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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 ensure that staff vaccination at {{org_field_name}} is managed in a way that protects the health and wellbeing of residents, staff, and visitors. In line with the Regulation and Inspection of Social Care (Wales) Act 2016, Control of Substances Hazardous to Health Regulations (COSHH) 2002, and the expectations of Care Inspectorate Wales (CIW), we recognise our duty to prevent and control the spread of infectious diseases within the care home setting.

Vaccinations are a critical part of our infection prevention and control (IPC) strategy, especially for seasonal illnesses such as influenza, and in light of the ongoing risks posed by COVID-19 and other vaccine-preventable infections such as hepatitis B. This policy outlines how our care home promotes, manages, records, and monitors staff vaccinations while respecting individual rights and complying with data protection laws.

2. Scope

This policy applies to all employees of {{org_field_name}}, including care staff, housekeeping, catering, maintenance, administration, agency workers, and volunteers. It also applies to students on placement and external professionals delivering services in our care home. While some vaccinations may not be mandatory, this policy aims to create a culture where vaccination is encouraged and facilitated to protect vulnerable people in our care.

3. Related Policies

This policy should be read alongside the following:

• CHW17 – Infection Prevention and Control Policy
• CHW16 – Health and Safety at Work Policy
• CHW21 – Medication Management and Administration Policy
• CHW02 – Fit and Proper Persons: Employed Staff Policy
• CHW27 – Staff Supervision, Training, and Development Policy
• CHW34 – Confidentiality and Data Protection (GDPR) Policy
• CHW13 – Safeguarding Adults from Abuse and Improper Treatment Policy

4. Policy Implementation and Operational Guidance

Vaccinations Covered

{{org_field_name}} will promote and facilitate vaccination for staff in accordance with current Welsh Government, Public Health Wales, Joint Committee on Vaccination and Immunisation (JCVI), UK Health Security Agency occupational immunisation guidance and occupational-health advice.

Vaccination is not a substitute for standard infection prevention and control measures.

There is no general requirement for care-home staff to be vaccinated solely because they work in a care-home service. Where an occupational risk assessment identifies that a member of staff may be exposed to a biological agent for which an effective vaccine is available, {{org_field_name}} will make appropriate arrangements for vaccination to be offered in accordance with the Control of Substances Hazardous to Health Regulations 2002, current national guidance and appropriate occupational-health advice.

Vaccinations that may be relevant include, depending upon current national recommendations, individual eligibility and occupational exposure:

• seasonal influenza vaccination;
• COVID-19 vaccination where the individual falls within a group currently eligible or recommended for vaccination under the Welsh vaccination programme;
• hepatitis B vaccination where occupational exposure to blood or other potentially infectious body fluids has been identified;
• measles, mumps and rubella vaccination where evidence of immunity is relevant to the role and current occupational-health guidance;
• varicella vaccination where indicated following occupational-health assessment; and
• other vaccinations, including BCG or pertussis vaccination, only where these are indicated by current national guidance, an identified occupational exposure or specific public-health advice.

The vaccination requirements and recommendations relevant to the service will be reviewed in consultation with {{org_field_infection_control_lead_name}}, the Infection Control Lead, occupational health where appropriate, and in response to changes in Welsh Government, Public Health Wales or other applicable national guidance.

Risk Assessment and Role-Based Requirements

{{org_field_name}} will assess occupational exposure to infectious biological agents as part of its health and safety and infection prevention and control arrangements.

The assessment will consider the actual duties undertaken by the member of staff and the nature, frequency and likelihood of occupational exposure. It will not assume that vaccination is required solely because a person belongs to a particular staff group.

Where an occupational risk assessment identifies a material risk of exposure to an infectious biological agent, appropriate control measures will be implemented. These may include safe systems of work, hand hygiene, personal protective equipment, safer sharps arrangements, environmental controls, training, occupational-health assessment, health surveillance where legally required and the offer of an effective vaccination where one is available and recommended.

Where evidence of vaccination, immunity or response to vaccination is relevant to the safe performance of a particular role, this will be determined through an appropriate risk assessment and current occupational-health or national immunisation guidance. Only information necessary to confirm the employee’s occupational fitness or the control measures required will be provided to management.

Vaccination will not be treated as a replacement for other reasonably practicable measures required to prevent or control exposure.

Promotion and Education

{{org_field_name}} will provide staff with clear, accurate and current information about vaccinations relevant to their work.

Where vaccination is offered as an occupational health and safety measure, staff will be informed of:

• the occupational infection risk that has been identified;
• the benefits of vaccination;
• any relevant limitations of vaccination;
• relevant risks or disadvantages of vaccination;
• the importance of continuing to follow infection prevention and control precautions irrespective of vaccination status; and
• how and where the vaccination can be obtained.

Seasonal influenza vaccination will be actively promoted to staff in accordance with the current Welsh vaccination programme and Public Health Wales guidance.

Vaccination information will be included, where appropriate, within induction, infection prevention and control training, staff communications and seasonal vaccination campaigns.

Where vaccination is required as a protective measure because of an occupational risk identified by {{org_field_name}}, appropriate arrangements will be made for staff to access the vaccination and the employee will not be required to bear the cost of that occupational protective measure.

Where appropriate, {{org_field_name}} will work with local health services, occupational-health providers, community pharmacies or other authorised vaccination providers to facilitate convenient staff access to vaccination.

Recording and Confidentiality

Information about an employee’s vaccination or immunisation status is health information and is special category personal data. It will therefore only be collected, recorded, accessed, used, retained or disclosed where {{org_field_name}} has identified an appropriate lawful basis and special category condition under applicable data-protection legislation and where the information is necessary and proportionate for the stated purpose.

Vaccination and occupational-health information will be handled confidentially and access will be restricted to persons who have a legitimate need to access the information.

Where occupational health is involved, managers will normally receive only the information necessary to determine whether the member of staff is fit to undertake their role and whether any precautions, restrictions or reasonable adjustments are required. Detailed clinical information will not routinely be provided to managers.

Records may include, where necessary and lawful:

• confirmation that an occupational vaccination has been offered;
• whether an occupational vaccination course has been completed where this information is necessary for the identified workplace risk;
• confirmation of immunity or response to vaccination where occupational-health guidance requires this;
• the date on which further occupational-health review or vaccination is due; and
• occupational-health advice concerning any restrictions, adjustments or additional control measures required.

{{org_field_name}} will not routinely require or record a member of staff’s reason for declining vaccination. Where information about a medical contraindication is necessary for occupational-health purposes, only the minimum information necessary for that purpose will be processed.

Where health surveillance is required under the Control of Substances Hazardous to Health Regulations 2002, the required occupational-health and health-surveillance records will be maintained in accordance with the applicable legal requirements.

All records will be securely stored and retained in accordance with {{org_field_name}}’s data protection and records-retention arrangements.

Declining Vaccination and Risk Management

Staff may decline an offered vaccination unless a specific lawful requirement applies to the particular circumstances. Staff will not routinely be required to provide a reason for declining an offered vaccination.

A decision to decline vaccination does not remove the employee’s responsibility to comply with infection prevention and control procedures, safe systems of work, personal protective equipment requirements and other measures implemented to protect residents, colleagues and other people.

Where a member of staff declines an occupational vaccination and the risk assessment identifies a continuing material risk of exposure or transmission, {{org_field_name}} will review the risk and determine whether further controls are required.

Depending upon the circumstances, this may include:

• occupational-health advice;
• additional infection prevention and control precautions;
• additional personal protective equipment;
• modification of particular duties;
• temporary deployment arrangements during an outbreak or other period of increased risk; or
• other reasonably practicable control measures.

Any restriction or change in duties will be based upon an individual and workplace risk assessment, current public-health guidance and occupational-health advice where appropriate. A member of staff will not automatically be excluded from duties solely because they are unvaccinated.

Any action taken will be necessary and proportionate to the identified risk and will take account of applicable employment, equality, health and safety and data-protection requirements.

Infection Control During Outbreaks

Where an outbreak or suspected outbreak of an infectious disease occurs, {{org_field_name}} will implement the current infection prevention and control and public-health guidance applicable to care-home services in Wales.

The Registered Manager and Infection Control Lead will ensure that the service:

• undertakes or reviews the relevant outbreak risk assessments;
• promptly implements additional infection prevention and control measures required by current guidance;
• obtains advice from the relevant health protection or public-health service where required;
• communicates necessary information and instructions to staff;
• supports access to vaccination where vaccination is recommended and available as part of the outbreak response;
• reviews staffing and deployment arrangements where this is identified as necessary through risk assessment;
• applies appropriate testing, personal protective equipment, isolation, exclusion from work or return-to-work measures where required by current national or public-health guidance; and
• maintains appropriate records of decisions and actions taken.

Vaccination status may be considered when making staffing or deployment decisions where this is supported by current Public Health Wales or other applicable national guidance and is relevant to the particular infectious disease and circumstances. Vaccination status will not, by itself, result in automatic exclusion or redeployment.

Bank, agency, temporary and other workers providing care within the service will be expected to comply with the same infection prevention and control requirements applicable to permanently employed staff.

CIW Compliance and Inspection Readiness

{{org_field_name}} will maintain evidence demonstrating that its staff vaccination arrangements form part of an effective system for infection prevention and control and occupational health and safety.

Evidence available for regulatory inspection, where relevant, will include:

• this policy and its links with the service’s wider infection prevention and control arrangements;
• relevant infection and occupational-exposure risk assessments;
• evidence that staff receive infection prevention and control information, instruction and training appropriate to their role;
• evidence that vaccination is promoted or offered where required by current national guidance or an occupational risk assessment;
• evidence of appropriate occupational-health arrangements;
• evidence of action taken in response to identified infection-control risks or outbreaks;
• audits and monitoring relating to the effectiveness of infection prevention and control arrangements; and
• evidence that identified concerns or shortfalls have resulted in appropriate action.

Individual vaccination information will only be made available where its disclosure is lawful, necessary and proportionate. Regulatory compliance does not require unrestricted access to individual employees’ confidential medical information.

Staff Welfare and Support

Vaccination discussions will be conducted respectfully, sensitively and confidentially.

Staff will be given opportunities to ask questions and will be directed to appropriate evidence-based information or occupational-health advice where required.

Staff will not be subjected to stigmatisation, harassment or inappropriate treatment because of a vaccination decision. Where an individual’s vaccination status creates a relevant occupational-health consideration, this will be managed through an appropriate risk assessment and proportionate safety measures.

Audit, Monitoring and Review

{{org_field_name}} will monitor the effectiveness of its staff vaccination and associated infection prevention and control arrangements.

Monitoring may include:

• uptake of seasonal or occupational vaccination programmes using aggregated or anonymised information wherever individual identification is unnecessary;
• evidence that eligible or occupationally exposed staff have been provided with appropriate information and access to vaccination;
• compliance with occupational-health recommendations;
• staff awareness of vaccination and infection prevention and control requirements;
• relevant findings from infection prevention and control audits;
• lessons identified from outbreaks or incidents; and
• actions arising from changes in national vaccination, occupational-health or infection prevention and control guidance.

Any vaccination uptake information used for management or quality-monitoring purposes will be limited to information that is necessary and proportionate and will be handled in accordance with data-protection legislation.

Findings from monitoring will be used to improve the service’s infection prevention and control arrangements and, where relevant, will contribute to the service’s quality monitoring and review arrangements.

5. Policy Review

This policy will be reviewed annually or earlier in response to:

Internal audit findings or outbreak analysis.

Emerging public health guidance or changes to recommended vaccination schedules.

Updates to CIW requirements or infection prevention best practice.

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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}}
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