Statement on the Government of Canada’s vaccine passport for travel initiative

The federal government has consulted our office on the standardized proof of vaccination for travel initiative (vaccine passports) and we have had a number of constructive discussions with government officials over the last few months.

Vaccine passports may offer significant public health benefits but they remain exceptional measures. They should only be imposed after careful consideration of privacy and other human rights principles.

Earlier this year, our office, along with our provincial and territorial counterparts, issued a joint statement on privacy and COVID-19 vaccine passports.

In particular, the statement says that in order to be justified, vaccine passports must be necessary to achieve their intended public health purposes. Their effectiveness in achieving these purposes should also be evidence-based.

Further:

• the privacy risks associated with the initiative must be proportionate to the public health purposes;
• the personal information collected should be limited to that which is necessary for the intended public health purposes;
• the information should be used only for the intended public health purposes and no other; and
• the initiative should be time limited.

The government has provided us with information relevant to each of these criteria. As mentioned, we have had constructive discussions with government officials about these issues.

That being said, in recent days, our office has received a number of complaints related to the government’s COVID-19 vaccination requirement for federal public servants. We will therefore be investigating the application of privacy principles in this context.

Although the initiatives are distinct, the principles applicable to vaccine passports for travel and to the vaccination requirement for federal public servants are the same. It would therefore be inappropriate to offer conclusions until we have completed our investigations.

Given the complaints about the public service vaccination requirement are now the subject of ongoing investigations, no further details can be provided.