitoring

To ensure effective vaccination management, {{org_field_name}} will:

• Maintain vaccination information only where it is necessary and proportionate for a specified occupational-health, employment or infection-control purpose. Vaccination information is special-category health data and will not automatically be collected for every member of staff.
• Review the occupational infection-risk assessment at suitable intervals and whenever duties, exposure risks, national guidance or the health needs of the people supported materially change. Vaccination information will be reviewed only where necessary for that purpose.
• Request evidence of vaccination or immunity during recruitment or induction only where this is necessary for the intrinsic duties of the particular role, supported by a documented occupational-risk assessment and processed in accordance with data protection and equality legislation. Recruitment decisions will not be based on vaccination status unless the requirement is lawful, objectively justified and proportionate.
• Regularly update staff on changes in vaccination recommendations.

Vaccination information will be kept separately from general personnel information where appropriate, protected by access controls and available only to authorised personnel with a genuine need to know. Managers will normally receive only the occupational-health outcome or work restrictions necessary to manage risk, rather than detailed clinical information. Records will be retained and securely destroyed in accordance with the organisation’s retention schedule and staff privacy notice.

4.2.1 Data protection requirements

Before vaccination information is collected or otherwise processed, {{org_field_name}} will:

• document the specific purpose for processing;
• identify the applicable Article 6 lawful basis;
• identify the applicable Article 9 condition for processing health data;
• identify any applicable Data Protection Act 2018 Schedule 1 condition and maintain an appropriate policy document where required;
• give the worker clear privacy information;
• collect only the minimum information required;
• ensure that information obtained for one purpose is not used for an incompatible purpose;
• establish an authorised retention period;
• keep the information accurate and secure; and
• complete a data protection impact assessment where the processing is likely to present a high risk to workers’ rights and freedoms.

Consent will not be relied upon as the default lawful basis merely because a worker has signed a vaccination form. The organisation will recognise the imbalance of power in the employment relationship and will identify the most appropriate lawful basis and special-category condition for the circumstances.

4.3. Encouraging and Facilitating Staff Vaccinations

To promote high vaccination uptake, {{org_field_name}} will:

• Provide staff with accurate information on the benefits and safety of vaccinations.
• Offer on-site vaccination clinics where possible, or facilitate off-site vaccinations through local healthcare providers.
• Where vaccination is offered as an occupational protective measure following the organisation’s risk assessment, make arrangements that allow the worker to receive it without personal cost and without being placed at a financial disadvantage. Arrangements for other NHS vaccination appointments will be managed in accordance with the organisation’s leave policy and applicable contractual rights.
• Meet the cost of any vaccination that the organisation is required to offer as a work-related protective measure. Staff must not be instructed to pay privately for an occupational vaccination and then rely on discretionary reimbursement.

The organisation will undertake timely vaccination communications in accordance with current Welsh programmes, including the seasonal influenza programme and any other programme for which relevant staff are eligible.

4.4. Managing Vaccination Refusal or Exemption

A worker may decide not to accept a vaccination that has been offered, or an appropriately qualified clinician may advise that a particular vaccine is unsuitable or should be deferred. Workers will not be required to disclose detailed medical information or religious or philosophical beliefs to their line manager. Where medical information is relevant, it should normally be considered confidentially through occupational health.

Where staff decline vaccinations, the following steps will be taken:

• An individual risk assessment will be completed only where the vaccination is relevant to the worker’s role or a current infection risk. The assessment will consider the nature of exposure, the vulnerability and needs of individuals supported, current public-health advice, existing control measures, the worker’s duties and any reasonable adjustments. The assessment will not assume that an unvaccinated worker automatically presents an unacceptable risk.

Where the assessment identifies a material residual risk, proportionate control measures will be selected in accordance with current infection-prevention guidance and the hierarchy of controls. Depending on the circumstances and current public-health advice, measures may include:

• reinforced standard infection-control precautions;
• task-specific personal protective equipment where indicated;
• symptom monitoring and prompt reporting;
• testing where it is clinically or epidemiologically indicated and supported by current Welsh guidance;
• temporary adjustment of duties or deployment; or
• exclusion from particular duties for a defined period where advised by occupational health or the relevant health protection service.

PPE, testing, redeployment or exclusion will not be imposed automatically because a worker has declined vaccination. Any measure must be necessary, proportionate, time limited, documented and reviewed.

Where an occupational vaccination has been offered, the organisation may record that the offer was made and whether it was accepted, declined or deferred, where that record is necessary and lawful. A worker will not be compelled to sign a document accepting personal liability or waiving employment rights. The record must not include unnecessary reasons for the worker’s decision.

4.5 Risk controls following vaccination assessment

Standard infection-prevention and control precautions apply to all staff, regardless of vaccination status. These include effective hand hygiene, appropriate use of personal protective equipment, respiratory and cough hygiene, safe management of waste and sharps, environmental and equipment decontamination, prompt reporting of symptoms or exposure incidents, and compliance with the organisation’s Infection Prevention and Control Policy.

Additional precautions will be introduced only where indicated by:

• the individual’s personal plan or known clinical vulnerability;
• a staff or service-level infection-risk assessment;
• a suspected or confirmed infection;
• an outbreak or exposure incident; or
• advice from Public Health Wales, occupational health or the relevant health protection service.

Additional measures will be applied consistently to vaccinated and unvaccinated workers where the assessed risk and current guidance require them.

4.6. Staff Training and Awareness

All staff will receive infection-prevention and control training appropriate to their role. Where vaccination is relevant to their duties, the training or information provided will cover:

• occupational exposure to biological agents and the control measures required;
• the purpose, benefits and limitations of vaccinations relevant to the role;
• the fact that vaccination does not replace standard infection-control precautions;
• how occupational vaccinations are offered and how confidential advice can be obtained;
• how to report symptoms, exposure incidents, adverse events or concerns;
• the confidentiality of vaccination and health information; and
• the worker’s responsibility to follow infection-control requirements regardless of vaccination status.

Training will be provided at induction and refreshed at intervals determined by the organisation’s training-needs analysis, risk assessment, current guidance and staff competence. Additional updates will be provided promptly following a material change in guidance, an identified competency concern, an outbreak or a relevant incident.

4.7. Reporting and Managing Outbreaks

In the event of an infectious disease outbreak, {{org_field_name}} will:

• Recognise and promptly report suspected or confirmed infection in accordance with the individual’s personal plan, the Infection Prevention and Control Policy and current Welsh guidance. As a domiciliary support provider, {{org_field_name}} will not impose isolation independently; it will support the individual to follow advice given by an appropriate clinician, Public Health Wales or the relevant health protection service while respecting the individual’s rights, capacity, wishes and home environment.
• Provide relevant staff, individuals and representatives with timely information about the precautions they need to take, while protecting confidential personal information and disclosing identifiable information only where there is a lawful and necessary basis.
• Co-operate with any vaccination or post-exposure programme led or advised by NHS Wales, Public Health Wales, occupational health or the relevant health protection service, and facilitate staff access where appropriate.
• Seek advice from and notify the relevant health protection service, local authority, CIW or other statutory body where notification is required by law, regulation, current guidance or the circumstances of the incident. The registered manager or nominated lead will confirm what must be reported, by whom and within what timescale.

A business continuity plan will ensure care services remain operational while managing infection risks.

4.7.1 Occupational exposure incidents

Any sharps injury, bite, splash to broken skin or mucous membrane, or other significant exposure to blood or body fluids must be dealt with immediately in accordance with the organisation’s exposure-incident procedure. The worker must:

• carry out immediate first aid;
• report the incident without delay;
• obtain urgent occupational-health or clinical assessment;
• follow advice concerning post-exposure prophylaxis, testing or vaccination; and
• complete the required incident record.

The organisation will consider whether the incident is reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 and whether any CIW, safeguarding or other notification is required.

4.8 Responsibilities

The service provider will:

• ensure that suitable and sufficient infection-risk assessments are completed;
• provide required occupational protective measures without charge to workers;
• ensure access to competent occupational-health advice;
• maintain lawful and secure information-governance arrangements;
• provide appropriate resources, training and PPE; and
• monitor compliance with this policy and the Infection Prevention and Control Policy.

The registered manager will:

• ensure that the policy is implemented consistently;
• avoid requesting unnecessary medical or belief information;
• refer clinical questions to occupational health;
• ensure that any work restriction or redeployment is risk based, proportionate and reviewed;
• ensure required notifications are made; and
• audit staff training, vaccination offers and identified control measures.

Occupational health or another appropriately qualified clinician will:

• provide confidential, role-specific vaccination advice;
• assess clinical suitability where required;
• advise the organisation only of relevant fitness-for-work outcomes, restrictions or adjustments, unless the worker has authorised wider disclosure or disclosure is otherwise lawfully required; and
• advise on post-exposure management.

Staff will:

• follow standard infection-control precautions at all times;
• attend required infection-control training;
• consider vaccination information provided and make an informed decision;
• promptly report symptoms and occupational exposure incidents;
• comply with any lawful and proportionate temporary precautions; and
• provide only such health information as is necessary for occupational-health or risk-management purposes.

5. Related Policies

This policy aligns with and should be read alongside the following:

• Infection Prevention and Control Policy (DCW17) – Covers wider infection control strategies.
• Health and Safety at Work Policy (DCW16) – Ensures workplace safety for staff and service users.
• Confidentiality and Data Protection Policy (DCW34) – Governs secure handling of vaccination records.
• Emergency and Business Continuity Plan (DCW19) – Outlines procedures during infectious disease outbreaks.

• Recruitment and Selection Policy – because vaccination evidence must not be requested indiscriminately during recruitment.
• Equality, Diversity and Human Rights Policy – because disability, pregnancy, religion or belief may be relevant and discrimination must be avoided.
• Occupational Health and Staff Well-being Policy – for confidential clinical assessment and advice.
• Sharps and Blood or Body Fluid Exposure Procedure – for immediate management and post-exposure follow-up.
• Staff Privacy Notice and Records Retention Schedule – for vaccination and health information.
• Sickness Absence and Communicable Disease Procedure – for symptom reporting, exclusion and return-to-work decisions.

6. Policy Review

This policy will be reviewed annually or sooner if required due to:

• Changes in legislation, the Regulated Services Regulations, CIW inspection requirements, Welsh Government or Public Health Wales guidance, Green Book recommendations, national vaccination-programme eligibility or data protection guidance.
• Any outbreak, occupational exposure incident, complaint, data-protection incident, equality concern or audit finding indicating that this policy or its implementation may be ineffective or unlawful.
• Emerging infectious disease threats.
• Feedback from staff and healthcare professionals.

All updates will be communicated to employees, and additional training will be provided where necessary.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.