COVID-19 vaccination for federal public service managers

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Responsibilities under the Policy

Managers, under the Policy on Vaccination, are responsible for:

  • ensuring 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)
  • reviewing 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
  • responding 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.
  • supporting the deputy head’s responsibilities related to the protection of privacy under the Privacy Act and its related instruments and other applicable legislation, including:
    • complying 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,
    • ensuring 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.
  • maintaining a respectful, productive, inclusive, and equitable environment.

Determining accommodation requests

Making an Informed Decision

  • The manager should decide on a response to the accommodation request at the earliest opportunity or no later than the full implementation date.
  • The manager should consult internal subject matter experts or guidance regarding the accommodation measure(s), including any related implications (e.g., security, technology, financial), if required.
  • The manager should work with employee representatives when requested by the employee and/or if others are affected by the accommodation decision.
  • The manager is required to consider requests for accommodation no matter the date of receipt of such a request.

Implementing accommodation when warranted

Once approved, accommodation should be provided up to the point of undue hardship. Given the public health considerations, the choice of accommodation should also ensure the safety and security of the workplace, along with privacy obligations.


The manager must promptly advise the employee of the decision, the rationale for the decision, the accommodation to be provided, if applicable, and the steps that must be taken to implement it:

  • The manager should consult with the employee regarding the best approach to explaining the accommodation to anyone affected by the measures, if necessary.
  • If a decision has been taken that the accommodation is not warranted, the manager will treat the situation as an employee unwilling to be vaccinated. The date of the accommodation decision will be the effective date as defined in the Policy for the purposes of determining the timing of follow-up steps.

Information management

  • The manager will document the process, supporting materials provided, the decision (including the accommodation measure, if applicable), and any follow-up actions in accordance with departmental standards and the Privacy Act.
  • Communication with others should be limited to a need-to-know basis for implementing the accommodation.
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