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Completing the application form (equivalent to readiness to vaccinate reportd employees)” . Please note, however, that these guidelines are not legally binding. When establishing cooperation with a mdical entity, the employer should clearly determine the rules for processing employees’ personal data at the stage of concluding the contract. The mdical entity will undoubtdly be a separate data controller of persons who decide to be vaccinatd.

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It will be his responsibility to conduct qualifications for vaccination, perform them, and above all, prepare mdical documentation and database issue vaccination cards. The role and obligations of the healthcare entity seem clear and do not require further discussion. But what about the employer? As the guidelines indicate, after establishing cooperation with a mdical entity and providing an approximate number of people willing to be vaccinatd (there is no ned to provide any personal data), the employer is also responsible.


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For ensuring appropriate safety conditions in the case of vaccination at the workplace and covering additional costs that will arise during the organization of vaccinations. In none of these cases, personal data will not be nedd by Phone Lead the employer. The indicatd guidelines point to one more obligation of the employer – to collect consent to the processing of personal data. However, it has not been specifid from whom this consent is to be collectd – whether from the employer or the mdical entity. If on behalf of a mdical entity, it seems that the consent to the processing of data of a special category under GDPR will not be the appropriate legal basis for data processing.

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