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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 clear guidelines for managing staff vaccinations within {{org_field_name}}. It is our duty to ensure that everyone who receives care and treatment from us is protected, as far as reasonably practicable, from the risk of infection. Vaccination is a key preventative measure, especially for individuals receiving personal and clinical care who may be immunocompromised or at higher risk of severe outcomes from infections. This policy ensures we are compliant with CQC regulations, upholding high standards of health and safety and maintaining a workforce that is protected, informed, and responsible.

2. Scope

This policy applies to all staff who work for or represent {{org_field_name}}, including:

• Permanent employees, whether full-time or part-time
• Temporary, agency and bank staff
• Contractors and external professionals, where relevant to the work they undertake
• Volunteers and placement students

Particular consideration will be given to staff whose duties involve direct care, exposure to blood or body fluids, cleaning, handling contaminated laundry or waste, food preparation, or other activities that may expose them or people using the service to communicable disease.

Vaccination and immunity requirements will not be applied automatically to all workers. They will be determined, where relevant, by current national immunisation guidance, the nature of the worker’s role, the risks identified through an appropriate workplace and infection prevention and control risk assessment, and occupational-health advice where required.

Staff must co-operate with reasonable infection prevention and control and occupational-health arrangements and should raise any relevant health concern, contraindication or need for adjustment confidentially with their line manager, HR or the occupational-health service, as appropriate.

3. Related Policies

This policy is closely linked with several other policies within our framework, including:

• CH02 – Fit and Proper Persons: Employed Staff Policy: Ensures that staff employed are suitable and safe for care delivery.
• CH11 – Safe Care and Treatment Policy: Emphasises the prevention and control of infections as part of safe care practices.
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy: Supports infection control measures to protect vulnerable individuals.
• CH17 – Infection Prevention and Control Policy: Offers further procedures and detailed infection control protocols.
• CH27 – Staff Supervision, Training, and Development Policy: Outlines training responsibilities, including education on vaccines.
• CH30 – Equality, Diversity and Inclusion Policy: Ensures decisions regarding vaccination are free from discrimination.

4. Policy Statement

{{org_field_name}} is committed to protecting people who use the service, staff and others from avoidable exposure to infection. Vaccination is one of a range of infection prevention and occupational-health measures and will be used alongside, and not as a substitute for, appropriate infection prevention and control precautions.

There is no general requirement under current English legislation for all care-home staff to be vaccinated against COVID-19 or to receive any other specified vaccination solely because they work in a care home. Any requirement to assess immunity or offer a vaccination will therefore be determined according to current legislation, national immunisation guidance, the individual’s duties and an assessment of occupational and service-user risk.

{{org_field_name}} will consider relevant vaccinations in accordance with current UK Health Security Agency guidance, including the Green Book, and any applicable Department of Health and Social Care, NHS, CQC or Health and Safety Executive guidance. Depending on the worker’s role and identified risks, this may include:

• Seasonal influenza vaccination where recommended or available for the relevant health and social care workforce
• COVID-19 vaccination where recommended or available for the relevant health and social care workforce
• Hepatitis B vaccination where the worker’s duties create a relevant occupational risk of exposure to blood, blood-stained body fluids or other circumstances identified through risk assessment
• MMR vaccination or evidence of appropriate immunity where this is relevant to the worker’s duties and current national guidance
• Varicella vaccination or evidence of immunity where this is relevant to the worker’s duties and current national guidance
• Other routine or occupational vaccinations where indicated by national guidance or an individual or workplace risk assessment

Decisions about occupational immunisation will be based on current national guidance and/or a local risk assessment. Where an effective vaccine is indicated because an employee is at occupational risk of exposure to a biological agent, {{org_field_name}} will arrange for the vaccination to be offered without charge to the employee.

Vaccination will not replace other necessary infection prevention and control measures, including hand hygiene, appropriate use of personal protective equipment, safe handling of blood and body fluids, environmental cleaning, management of infectious illness, safe working practices and outbreak-control measures.

5. Implementation and Management

5.1 Promotion and Education

We provide information on vaccines during induction, team meetings, supervision, and annual refresher training. All materials are in accessible formats, and staff are encouraged to discuss concerns with our Infection Control Lead or line manager. We aim to counter misinformation and ensure staff understand the benefits of vaccination not only for themselves but for the people we support.

5.2 Consent and Confidentiality

Vaccination is a healthcare intervention and will only be administered with the individual’s valid consent by an appropriately authorised healthcare professional.

There is no general statutory requirement for care-home workers in England to accept COVID-19 vaccination or any other vaccination solely because they work in a care home. A member of staff may decline an offered vaccination. Where a vaccination has been identified through national guidance or a role-specific occupational-health risk assessment, the member of staff will be provided with appropriate information about the benefits, risks and limitations of vaccination and the implications, if any, for safe working.

A decision to decline vaccination will not automatically result in disciplinary action or exclusion from work. Where an identified occupational or service-user risk remains, {{org_field_name}} will assess what reasonably practicable alternative or additional control measures are required. Any employment decision must be lawful, necessary, proportionate and based on the circumstances of the individual role and identified risk.

Information about a worker’s vaccination, immunity, medical contraindications or other health circumstances is health information and constitutes special category personal data. {{org_field_name}} will process such information only where there is an identified lawful basis under Article 6 of the UK GDPR and an applicable condition for processing special category data under Article 9 of the UK GDPR and the Data Protection Act 2018, as amended.

Only information that is necessary and proportionate for the identified purpose will be collected. Health and immunisation information will be kept confidential, stored securely and accessed only by persons who need the information for an authorised purpose. Managers will normally receive only the minimum information necessary to manage fitness for work, workplace restrictions or infection risks and will not be given unnecessary clinical information.

5.3 Record Keeping

{{org_field_name}} will maintain an up-to-date record of relevant staff immunisation or immunity information where this is necessary because of current national guidance, an occupational-health requirement or an identified workplace or infection-control risk.

The requirement to obtain or record vaccination information will be proportionate to the individual’s role and the risk being managed. Staff will not be required as a blanket condition of employment to provide proof of every vaccination or evidence of a medical exemption.

Where an occupational vaccination is indicated, appropriate confidential records may include:

• The vaccination or immunity relevant to the worker’s role
• Whether appropriate evidence of immunity has been established where this is necessary
• Whether an occupational vaccination has been offered
• Whether an offered vaccination has been accepted or declined
• Any occupational-health conclusion relevant to the person’s fitness for work or necessary workplace controls

Detailed clinical information will not be recorded in general management records unless there is a lawful and necessary reason for doing so. Relevant vaccination and occupational-health information will be maintained as confidential health or occupational-health information with access restricted to authorised persons.

All vaccination and immunity records will be processed in accordance with the UK GDPR, the Data Protection Act 2018, as amended, {{org_field_name}}’s data-protection policies and applicable retention requirements. Information will not be retained for longer than is necessary for the purpose for which it was collected.

5.4 Risk Assessment and Adjustments

{{org_field_name}} will assess risks arising from exposure to communicable diseases and biological agents as part of its health and safety and infection prevention and control arrangements. Risk assessments will take account of the requirements of the Health and Safety at Work etc. Act 1974, the Control of Substances Hazardous to Health Regulations 2002, Regulation 12 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and current national infection prevention and immunisation guidance.

The assessment will consider, as appropriate:

• The nature of the worker’s duties
• The likelihood and potential consequences of exposure to infection
• Contact with blood, body fluids or other potentially infectious material
• The vulnerability and clinical needs of people using the service
• Current outbreaks or known exposure to communicable disease
• National recommendations concerning vaccination or immunity
• Existing infection prevention and control measures
• Advice from occupational health, UKHSA, the local Health Protection Team or other appropriate professionals where necessary

Vaccination will be considered as an additional risk-control measure where appropriate; it will not be used as a substitute for other reasonably practicable measures to prevent or control exposure.

Where a worker has not received a vaccination that has been identified as relevant to their role, or where adequate immunity has not been established, an individual risk assessment will be undertaken where necessary. Depending upon the identified risk, proportionate measures may include:

• Reinforcement of standard and transmission-based infection prevention and control precautions
• Appropriate personal protective equipment
• Modification of particular duties
• Avoidance of specified exposure-prone activities where clinically or occupationally indicated
• Temporary redeployment where necessary and reasonably practicable
• Occupational-health assessment or advice
• Additional measures during an outbreak or following exposure to a specific infection

Any restrictions or adjustments will be based on the actual risk and will be reviewed when circumstances change. Decisions will not be based solely on assumptions about vaccination status.

5.5 Access and Support

Where current national guidance or a workplace risk assessment indicates that an employee should be offered vaccination because of occupational exposure, {{org_field_name}} will ensure that the vaccination is made available without charge to the employee.

Appropriate arrangements may include:

• Access to an occupational-health vaccination service
• Liaison with NHS vaccination services, GP practices or other authorised vaccination providers
• In-house vaccination clinics where suitable arrangements can safely and lawfully be made
• Reasonable arrangements to enable staff to attend occupational vaccination appointments
• Reimbursement of charges where an occupational vaccination that the employer is required to provide cannot otherwise be obtained without cost to the employee

Staff who are offered occupational vaccination will be given or directed to reliable and current information explaining the benefits, possible risks and limitations of vaccination so that they can make an informed decision.

Where vaccination is declined or cannot be administered, staff will have access to appropriate occupational-health or medical advice where necessary, and alternative infection-control measures will be considered through risk assessment.

5.6 Monitoring Compliance

The Registered Manager, {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}, is responsible for monitoring compliance with this policy. Routine internal audits will check vaccine records, staff awareness, and implementation practices. Any gaps identified will be addressed promptly and form part of our continuous improvement plans.

6. Responsibilities

• All Staff: Staff must comply with infection prevention and control procedures, co-operate with relevant workplace and occupational-health risk assessments, report work-related exposure to infection promptly and provide health or immunisation information where there is a lawful, necessary and proportionate requirement for that information. Staff are expected to consider vaccination offered in accordance with national guidance and occupational risk assessment, but acceptance of an offered vaccination is not a general statutory condition of care-home employment.
• Registered Manager: The Registered Manager is responsible for ensuring that appropriate systems are in place to assess infection risks, implement reasonably practicable controls, facilitate access to relevant occupational-health advice and vaccination, and monitor compliance with this policy and applicable CQC requirements.
• Infection Control Lead ({{org_field_infection_control_lead_name}}): The Infection Control Lead will support implementation of current infection prevention and control guidance, provide or arrange appropriate information for staff, identify circumstances in which specialist advice is required and support the Registered Manager with monitoring and review.
• HR Department: HR will ensure that any staff vaccination, immunity or health information processed by {{org_field_name}} is collected only where necessary and lawful, is treated as confidential special category personal data, is accessible only to authorised persons and is retained only for as long as necessary. HR will liaise with occupational health where appropriate.
• Line Managers: Line managers will implement relevant infection-control measures, support staff to access occupational-health advice and vaccination where indicated, ensure identified workplace controls are followed and refer individual health matters to appropriately qualified professionals rather than making clinical judgements themselves.
• Occupational Health or Other Appropriate Occupational-Health Adviser: Where occupational-health advice is required, the adviser will assess relevant occupational risks, advise on appropriate vaccination or immunity requirements, advise on fitness for work and workplace restrictions where necessary and maintain clinical confidentiality.

7. Equality and Non-Discrimination

{{org_field_name}} will apply this policy fairly and in accordance with the Equality Act 2010.

No worker will be subjected to unlawful discrimination, harassment or victimisation because of a protected characteristic or because of a health condition associated with vaccination or inability to receive a vaccine.

Where vaccination, evidence of immunity or an alternative infection-control measure is considered necessary for a particular role or activity, the decision must be supported by current national guidance and/or an individual or workplace risk assessment and must be lawful, necessary and proportionate to the identified risk.

Where a disability or other protected characteristic is relevant, {{org_field_name}} will consider its legal duties, including the duty to make reasonable adjustments where applicable. Occupational-health advice will be obtained where necessary.

A worker’s vaccination status will not, by itself, be used as an automatic basis for disciplinary action, dismissal, exclusion from the workplace or adverse treatment. Any decision affecting duties or deployment will be based on an assessment of the actual risks, available control measures, current guidance and the individual circumstances.

Confidentiality will be maintained throughout the process, and health information will be disclosed only where there is a lawful and necessary reason to do so.

8. Policy Review

This policy will be reviewed annually or immediately if:

• New vaccination guidance is released by the Department of Health or NHS England
• There is an outbreak or public health concern requiring policy revision
• A significant change occurs in our organisational structure or delivery model

The review will be conducted by the Registered Manager in collaboration with the Infection Control Lead and senior management team.

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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.