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Cayman Islands: Ombudsman issues guidance for employers on employee vaccination status checks
The Office of the Ombudsman released, on 15 October 2021, general guidance for employers on employee vaccination status checks. In particular, the guidance is issued in light of recently approved vaccination requirements regarding work permit applications and renewals in the Cayman Islands and provides employers with general guidance on data protection issues to consider before recording employees' COVID-19 vaccination status. Specifically, the guidance details, among other things, that businesses should:
- produce a written policy stating how employees' vaccination checks will be done, and for what purpose;
- not use this information for incompatible purposes other than those for which it was collected;
- ensure that processing of personal data is justified with a legal basis;
- have in place additional measures to protect the use of this data as it is classified as sensitive personal data; and
- ensure that they only collect the minimum amount of personal data necessary, hold it only for as long as is needed for the initial purpose, and ensure that it is held securely, with access granted only to those who need to see it.
You can read the guidance here.
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