Covid-19 Vaccination policy

1. PURPOSE

The purpose of this policy is to provide information on the measures regarding COVID-19 vaccinations being taken by Brisbane Catholic Education (“BCE") to:

  • protect the health and safety of our people, students, school communities, and members of the public;
  • ensure compliance with Government Health Directions and more particularly, the COVID-19 Vaccination Requirements for Workers in a high-risk setting Direction - Public Health Act 2005 (Qld); and
  • outline the limited exemptions available.

2. SCOPE

This policy applies to all employees, contractors, and volunteers of Brisbane Catholic Education (“Workers").

3. POLICY STATEMENT

Brisbane Catholic Education is committed to health and safety and to preventing the spread of vaccine-preventable diseases such as COVID-19. In addition, a Queensland Government Health Direction has been issued, which is applicable to the education sector, and which requires workers to be fully vaccinated against COVID-19 to attend work.

BCE recognises that having a vaccination, including those related to COVID-19, is a personal choice. However, in order for BCE to comply with the Health Direction (and any other Health Directions which replace it from time to time), meet its workplace health and safety obligations and its duty of care to the people its Workers interact with, BCE requires all Workers to receive their first dose of an approved COVID-19 vaccination by 17 December 2021 and their second dose by 23 January 2022.

This is a lawful and reasonable direction that BCE is issuing to comply with the Health Direction and as part of its duty of care (including under workplace health and safety laws) to keep its Workers and the broader community safe.

Failure to cooperate and comply with this policy may result in disciplinary action, including employees being stood down without pay or use of accrued leave and/or other consequences.  Workers who are not employees of BCE (being contractors or volunteers) will not be permitted to work at any BCE site (including Schools, Colleges or Offices) until they are able to demonstrate compliance with this policy.

4. VACCINATION REQUIREMENTS

4.1 By 17 December 2021 (for first dose) and 23 January 2022 (for second dose), all Workers must:

4.1.1 ​have received relevant dose(s) of a COVID-19 vaccination, subject to the very limited exceptions set out below under '4.4 Exceptions to COVID-19 Vaccination Requirements/Valid Medical Exemptions';

4.1.2 record suitable proof of these vaccinations within the required system being the Ascender Web Self Service (WSS) portal. (BCE employees only); and

4.1.3 provide suitable evidence of these vaccinations to BCE on request.

4.2 Evidence of a COVID-19 vaccination includes:

​​4.2.1 Vaccination information displayed on the Check In Qld app (preferred); or

4.2.2. a COVID-19 digital vaccination certificate (accessible at the MyGov website or Express Plus Medicare mobile app);

4.2.3 an immunisation history statement which can be accessed from Medicare online; or

4.2.4 an International COVID-19 Vaccination certificate.

Employees may redact their individual healthcare identifier (IHI) before providing evidence. 

4.3 Scheduling of Vaccinations

Workers are responsible for making their own arrangements to receive their vaccinations.

If an employee is unable to present to work as a result of their COVID-19 vaccination, they will be able to access their personal leave (where applicable). Should an employee require more time to recover, normal arrangements regarding employee illness will apply.

4.4 Exceptions to COVID-19 Vaccination Requirements/Valid Medical Exemptions

Sections 4.1 and 4.2 do not apply to a Worker who is unable to receive a COVID-19 vaccination because they have a recognised medical contraindication (a medical condition that prevents them from receiving the vaccination) and where BCE:

4.4.1 assesses (and deems acceptable) the risk to other workers and other persons at a BCE site (including Schools, Colleges or Offices); and

4.4.2 the worker undertakes a COVID-19 PCR test before starting work each day and provides a negative test result to the responsible person for the BCE site (including School, College or Office) as soon as reasonably practicable after the result is received; and

4.4.3 the worker uses personal protective equipment as required by the responsible person for the BCE site (including School, College or Office).

In these circumstances, a person should consult with their Principal/Manager to see if any suitable alternative duties can be accommodated.  If a Worker believes that they are medically exempt from the vaccination   requirements set out in this Policy, or that other exceptional circumstances apply, they must notify their Principal/Manager by close of business on the day before 17 December 2021 (for first dose), or the day before 23 January 2022 (for second dose).

​4.5 Evidence of Medical Contraindication 

A worker at a BCE site (including School, College or Office) where section 4.4 applies must provide evidence of the medical contraindication.

Evidence of a medical contraindication is a digital or paper COVID-19 vaccine medical exemption recorded on the Australian Immunisation Register, or an Australian Immunisation Register immunisation medical exemptions form completed and signed by an eligible health professional for the COVID-19 vaccine.

A medical contraindication against one COVID-19 vaccine does not necessarily translate to a contraindication against all vaccines.

Where the person has a temporary medical contraindication which prevents them from being able to receive the COVID-19 vaccination, the exemption only applies for the period specified.

If the medical contraindication continues beyond the specified period, the person must provide new evidence of a continuing medical contraindication or of their COVID-19 vaccination to comply with the COVID-19 vaccination requirements.

An employee who applies for an exemption under section 4.4 must provide any supporting evidence if requested by BCE which meets the requirements of the Australian Technical Advisory Group on Immunisation (ATAGI) and informs an assessment of the risk. 

Note: Conscientious objection to receiving the COVID-19 Vaccination will not be  accepted as a valid exception to this policy.​

4. 6 Non-Compliance

Should a Worker not comply with the requirements as outlined within this Policy, the employee will be considered to be 'non-compliant'

Any non-compliant employees, depending on the manner in which they are engaged, may be stood down for no more than 30 days. Stood down employees may include employees who:

  • are vaccinated however not provided evidence;
  • have a vaccination in progress (received first dose, pending second);
  • tentatively committed to vaccinate;
  • has no intent to vaccinate; or
  • is medically unable to vaccinate.


Stood down employees may be able to access any accrued Annual or Long Service Leave (if applicable), for no more than 30 days. Any leave requests that exceed 30 days are required to be approved by the Head of People and Culture.

In some limited circumstances, employees who are stood down may be able to work from home on a temporary basis (for a period not exceeding 30 days and as approved by Principals/Managers) while their compliance with the Health Direction is being assessed. 

On or before the end of the 30-day period, the employee must provide proof of vaccination, or a process may be commenced to terminate their employment.

4.7  Record Keeping

BCE considers that the most effective way to ensure that it complies with the Health Direction and its duty of care to its Workers is to collect and record the vaccination information of its Workers. This includes a Worker's vaccination status, the type of COVID-19 vaccination, evidence of a medical contraindication, or evidence of being a COVID-19 vaccine trial participant.

All Employees must provide evidence of their COVID-19 vaccination status as soon as possible by uploading a valid vaccination record into their Ascender Web Self Service (WSS) portal.

All other Workers covered by this policy must provide a valid vaccination record as otherwise designated by BCE.

Where an individual has a medical exemption, BCE will collect and record evidence that the Worker is unable to receive a COVID-19 vaccine.

If BCE does not hold vaccination information about a Worker, the Worker will be deemed to be unvaccinated.

The purpose of collecting this information is:

  • to enable BCE to ensure that all Workers comply with the conditions of their engagement, which includes receiving the first dose of COVID-19 vaccination by 17 December 2021 and the second dose of COVID-19 vaccination by 23 January 2022, and subsequent booster vaccinations as directed by the government authorities;
  • to enable BCE to take the necessary steps if an individual does not meet the conditions of their engagement by receiving the applicable dose of COVID-19 vaccination by the relevant date and subsequent booster vaccinations;
  • as part of ensuring BCE is taking all reasonably practical steps to ensure the health and safety of its Workers, students, school community and members of the public, including preparation for any possible future outbreaks; and
  • so that BCE can comply with requests for the provision of information to a public health officer.

Vaccination information is sensitive information and is collected, managed and stored securely in accordance with the Privacy Act 1988 (Cth), Australian Privacy Principles (APPs) and the BCE Privacy Policy. 

An employee can request to access their vaccination information at any time and can also request updates are made to their vaccination information.

An employee's proof of their COVID-19 vaccination status will be stored in the required system and deleted once the Health Direction expires.

All other Workers covered by this policy must provide a proof of vaccination as otherwise required by BCE.

4.8  New Workers

Workers engaged and commencing after 17 December 2021 will be required to comply with the COVID-19 vaccination requirements in this Policy from commencement.​

5. POLICY OWNER AND POLICY MANAGER

The Policy Owner of this policy is the Executive Director, Brisbane Catholic Education. The Policy Manager of this policy is the Head of People and Culture, Brisbane Catholic Education.

6. RELATED CANON LAW, LEGISLATION, STANDARDS, REFERENCES

Source Reference

Fair Work Act 2009 (Cth)

National Employment Standards

Part 2-2 Division 6 Annual leave
Code of Canon LawCanon 1286

Health Act 2005 (Qld) 
Work, Health and Safety Act 2011 (Qld) 
COVID-19 Vaccination Requirements for Workers in a high-risk setting Direction - Public Health Act 2005 (Qld)​11 December 2021


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7. COMPLIANCE AND MONITORING

7.1 The Policy Owner has strategic responsibility for monitoring compliance with approved policy documents.

7.2 Non-compliance with this policy:

  • in the first instance, it should be brought to the attention of the Worker's  Principal/Manager for discussion and remedial action;
  • if recurring, it should be reported to the Head of People and Culture, Brisbane Catholic Education;
  • if of a serious nature, it must be reported to the Executive Director, Brisbane Catholic Education.

7.3 Non-compliance with this policy may lead to disciplinary action, and/or termination of employment or ceasing of the engagement of the person.

7.4 ​Organisational policy documents are developed by Brisbane Catholic Education to assist in the effective management of its business. Such policy documents are not intended to be legally binding on the organisation. They are not incorporated in contracts of employment. BCE may modify, replace or withdraw any of its policy documents at any time and it reserves the right to depart from them in individual cases.


8. DEFINITIONS

CANON LAWThe Code of Canon Law is the codified body of general laws governing the Roman Catholic Church.
CONSCIENTIOUS OBJECTOR
An individual who declines to be vaccinated for non-medical reasons.
CONTRAINDICATIONIn medicine, a contraindication is a condition that serves as a reason not to take a certain medical treatment due to the harm that it would cause the patient. Contraindication is the opposite of indication, which is a reason to use a certain treatment.
COVID-19 VACCINATIONA COVID-19 vaccine approved by the Therapeutic Goods Administration (TGA) for use in Australia, or where a person has been vaccinated overseas, a COVID-19 vaccine determined by the TGA to be a “recognised vaccine".
EXECUTIVE DIRECTORThe Executive Director of Brisbane Catholic Education.
RELATED DOCUMENTSDocuments that are related to this document and assist with its implementation.
VOLUNTEER

This policy applies to people who volunteer and deliver or undertake activities:

  • with children
  • in schools and workplaces
WORKERA person who undertakes work for BCE as an employee, an independent contractor, or as a volunteer (as defined in 'volunteer' above).

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Appendix 1 – Flow Chart- COVID Vaccination Notification Process

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