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Primer for Mandatory COVID-19 Vaccination Policies

On September 3, 2021, the Middlesex-London Health Unit’s Medical Officer of Health issued a letter of recommendation to employers and business operators, calling on all businesses to implement workplace COVID-19 vaccination policies, requiring all employees, volunteers, and contractors who have in-person interactions to be vaccinated against COVID-19, with exceptions accommodated under exempted medical conditions and other protected grounds under the Ontario Human Rights Code.

Please see the guidance below to assist in the development of your workplace policies.


COVID-19 and Ontario’s Human Rights Code

Questions and Answers

The Ontario Human Rights Commission has developed a series of questions and answers for understanding your human rights and obligations during the COVID-19 pandemic. Read the Q&A here →

Vaccines are a safe and effective way to protect individuals from COVID-19

Vaccines are an important tool to help stop the spread of the virus, reduce the risk of outbreaks, and protect against serious illness. Vaccination is the single most effective public heath measure to reduce the spread of COVID-19.

Promoting vaccine uptake through mandatory vaccination policies can help to establish safe and supportive environments for staff and patrons. The Middlesex-London Health Unit strongly recommends that all employers and business operators require all employees, contractors, or visitors who are involved in any in-person activity to be fully vaccinated against COVID-19, with the rare exception of those individuals who cannot be vaccinated due to permitted exemptions (medical and other protected grounds under the Ontario Human Rights Code).

This primer provides guidance on steps that can be taken to establish a mandatory COVID-19 vaccination policy and provides examples of relevant policies and procedures.

Applicable Legislation

The policy should adhere to the Occupational Health and Safety Act, the Ontario Human Rights Code and applicable privacy laws.

The information provided in this primer is for general information purposes. It does not contain legal advice and should not be relied on or treated as legal advice. Those persons, businesses or organizations for whom these recommendations are intended are encouraged to seek their own legal advice with respect to their own specific workplaces, organizations, and circumstances.

Key components of a mandatory COVID-19 vaccination policy

1) Identify the scope and purpose

  • Explain the purpose of the policy including the risks of COVID-19 and to whom the policy applies (e.g., employees, contractors, students, volunteers and/or customers/patrons)
  • Highlight the benefits of having a high COVID-19 vaccination rate in the workplace, including reduced risk of infection and outbreak, reduced absenteeism, and enhanced staff and customer confidence in returning to the business.

2) List action steps employees must take

  • Workplace policies should require workers to provide one of the following:
    I. Proof of full vaccination:
    • Fully vaccinated means having received the full series of a COVID-19 vaccine or combination of COVID-19 vaccines approved by WHO (e.g., two doses of a two-dose vaccine series, or one dose of a single-dose vaccine series); and having received the final dose of the COVID-19 vaccine at least 14 days ago,
    • Methods of providing such proof could include a vaccination receipt (printed or electronic – i.e. from the Government of Ontario's website), or a government-led proof-of-vaccination system;

II. Written proof of a medical reason (APPENDIX C – Sample COVID-19 Vaccination Medical Exemption Form), provided by a licensed physician or nurse practitioner that sets out:

    • A documented medical reason for not being fully vaccinated against COVID-19, AND
    • the effective time-period for the medical reason;

III. A signed written declaration from a person who is not able to obtain COVID-19 vaccine for a reason related to a protected ground under the Ontario Human Rights Code, including a description of the need for protection and accommodation.

3) Set deadlines for individuals to complete these steps

  • Specify a reasonable date for individuals to demonstrate compliance with the policy.
  • For example, all staff are required to be fully vaccinated with a COVID-19 vaccine series by October 30, 2021. Staff must receive one dose of COVID-19 vaccine by September 30, 2021, and their second dose of COVID-19 vaccine by October 30, 2021.

4) List available supports for vaccination

  • Provide information about COVID-19 vaccines from credible sources such as the Ministry of Health and the Middlesex-London Health Unit.
  • Provide the link to the MLHU website about where to get vaccinated in the Middlesex-London region.
  • Where possible, provide paid leave and/or transportation to staff to get vaccinated.
  • Offer flexible hours or paid sick days if staff have side effects after getting vaccinated.

5) Establish provisions for unvaccinated individuals

  • Alternative options should be available for individuals not yet eligible to receive the COVID-19 vaccine (e.g., those under age 12) and individuals who decline the vaccine for medical exemptions and/or reasons protected by the Ontario Human Rights Code.
  • Options may include staff reassignment, relocation, modified work, or use of additional personal protective equipment. Rapid testing protocols can also be considered (APPENDIX E – Sample COVID-19 Rapid Antigen Testing Procedure). It is important to note that these protocols are not preventive and are not a replacement for immunization and should be used only in instances where vaccination is not possible. Learn more about Rapid Antigen Testing →
  • If relocation or reassignment is not possible, consider if unvaccinated workers may use vacation or unpaid leave until some later time when it is safe for them to return to the workplace.

6) Establish consequences for non-compliance

  • Outline consequences for staff and patrons who do not fulfil the requirements of the policy.
  • Staff who do not comply with the policy may be subject to discipline, up to and including dismissal.

7) Address privacy considerations

  • The policy should protect a worker’s privacy as much as possible and specify how individual vaccination status of workers will be used, shared and disposed of by employers.
  • Information about workers’ vaccination information must be protected in accordance with applicable privacy legislation. Knowing your workers’ vaccination status may be important to help you take appropriate action quickly, in the event of COVID-19 cases in your workplace, to protect workers, their families, and the general public.
  • When collecting, sharing, storing and disposing of information about a worker’s vaccination status, identify ways to safeguard workers’ personal health information:

I. Limit information collected to the worker’s name and date of vaccination for each dose.
II. Keep worker vaccination information separate from their personnel file.
III. Individuals should be instructed to use the least intrusive mechanism to disclose vaccination status. Limit information collected to what is necessary.
IV. Ensure personal health/vaccination information is stored securely and protected in accordance with privacy legislation. It should only be used when required.

8) Designate staff contact

  • Identify who staff should contact for questions about the policy and to whom individuals should disclose proof of vaccination.

9) Continued compliance with all COVID-19 prevention measures

  • Individuals must continue to comply with COVID-19 prevention measures as outlined by the Ontario government and Middlesex-London Health Unit, including screening, wearing a mask or face covering, physical distancing, hand hygiene, and monitoring for symptoms of COVID-19.

10) Ensure open and transparent communication

  • Have a clear communication plan for staff and patrons to introduce the policy.
  • Establish continuous dialogue with staff and patrons to provide education as necessary, and to manage understanding and expectations related to the mandatory vaccine policy and COVID-19 prevention measures.
Date of creation: September 3, 2021
Last modified on: September 16, 2021