Vaccine passes: protecting human rights and personal data

Council of Europe

At a time where vaccination campaigns are accompanied by a willingness to relax restrictions taken to protect public health against the threat of the COVID-19 pandemic, the issue of a “vaccine pass” is being raised in Europe as well as in other parts of the world.

In a statement on human rights considerations relevant to a “vaccine pass” and similar documents, the Committee on Bioethics is calling for careful deliberation on the challenges raised by such a pass and on the steps taken to ensure that the human rights and fundamental freedoms of all individuals are promoted and protected.

The Committee on Bioethics also concurs with the conclusions of the Secretary General of the Council of Europe that “combating the current pandemic depends, above all, on the increased efforts to produce and administer vaccines, with particular attention to people in vulnerable situations, so that restrictions to individual freedoms and constraints imposed can be progressively reviewed as the population acquires greater immunity, taking into account acquired scientific knowledge”.

In its statement, the Data Protection Convention Committee calls for data protection safeguards to be strictly respected in the Covid-19 national vaccination programmes as well as in certificates attesting vaccination, results of negative tests or a past infection. Noting the complex challenges related to protecting public health and combatting the pandemic, the committee welcomes the work that is being done to enable vaccination certificates to be harmonised and interoperable at European and international levels.

However, it also warns that the use of such vaccination certificates – or those containing the results of negatives tests or of a past Covid-19 infection – for non-medical purposes raises human rights issues which should be carefully considered, notably in respect of the right to data protection and the principle of non-discrimination. Therefore, all the digital tools used to limit infection, including those which require the processing of data on vaccination and negative tests, must respect the principles of necessity, proportionality and non-discrimination. In particular, data bases as they rely on sensitive data should be used ensuring strict respect of the right to data protection. The committee recommends decentralised solutions both for the storage of the data contained in these certificates, for example, on users´ mobile devices, and for the data collected by national IT systems supporting vaccination programmes.


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