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At the outset, let me say that I will not dwell extensively on the analysis of whether data on the desire to be vaccinatd are data of a special category. Recital 35 of the GDPR preamble is decisive here, which indicates that health data also includes data collectd when registering for a healthcare service. Vaccination against Covid-19 undoubtdly counts as a healthcare service.

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Health care is understood as the health services providd to patients by health professionals in order to assess, maintain or improve database their state of health . In the further part of the considerations, it should be notd that at the time of writing this text, there are no applicable regulations regulating the scope of data collectd as part of vaccinations at the workplace and the role of the employer in the processing of personal data.


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At this point, an important document that regulates the discussd issue is the guidelines for the organization and implementation Phone Lead of vaccinations in workplaces, developd by, among others, team of the Chancellery of the Prime Minister and the Ministry of Health. The guidelines emphasize that the employer is responsible, among others, for: for: “establishing cooperation with a mdical entity that will carry out vaccinations, collecting a list of employd employees willing to be vaccinatd and statements of consent to the processing of personal data, as well as correctly.

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