Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police

Date modified: 2021-10-06
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1. Effective Date of this Policy

  • 1.1This policy takes effect on October 6, 2021.

2. Authorities

  • 2.1This policy is issued pursuant to sections 7 and 11.1 of the Financial Administration Act.
  • 2.2The Treasury Board has delegated to the President of the Treasury Board the authority to:
    • 2.2.1Issue, amend or repeal directives associated with this policy on the recommendation of the Secretary of the Treasury Board and the Chief Human Resources Officer, provided they are consistent with the overall intent of the Policy and there are no financial implications.
  • 2.3The Treasury Board has delegated authority to the Chief Human Resources Officer to:
    • 2.3.1Make technical amendments to this policy and related instruments.
    • 2.3.2Determine the effective dates of the instruments specified in paragraph 2.2.1, where the dates have not been specified by the Treasury Board or the President of the Treasury Board.
    • 2.3.3Issue, amend or repeal standards associated with this policy provided they are consistent with its overall intent and do not have financial implications.
    • 2.3.4Direct deputy heads with respect to:
      • 2.3.4.1Their responsibilities related to this policy.
      • 2.3.4.2Any oversight, systems, information requirements, or compliance and reporting in respect of those responsibilities.
      • 2.3.4.3Any appropriate action to address non-compliance issues.
      • 2.3.4.4Other measures to assess whether requirements of this policy or its supporting instruments have been met.

3. Objectives and Expected Results

  • 3.1The objectives of this policy are as follows:
    • 3.1.1To take every precaution reasonable, in the circumstances, for the protection of the health and safety of employees. Vaccination is a key element in the protection of employees against COVID-19.
    • 3.1.2To improve the vaccination rate across Canada of employees in the core public administration through COVID-19 vaccination.
    • 3.1.3Given that operational requirements may include ad hoc onsite presence, all employees, including those working remotely and teleworking must be fully vaccinated to protect themselves, colleagues, and clients from COVID-19.
  • 3.2The expected results of this policy are as follows:
    • 3.2.1All employees of the core public administration are fully vaccinated unless accommodated based on a certified medical contraindication, religion, or another prohibited ground for discrimination as defined under the Canadian Human Rights Act.
    • 3.2.2All organizations within the core public administration monitor implementation of this policy and report on its implementation to the Office of the Chief Human Resources Officer.
    • 3.2.3Personal information is only created, collected, retained, used, disclosed, and disposed of in a manner that respects the provisions of the Privacy Act and other applicable legislation.

4. Requirements

Deputy Heads

  • 4.1

    Deputy heads are responsible for the following:

    Implementation

    • 4.1.1Implementing this policy within their organization.
    • 4.1.2Complying with direction received from the President of the Treasury Board, the Secretary of the Treasury Board, or the Chief Human Resources Officer regarding how to implement this policy.
    • 4.1.3Ensuring that their organization complies with any oversight, systems, information requirements, or reporting established by the Chief Human Resources Officer regarding the implementation of this policy, including:
      • 4.1.3.1Collecting and storing data and information regarding vaccine attestations, testing, and testing results in any system prescribed by the Chief Human Resources Officer.
    • 4.1.4Obtaining a waiver from the Chief Human Resources Officer if their organization is unable to comply with any oversight, systems, information requirements, or reporting established by the Chief Human Resources Officer regarding the implementation of this policy.
    • 4.1.5Providing training related to the requirements set out for employees pursuant to this policy and tracking records of attendance when applicable.
    • 4.1.6Collecting and storing attestation and consent forms once signed for those unable to use the Government of Canada Vaccine Attestation Tracking System (GC-VATS).
    • 4.1.7Conducting audits on attestations and consent forms.

    Duty to Accommodate

    • 4.1.8Implementing this policy and the Directive on the Duty to Accommodate for persons unable to be fully vaccinated by:
      • 4.1.8.1Ensuring that employees are informed of:
        • Their right to accommodation;
        • Procedures to be followed when seeking accommodation;
        • The employee’s responsibilities when seeking accommodation;
        • Any mandatory testing that needs to be undertaken as accommodation measures, where applicable; and
        • The organization’s approach to accommodation and privacy obligations to reassure employees that the workplace will be safe.
      • 4.1.8.2Ensuring that managers are informed of their responsibilities and obligations regarding:
        • Addressing requests for accommodation on a case-by case basis, in a timely manner, and up to the point of undue hardship for employees who are unable to be fully vaccinated based on a certified medical contraindication, religion, or another prohibited ground of discrimination as defined under the Canadian Human Rights Act, which could also include employees who are partially vaccinated;
        • The fulfilment of mandatory testing requirements as accommodation measures, where applicable; and
        • The relevant confidentiality and privacy considerations.
      • 4.1.8.3Implementing measures for employees unwilling to disclose their vaccination status, or who choose not to be fully vaccinated, without an approved accommodation.

    Respectful workplace

    • 4.1.9Ensuring a respectful, productive, inclusive, and equitable environment, including:
      • 4.1.9.1Ensuring that employees are aware that harassment or other prohibited conduct directed toward an individual for any reason, including based on their vaccination status, will not be tolerated.

    Privacy

    • 4.1.10Ensuring that personal information is collected and managed in accordance with the Privacy Act and its related instruments and other applicable legislation, including the institution's enabling legislation:
      • 4.1.10.1Ensuring that their privacy breach plans and procedures are up to date;
      • 4.1.10.2Ensuring that privacy breach plans and procedures are readily available to employees and managers; and
      • 4.1.10.3Ensuring that privacy breach plans include:
        • Immediate containment measures in the event of a privacy breach; and
        • Contact information for the relevant officials.

Managers

  • 4.2Managers are responsible for:
    • 4.2.1Ensuring that employees who report to them know how to enter their vaccine attestations and any associated data or information in any system prescribed by the Chief Human Resources Officer (i.e., the GC-VATS);
    • 4.2.2Reviewing vaccine attestations and any associated data or information entered by employees who report to them, for the purpose of validating that the information complies with the requirements;
    • 4.2.3Responding to employees’ requests for accommodation under the Duty to Accommodate, as outlined above, including:
      • Informing the employee of their obligations;
      • Gathering the relevant information;
      • Making decisions as to whether the duty to accommodate applies;
      • Implementing the decision by identifying the appropriate accommodation measures, which may include mandatory testing; and,
      • Documenting the process.
    • 4.2.4Supporting the deputy head’s responsibilities related to the protection of privacy under the Privacy Actand its related instruments and other applicable legislation, including:
      • 4.2.4.1Complying with responsibilities assigned to executives and senior officials who manage programs or activities involving the creation, collection, or handling of personal information under the Directive on Privacy Practices; and,
      • 4.2.4.2Ensuring that they are aware of and adhere to the requirements of the Privacy Act as well as the Policy on Privacy Protection and its related instruments and other applicable legislation.
    • 4.2.5Maintaining a respectful, productive, inclusive, and equitable environment.

Employees

  • 4.3Employees are responsible for:
    • 4.3.1Providing truthful information for the implementation of all aspects of this policy and any procedures, standards, or directives associated with this policy. Failure to do so could constitute a breach of the Values and Ethics Code for the Public Sector and may result in disciplinary action.
    • 4.3.2Disclosing their vaccination and testing status accurately as required by this policy.
    • 4.3.3Informing their manager of their need for accommodation based on a certified medical contraindication, religion, or another prohibited ground of discrimination as defined under the Canadian Human Rights Act at the earliest opportunity or by the attestation deadline, if possible.
    • 4.3.4Providing their manager with complete and accurate information necessary to identify appropriate accommodation, including information on relevant limitations, restrictions, and if they are partially vaccinated.
    • 4.3.5Cooperating and collaborating in good faith with their organization’s representative(s) to identify one or more means to accommodate such needs, which may include mandatory testing, and the reporting of the results, per Health Canada’s testing protocol.
    • 4.3.6Notifying their manager if their accommodation needs change.
    • 4.3.7Informing themselves of and adhering to the requirements of the Privacy Act, as well as the Policy on Privacy Protection and related instruments and other applicable legislation.
    • 4.3.8Attending training as required.
    • 4.3.9Refraining from directing harassment or any other prohibited conduct toward an individual for any reason, including their vaccination status or accommodation measures.

Secretary of the Treasury Board

  • 4.4The Secretary of the Treasury Board is responsible for:
    • 4.4.1Using authorities under the Policy on People Management to effect any mandatory training requirements related to this policy.

Chief Human Resources Officer

  • 4.5The Chief Human Resources Officer is responsible for:
    • 4.5.1Prescribing any oversight, systems, information requirements, or reporting for the purpose of implementing this policy; and
    • 4.5.2Reviewing the need for this policy and the policy contents, at a minimum every 6 months, and reporting the results to the President of the Treasury Board.

5. Roles and Responsibilities of Other Government Departments

  • 5.1The Treasury Board of Canada Secretariat is responsible for:
    • 5.1.1Assisting organizations within the core public administration by providing direction, guidance, and tools to support the vaccination of public service employees by:
      • 5.1.1.1Communicating timely information to deputy heads on vaccination considerations, as appropriate; and
      • 5.1.1.2Liaising with bargaining agents at a national level.
    • 5.1.2Addressing key COVID-19 vaccination-related labour relations issues with organizations of the core public administration, such as the employer’s obligations relating to occupational health and safety, work refusals, compensation, guidance on the use of leave, duty to accommodate, the collection, use and disclosure of personal information, general Information Management, and values and ethics.
    • 5.1.3Communicating guidance to organizations regarding the duty to accommodate, compliance with the Canada Labour Code, Part II and the National Joint Council Occupational Health and Safety Directive, specifically as it relates to COVID-19.
    • 5.1.4Providing support, advice, and guidance for the consistent implementation of this policy, including administrative measures related to unwilling employees.
    • 5.1.5Developing and managing the GC-VATS.
  • 5.2Health Canada’s Public Service Occupational Health Program is responsible for:
    • 5.2.1Providing occupational health advice and guidance to the core public administration related to COVID-19; and
    • 5.2.2Supporting the Treasury Board of Canada Secretariat in the implementation of this policy by providing occupational health advice.
  • 5.3Health Canada’s Testing Secretariat is responsible for:
    • 5.3.1Supporting the provision of testing (procurement and distribution);
    • 5.3.2Sharing information on testing supplies, guidance materials, and other relevant information as it relates to testing;
    • 5.3.3Establishing the testing protocol; and
    • 5.3.4Connecting organizations to share procedures, best practices, and lessons learned as it relates to testing.
  • 5.4Canada School of Public Service is responsible for:
    • 5.4.1Providing a learning platform for delivering COVID-19 information tools and or pre-recorded training sessions; and
    • 5.4.2Enabling course registration and completion tracking, including in each learner’s account in GCcampus, if they have one.

6. Application

  • 6.1This policy applies to all employees as defined in Appendix A. The principles of this policy apply equally to Interchange Canada Participants and volunteers.
    • 6.1.1Employees must comply with this policy regardless of whether they work onsite, remotely, or telework.
  • 6.2This policy does not apply to:
    • 6.2.1Members of the public receiving services (e.g., Service Canada, Veterans Affairs Canada, Canada Revenue Agency).
    • 6.2.2Locally engaged staff at missions abroad.
    • 6.2.3Members of the Canadian Armed Forces.

7. Consequences of Non-Compliance

  • 7.1For employees unwilling to be fully vaccinated or to disclose their vaccination status, as per Appendix A, the employer will implement the following measures:
    • 7.1.1Within 2 weeks of the attestation deadline, require employees to attend an online training session on COVID-19 vaccination;
    • 7.1.2At 2 weeks after the attestation deadline:
      • 7.1.2.1Restrict employees’ access to the workplace, off-site visits, business travel and conferences;
      • 7.1.2.2Place employees on administrative Leave Without Pay advising them not to report to work, or to stop working remotely, and taking the required administrative action to put them on Leave Without Pay;
  • 7.2For employees who are partially vaccinated as per Appendix A:
    • 7.2.1Partially vaccinated employees will be placed on Leave Without Pay if they have not received their second dose by 10 weeks after their first dose;
    • 7.2.2Employees who have been placed on Leave Without Pay and who become partially vaccinated will resume work and have their pay reinstated;
    • 7.2.3Partially vaccinated employees may be subject to temporary measures for the period of time for which they remain partially vaccinated.
  • 7.3“Other Leave With Pay (699)”, is not available for employees unwilling to be fully vaccinated or unwilling to disclose their vaccination status.
  • 7.4The Chief Human Resources Officer may direct deputy heads to take appropriate action to address non-compliance issues or may impose any other measures deemed appropriate to assess whether requirements of this policy or its supporting instruments and mandatory procedures have been met.
  • 7.5The costs of measures that may arise because of errors or inappropriate application of this policy, associated instruments, and mandatory procedures, will be paid by the organization, in accordance with existing reference levels.
  • 7.6These measures may include recommendations by the Chief Human Resources Officer to the Treasury Board to add conditions to, modify, or revoke the authority of deputy heads, including any measures allowed by the Financial Administration Act that the Treasury Board may determine appropriate.

8. References

9. Enquiries

  • 9.1Employees should direct enquiries to their manager.
  • 9.2Human resources advisors should direct enquiries about this policy to the office of their head of human resources, or their designate, who will contact the Office of the Chief Human Resources Officer, as required.

Appendix A: Definitions

Attestation deadline (date limite de présentation de l’attestation)

The date by which an employee’s attestations must be entered in the GC-VATS, or provided to managers if the employee does not have access to the GC-VATS:

  • October 29, 2021, including for employees on “Other Leave With Pay (699)” for reasons related to the pandemic; or
  • 2 weeks after return from leave if the return from leave is after October 15, 2021; or
  • 2 weeks after the date on which an employee has been informed of their manager’s decision that the duty to accommodate does not apply; or
  • For employees who, for reasons related to their current position, are unable to attest to their vaccination status, or do not have access to vaccines for the period extending from October 15th to October 29th, the attestation deadline is 2 weeks from the date they have access to each, as determined by their manager, and notwithstanding their leave status.
Clinical Trial Participants – Not fully vaccinated (as of October 6, 2021) (participants aux essais cliniques – pas entièrement vaccinés (à partir du 6 octobre 2021))

Employees who are participating, or have participated, in a Health Canada authorized COVID-19 vaccination study should be considered to be not fully vaccinated. Employees should use the accommodation process until such time that either:

  • The study is completed, Health Canada authorizes the COVID-19 vaccine, and the employee can disclose that they are fully vaccinated as per this policy.
  • The employee withdraws from the study or is informed they received a placebo, or Health Canada declines authorization of the study vaccine. At that time, the employee is expected to be vaccinated against COVID-19 with Health Canada authorized vaccine as per the Public Health Agency of Canada or the National Advisory Committee on Immunization (NACI) recommendations. The employee will be given 4 weeks from any of the preceding events occurring to begin their COVID-19 vaccine series unless they are eligible for a different accommodation. When they complete their primary vaccination, they should disclose this information as per this policy and will then be considered fully vaccinated and will no longer require accommodation.
  • There may be additional exceptions that would need to be addressed on an individual basis (e.g., participants in clinical trials outside of Canada, employees who received non-Health Canada approved vaccines outside of work-related postings).

Definition will be adjusted if and as required when the National Advisory Committee on Immunization (NACI) makes any future recommendations.

Employees (employés)

For the purpose of this policy, “employees” is used throughout to simplify the text.

It means employees of the core public administration (i.e., departments listed under schedules I and IV of the Financial Administration Act) as defined in sections 7 and 11 of the Financial Administration Act and includes the following regardless of whether they work on-site or telework (full time or part-time):

  • Indeterminate employees;
  • Determinate employees;
  • Members and reservists of the Royal Canadian Mounted Police; and
  • Internationally based public service employees.

For the purpose of this policy, it also includes:

  • Casual workers;
  • Students;
  • Visiting scientists working in Government of Canada laboratories;
  • Cadets, enrolled in the Royal Canadian Mounted Police Cadet Training Program, and other cadets/trainees (ab initio) enrolled in any federal public service training college or academy; and
  • The principles of this policy are applicable to Interchange Canada participants and volunteers.

These individuals are not entitled to certain benefits explained in this policy (e.g., leave provisions). Such benefits, and any other non-applicable terms, are not applicable to these individuals.

Unvaccinated employees are grouped in 3 categories
Partially vaccinated employees (employés partiellement vaccinés)
For the purpose of this policy “partially vaccinated employees” means employees who have received 1 dose of a Health Canada authorized vaccine, but who have not received a full vaccination series, and do not meet the definition of fully vaccinated below.
Employees unable to be fully vaccinated (employés qui ne peuvent pas être entièrement vaccinés)
For the purpose of this policy “employees unable to be fully vaccinated” means employees that cannot be fully vaccinated due to a certified medical contraindication, religion, or any other prohibited ground of discrimination as defined in the Canadian Human Rights Act.
Employees unwilling to be fully vaccinated (employés qui refusent d’être entièrement vaccinés)
For the purpose of this policy “employees unwilling to be fully vaccinated” means employees refusing to disclose their vaccination status (whether they are fully vaccinated or not), employees for whom accommodations for a certified medical contraindication, religion, or another prohibited ground of discrimination is not granted and where the employees are still unwilling to be vaccinated, and employees who have attested that they are unvaccinated.
Employer (employeur)
Under this policy, “employer” means a department or an agency of the core public administration including the Royal Canadian Mounted Police.
Full Implementation Date (date de mise en œuvre complète)
The date by which the testing regime will be in place for employees unable to be vaccinated, and at which consequences will begin to apply to those employees unwilling to be fully vaccinated.
Fully Vaccinated - COVID-19 (employees vaccinated in Canada as of October 6, 2021) (entièrement vacciné - COVID-19(employés vaccinés au Canada à partir du 6 octobre 2021))

People are considered fully vaccinated 14 days after they have either:

  • Received both doses of a Health Canada authorized vaccine that requires 2 doses to complete the vaccination series (as of September 16, 2021): Pfizer-BioNTech Comirnaty COVID-19 vaccine, Moderna Spikevax COVID-19 vaccine, or AstraZeneca Vaxzevria COVID-19 vaccine.
  • Received mixed dose vaccination series are accepted as long as it aligns with NACI Recommendations on the use of COVID-19 vaccines.
  • Received 1 dose of a Health Canada authorized vaccine that only requires 1 dose to complete the vaccination series (as of September 16, 2021): Janssen (Johnson & Johnson) COVID-19 vaccine.
  • For current residents of Quebec only, have had a laboratory-confirmed COVID-19 infection followed by at least 1 dose of a Health Canada authorized COVID-19 vaccine.

Definition will be adjusted if and as required when the National Advisory Committee on Immunization (NACI) makes any future recommendations.

Fully Vaccinated - COVID-19 (employees vaccinated outside of Canada as of October 6, 2021) (entièrement vacciné - COVID-19 (employés vaccinés à l’extérieur Canada à partir du 6 octobre 2021))

People are considered fully vaccinated 14 days after they have either:

  • Received 1 additional dose of an mRNA vaccine at least 28 days after a complete or incomplete course/series of a non-Health Canada authorized vaccine (e.g., may be applicable for public servants who were posted abroad who received a non-Health Canada authorized vaccination and have now returned to Canada).
  • Met the definition for fully vaccinated in the jurisdiction in which they currently reside (i.e., for public servants posted abroad who have not yet returned to Canada).
  • Received 3 doses of any COVID-19 vaccine regardless if they are Health Canada authorized vaccines or non-Health Canada authorized vaccines.

Definition will be adjusted if and as required when the National Advisory Committee on Immunization (NACI) makes any future recommendations.

Government of Canada Vaccine Attestation Tracking System (GC-VATS) (système de suivi des attestations de vaccination du Gouvernement du Canada – SSAV-GC)

GC-VATS is a user-friendly web platform within the Treasury Board of Canada Secretariat Application Portal (TAP). The GC-VATS will allow employees to attest to the status of their COVID-19 vaccinations and store the attestations.

GC-VATS will centrally store the attestations and provide access to aggregated data to the Treasury Board of Canada Secretariat, in compliance with the Privacy Act and the security requirements. Similarly, deputy heads and departmental Heads of Human Resources will have access to departmental-level aggregated data.

Vaccination (vaccination)
Vaccination is the term used for receiving a vaccine, usually through an injection.
Vaccine (vaccin)
A vaccine is a substance used to stimulate the immune system and provide immunity against one or several diseases, prepared from the causative agent of a disease, its products, or a synthetic substitute, treated to act as an antigen without inducing the disease.
Workplace (lieu de travail)
Means any place where an employee is engaged in work for the employee’s employer, as per the Canada Labour Code, Part II. For the purpose of this policy, this includes employees working on site, remotely, and teleworking (full time or part time).
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