The manner in which COVID-19 vaccination records are created and retained by Australian Government agencies will vary, depending on the business practices adopted by individual agencies and how the relevant information is collected and managed. The practices agencies adopt for collecting and retaining vaccination records should be in-line with advice from the Australian Public Service Commission (APSC Circular 2021/09) and the Fair Work Ombudsman, and may differ between jurisdictions according to the relevant public health orders in force.

Generally, a copy of the vaccination certificate will not need to be retained and agencies will simply have a supervisor of an appropriate level sight the vaccination certificate and then retain a record of the vaccination status of the employee.

The two most common scenarios for recording vaccination status are as follows:

• The vaccination certificate is sighted by the supervisor and an appropriate entry is made in the employee’s individual personnel file to record their vaccination status. This is similar to the recording of ‘medical reports and health declarations’ on an employee’s personnel record – the retention periods for which are set out under AFDA Express Version 2 – PERSONNEL MANAGEMENT, classes 62629 and 62641. If a similar process is adopted for volunteers (including students undertaking work placements), with their vaccination status recorded on their individual file, then these will be retained under PERSONNEL MANAGEMENT, classes 62638 and 62641.
• The vaccination certificate is sighted by the supervisor and the vaccination status is centrally recorded, such as in a COVID-19 vaccination register – either an organisation-wide register, or possibly a location specific register. Such an approach may be necessary in some situations to meet local public health orders. Where this approach is adopted the register is considered a work health and safety compliance record and will be retained in accordance with AFDA Express Version 2 – WORK HEALTH AND SAFETY, class 62652.

An agency may potentially use both methods. Recording the vaccination status on an individual’s personnel record and maintaining a local vaccination status register.

In both cases it is anticipated that once the vaccination certificate has been sighted and recorded the original certificate will be returned to the employee (as it is not Commonwealth property). Where this is not possible it should be securely destroyed as a Normal Administrative Practice. This is similar to a medical certificate to support personal leave, which may be returned to an employee once sighted by a supervisor.

In some circumstances an agency may determine that its business practice will involve creating and retaining a copy of an employee’s vaccination certificate – either to place on their individual personnel record or to store centrally. Regardless of whether the agency chooses to record the vaccination status or create and retain a copy of the vaccination certificate, the above AFDA Express Version 2 disposal classes will apply.

An employee’s vaccination status is considered sensitive health information and agency records containing this information should be kept secure and classified as ‘OFFICIAL: Sensitive’ (previously known as personnel-in-confidence). This will apply equally to records of employee vaccination status centrally recorded in COVID-19 vaccination registers and vaccination status information on individual employee’s personnel records. Only appropriately authorised personnel should have access to the vaccination status information.

Where Australian Government agencies require additional advice and guidance in relation to COVID-19 vaccination records, they should contact the Agency Service Centre.