The Italian Data Protection Authority (Garante) has issued detailed guidelines on data processing activities in the context of workplace vaccination campaigns and on the role of the so-called “competent doctor” (medico competente).
The new guidelines confirm the general principle already outlined in the Garante’s FAQs: The employer is not entitled to collect any vaccine-related information (including the employee’s willingness to get vaccinated or whether the employee has been vaccinated), either directly from the data subject, or indirectly through the competent doctor or other health professionals.
In particular, the Garante has further clarified that: