Registration Number: {{org_field_registration_no}}

Staff Vaccination Policy

1. Purpose

The purpose of this policy is to set out how {{org_field_name}} will manage staff vaccination and immunisation as part of its wider infection prevention and control (IPC), occupational health, and risk management arrangements for domiciliary care services in England.

This policy is designed to:

reduce the risk of transmission of vaccine-preventable infections to service users, staff, visitors, and others;
support the delivery of safe care and treatment;
ensure that staff are protected, so far as reasonably practicable, in the course of their work;
ensure that decisions about vaccination are informed by current national guidance, individual and role-specific risk assessment, and the needs of the people we support;
support compliance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Code of Practice on the prevention and control of infections, and current Care Quality Commission (CQC) expectations.

Vaccination is an important part of safe care, but it operates alongside other control measures including hand hygiene, use of personal protective equipment (PPE), respiratory hygiene, safe working practices, environmental cleaning, safe waste disposal, reporting, training, and management oversight.

2. Scope

This policy applies to all persons working for or on behalf of {{org_field_name}} where their role may create a risk of transmitting infection or of occupational exposure to infection, including:

employees;
bank staff;
agency workers;
volunteers;
students and trainees;
contractors and any other persons deployed to deliver or support regulated activities.

This policy applies to staff working in:

service users’ homes;
the office base;
the community; and
any other location where work is undertaken on behalf of the organisation.

This policy covers:

vaccination and immunisation requirements determined by national guidance and risk assessment;
pre-employment and ongoing occupational health screening;
staff information, consent, and access to vaccination;
individual risk assessment where vaccination is declined, contraindicated, incomplete, or unavailable;
record-keeping, confidentiality, and data protection;
management action during outbreaks or increased infection risks;
staff training, supervision, audit, and review.

This policy should be read alongside the organisation’s Infection Prevention and Control Policy, PPE Policy, Risk Assessment Policy, Recruitment Policy, Data Protection/Confidentiality Policy, Sickness and Absence Policy, and Health and Safety arrangements.

3. Legal and Regulatory Framework

This policy is informed by and should be implemented in line with the following legislation, regulations, codes, and guidance, as amended from time to time:

Health and Social Care Act 2008;
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, in particular:
- Regulation 12: Safe care and treatment;
- Regulation 17: Good governance;
- Regulation 18: Staffing;
- Regulation 19: Fit and proper persons employed;
Health and Social Care Act 2008: Code of Practice on the prevention and control of infections and related guidance;
current Care Quality Commission (CQC) guidance on infection prevention and control and compliance with the Fundamental Standards;
current UK Health Security Agency (UKHSA), GOV.UK, NHS and occupational health guidance on immunisation of health and social care workers, including the Green Book;
Equality Act 2010;
UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018;
Health and Safety at Work etc. Act 1974 and associated health and safety duties, where relevant.

The organisation will keep this policy under review and will apply the most current national guidance in force at the relevant time.

4. Vaccination and Immunisation Requirements

{{org_field_name}} does not operate a blanket approach to vaccination. Vaccination and immunisation requirements will be based on current national guidance, the nature of the staff member’s role, the risks associated with the people they support, the tasks they undertake, and any individual clinical advice.

4.1 General principles

The organisation will:

encourage uptake of relevant vaccines for all eligible frontline staff;
make vaccination information available in an accessible and evidence-based way;
offer or arrange access to vaccination where this is part of employer responsibility or occupational health arrangements;
undertake individual risk assessments where a vaccine is declined, contraindicated, delayed, or incomplete;
avoid describing a vaccine as “mandatory” unless there is a current legal requirement or a lawful and proportionate role-specific requirement supported by a documented risk assessment and HR process.

4.2 Vaccines that may be relevant to staff

Depending on role and risk, staff may be advised, offered, or expected to discuss the following with occupational health or their GP:

Influenza (flu): all eligible frontline staff should be encouraged to receive annual flu vaccination to reduce the risk of transmission to vulnerable people.
COVID-19: staff should be supported to access COVID-19 vaccination in line with current national guidance and eligibility arrangements.
Hepatitis B: should be considered for staff whose work creates a risk of exposure to blood or blood-stained body fluids, sharps injury, or other relevant occupational exposure.
MMR (measles, mumps and rubella): staff without evidence of satisfactory immunity should be identified through screening and managed in line with current guidance.
Varicella (chickenpox): relevant for staff without immunity where role-related exposure risks arise.
Other vaccines as indicated by national guidance, occupational health advice, outbreak management arrangements, travel requirements linked to work, or specific service-user risks.

4.3 No blanket statement of legal mandate

At the time of review, this policy does not treat flu or COVID-19 vaccination as a general legal condition of deployment for domiciliary care staff in England. Any future statutory requirement or change in national policy will be implemented once in force and this policy will be updated accordingly.

5. Informed Decision-Making and Staff Responsibilities

Staff are expected to:

engage with vaccination and occupational health discussions honestly and promptly;
provide accurate information where asked to do so lawfully and proportionately;
notify the organisation of any relevant change that may affect safe deployment, such as confirmed infectious illness, exposure, or clinical advice;
comply with risk assessments, PPE requirements, and infection prevention controls;
attend training and follow reporting procedures.

Managers must:

ensure staff understand this policy;
support informed and respectful discussion;
avoid pressure, stigma, or unsafe assumptions;
ensure decisions are documented and reviewed;
escalate concerns where a staff member’s deployment may create avoidable risk to service users or colleagues.

6. Data Protection and Access to Records

Vaccination and immunisation information held under this policy will be treated as confidential health information. The organisation will:

identify and document an appropriate lawful basis and condition for processing;
inform staff, through privacy information and relevant policies, what data is collected, why it is needed, who may access it, and how long it will be kept;
limit access to those with a legitimate role-related need to know;
ensure data is accurate, relevant, and not excessive;
store records securely and dispose of them safely in line with retention requirements.

Staff may request access to their personal data in accordance with data protection law and organisational procedures.

7. Vaccination Procedures, Occupational Health Screening, and Record-Keeping

To support safe deployment and regulatory compliance, the organisation will maintain a clear process for vaccination and immunisation management.

7.1 Pre-employment and onboarding

Before deployment, and so far as appropriate to the role, the organisation will:

obtain relevant occupational health information;
identify whether the role involves contact with clinically vulnerable people, exposure-prone tasks, exposure to blood or body fluids, or work during outbreaks;
review available evidence of vaccination, immunity, or occupational health advice where relevant and proportionate;
identify whether any follow-up action, restrictions, or risk control measures are needed before the individual undertakes unsupervised work.

7.2 Ongoing review

The organisation will keep staff vaccination-related risk under review:

during annual health and safety / IPC review processes;
when national immunisation guidance changes;
when a staff member changes role or duties;
during outbreaks, incidents, or increased infection risks;
where there is known exposure to a vaccine-preventable disease.

7.3 Access to vaccination

Where relevant, the organisation will:

signpost staff to NHS or GP vaccination services;
arrange employer-led or occupational health vaccination programmes where appropriate;
provide timely information about seasonal vaccination programmes, including annual flu arrangements;
support staff to obtain advice where they are unsure of their vaccination status or clinical suitability.

7.4 Records

The organisation will keep accurate and proportionate records of:

whether vaccination or immunisation review has been considered for the role;
occupational health advice received;
evidence provided by the staff member where relevant;
vaccine offers made by the organisation, where applicable;
whether a vaccine was accepted, declined, deferred, contraindicated, or not required following assessment;
any associated risk assessment and control measures;
review dates and follow-up actions.

7.5 Confidentiality and data protection

Vaccination and immunisation information is health information and will be processed confidentially, lawfully, fairly, and only to the extent necessary for employment, health and safety, infection prevention and regulatory compliance purposes. Access will be restricted to authorised persons with a legitimate need to know. Records will be stored securely, kept accurate and up to date, and retained in accordance with the organisation’s retention schedule and data protection arrangements.

8. Individual Assessment, Contraindications, Declines, and Reasonable Adjustments

The organisation recognises that vaccination decisions may involve clinical, personal, cultural, religious, or belief-related issues. Each case will be considered individually, fairly, and proportionately.

A staff member may:

be unable to receive a vaccine because of a clinical contraindication or other medical advice;
be awaiting vaccination, booster dose, or evidence of immunity;
decline vaccination;
raise concerns linked to religion, belief, pregnancy, disability, or another protected characteristic.

Where vaccination is not undertaken, the organisation will not rely on assumptions. Instead, it will complete and document an individual risk assessment that considers:

the nature of the staff member’s duties;
whether they support people at increased clinical risk;
the likelihood and consequences of exposure or transmission;
whether other controls can reduce the risk sufficiently;
whether advice from occupational health, the staff member’s GP, or another clinician is required;
whether temporary or longer-term adjustments are reasonable and necessary.

Depending on the outcome of the assessment, controls may include:

reinforcement of hand hygiene and respiratory hygiene;
enhanced PPE requirements;
exclusion from certain higher-risk tasks;
temporary redeployment;
additional supervision or competency checks;
outbreak-specific restrictions;
prompt reporting and testing arrangements in line with current public health guidance.

All decisions will be recorded, kept under review, and managed in a way that is consistent with equality, health and safety, infection prevention, and employment obligations.

9. Infection Prevention, Home-Based Care, and Outbreak Management

Vaccination is only one part of infection prevention and control. The organisation will operate a whole-system approach to reducing infection risk in domiciliary care.

9.1 Working in people’s homes

Because staff work in domestic environments that are not under the organisation’s direct physical control, staff must assess and manage infection risks in each home setting, including:

the presence of known or suspected infectious illness;
opportunities for hand hygiene;
the safe use, storage, and disposal of PPE;
cleaning arrangements for equipment taken into the home;
waste handling and disposal arrangements;
risks linked to pets, clutter, ventilation, household smoking, and shared surfaces where relevant;
whether care tasks increase the likelihood of exposure to blood, body fluids, respiratory secretions, or contaminated items.

9.2 Standard precautions

All staff must follow standard infection prevention and control precautions, including:

effective hand hygiene before, during, and after care delivery as appropriate;
appropriate use of PPE based on task and risk assessment;
respiratory and cough hygiene;
safe handling of equipment, linen, waste, and sharps where applicable;
prompt reporting of exposure incidents and symptoms of infectious illness.

9.3 Staff illness and exposure

Staff must not attend work when they may place service users or colleagues at avoidable risk. Staff are required to report:

symptoms of potentially transmissible infection;
confirmed diagnosis of a relevant infectious disease;
significant contact or exposure, where this may affect safe deployment;
outbreaks or clusters affecting service users, staff, or households.

9.4 Outbreak or increased-risk response

Where there is an outbreak, suspected outbreak, or increased infection risk, the organisation may introduce additional control measures, including:

reviewing vaccination and immunity-related risk promptly;
updating service-user and staff risk assessments;
increasing PPE requirements;
restricting staff movement between service users or work settings;
redeploying staff where necessary;
seeking advice from public health, infection control, commissioners, local authority teams, or other relevant agencies;
ensuring communication with staff, service users, families, and professionals is timely and appropriate.

10. Staff Training, Information, and Competence

The organisation will ensure that staff receive appropriate information, instruction, training, and supervision in relation to vaccination and infection prevention and control.

This will include, where relevant to role:

induction on infection prevention and control;
vaccination awareness as part of safer working practices;
blood-borne virus awareness and post-exposure actions where relevant;
use of PPE and hand hygiene;
recognising and reporting infectious symptoms, exposure incidents, and outbreaks;
the organisation’s arrangements for occupational health referral and risk assessment;
role-specific updates when national guidance changes.

Training must be supported by:

competency assessment where appropriate;
supervision and spot checks;
refresher training at intervals determined by the organisation’s training matrix, risk profile, and current guidance;
management oversight to ensure learning is embedded in practice.

Staff must be able to explain how vaccination fits within broader infection prevention and control measures and must not assume that vaccination alone removes the need for safe practice.

11. Equality, Fairness, and Non-Discrimination

The organisation will implement this policy in a fair, respectful, and non-discriminatory manner. Decisions will not be based on assumptions or blanket rules. Where a staff member raises issues related to disability, pregnancy, religion, belief, or another protected characteristic, the organisation will consider the matter individually and proportionately, taking account of clinical advice, service-user safety, role requirements, and legal obligations.

Any concerns, objections, or requests for adjustment will be handled sensitively and documented appropriately.

12. Compliance, Monitoring, Audit, and Governance

The Registered Manager, or delegated senior person, is responsible for overseeing implementation of this policy.

The organisation will monitor compliance by:

auditing staff vaccination and immunisation records on a proportionate and lawful basis;
checking that role-specific risk assessments are completed and reviewed;
monitoring uptake of relevant vaccination programmes, particularly seasonal campaigns such as flu;
reviewing incidents, outbreaks, sickness trends, exposure events, and lessons learned;
checking that staff training, supervision, and competency requirements are met;
ensuring records are complete, secure, accurate, and available for inspection where required.

Where gaps are identified, the organisation will:

complete an action plan;
allocate responsibility and timescales;
review progress through governance and quality assurance processes;
amend practice, training, or policy as required.

Evidence of monitoring, review, and improvement will be maintained to support compliance with Regulation 17: Good governance.

This policy will be reviewed at least annually and sooner where there is a change in legislation, CQC guidance, UKHSA/GOV.UK guidance, occupational health advice, service need, learning from incidents or outbreaks, or any organisational change affecting its operation.

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.

DC141-Staff Vaccination Policy