Policy on COVID-19 Vaccination for the Canadian Institutes of Health Research
(Également publié en français sous le titre Politique des Instituts de recherche en santé du Canada sur la vaccination contre la COVID-19)
- Effective date
- Objectives and expected results
1. Effective date
1.1 This policy takes effect on November 8, 2021.
2.1 The Canadian Institutes of Health Research (CIHR) is committed to the promotion and maintenance of sound health, safety, and wellness practices for its employees. CIHR is committed to contributing to the efforts of the Government of Canada in response to the COVID-19 pandemic to ensure the health and safety of all Canadians.
Attestation deadline (date limite de présentation de l’attestation)
The date by which an employee’s attestations must be entered in the CIHR-VATS, or provided to their manager if the employee does not have access to the CIHR-VATS:
- November 30, 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 November 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 November 8, 2021 to November 30, 2021, the attestation deadline is 2 weeks from the date they have access to each, as determined by their manager, and notwithstanding their leave status.
Canadian Institutes of Health Research Vaccine Attestation Tracking System (CIHR-VATS) (système de suivi des attestations de vaccination des Instituts de recherche en santé du Canada (SSAV-IRSC))
CIHR-VATS is a user-friendly web platform that will allow employees to attest to the status of their COVID-19 vaccinations and store the attestations.
CIHR-VATS will centrally store the attestations and provide access to aggregated data to the CIHR and the Treasury Board of Canada Secretariat, in compliance with the Privacy Act and the security requirements. Similarly, the President, members of the Senior Leadership Committee, the Director General, Human Resources, the Manager and Advisors of Labour Relations, and the Human Resources Analyst will have access to organizational-level aggregated data for purposes of tracking, follow-up and reporting.
Clinical Trial participants – Not fully vaccinatedFootnote 1 (as of November 30, 2021) (participants aux essais cliniques – pas entièrement vaccinés (au 30 novembre 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 four (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).
It means employees of CIHR and includes the following whether they work on-site or remotely: indeterminate and term employees, employees on leave with or without pay, students, casual, seasonal, and part-time workers.
The principles of this policy also apply to Interchange Canada participants and volunteers.Footnote 2
It does not include Scientific Directors or Institute staff.
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-19Footnote 1 (employees vaccinated in Canada as of November 30, 2021) (entièrement vacciné - COVID-19 (employés vaccinés au Canada au 30 novembre 2021))
People are considered fully vaccinated 14 days after they have either:
- Received both doses of a Health Canada authorized vaccine that requires two (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 one (1) dose of a Health Canada authorized vaccine that only requires one (1) dose to complete the vaccination series (as of September 16, 2021): Janssen (Johnson & Johnson) COVID-19 vaccine.
Fully vaccinated - COVID-19Footnote 1 (employees vaccinated outside of Canada as of November 30, 2021) (entièrement vacciné - COVID-19 (employés vaccinés à l’extérieur Canada au 30 novembre 2021))
People are considered fully vaccinated 14 days after they have either:
- Received one (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.
- Received three (3) doses of any COVID-19 vaccine regardless of if they are Health Canada authorized vaccines or non-Health Canada authorized vaccines.
For the purpose of this policy, “managers” means any employee occupying a CIHR position at grade 12 or above.
Unvaccinated employees (employés non vaccinés) 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 one (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 as per the terms of this policy.
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 who 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.
New Employees (nouveaux employés)
For the purpose of this policy, a new employee is an employee hired to join the CIHR on or after November 8, 2021.
Vaccination is the term used for receiving a vaccine, usually through an injection.
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).
4.1 This policy is issued pursuant to the human resources authorities outlined in s. 17 of the Canadian Institutes of Health Research Act, as delegated by Governing Council to the President.
4.2 Any financial implications of this policy are subject to applicable financial powers and authorities.
5.1 This policy applies to all employees as defined in s. 3. The principles of this policy apply equally to Interchange Canada participants.
5.1.1 Employees must comply with this policy regardless of whether they work onsite, remotely or telework.
5.2 Any individuals not listed in s. 5.1 are considered as members of the public and are subject to the public health measures applicable in the location where their interaction with the CIHR and its employees takes place.
5.3 New employees shall be fully vaccinated or be unable to be vaccinated with accepted accommodations measures identified as defined in s. 3 as a condition of employment. Individuals who are partially vaccinated or unwilling to be fully vaccinated may not be provided with an employment opportunity until such time as they become fully vaccinated or CIHR accepts the request for accommodation.
6.1 For employees unwilling to be fully vaccinated or to disclose their vaccination status as per s. 3, the employer will implement the following measures:
6.1.1 Within two (2) weeks of the attestation deadline, require employees to attend an online training session on COVID-19 vaccination;
6.1.2 On December 15, 2021:
- Restrict employees’ access to the workplace, off-site visits, business travel and conferences;
- Place 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.
6.1.3 For new employees refusing or omitting to complete their attestation in the CIHR‑VATS within their first week of employment, administrative and/or disciplinary measures, up to and including termination of employment, may apply.
6.2 For employees who are partially vaccinated as per s. 3:
6.2.1 Partially vaccinated employees will be placed on leave without pay if they have not received their second dose by 10 weeks after their first dose;
6.2.2 Employees who have been placed on leave without pay and who become partially vaccinated will resume work and have their pay reinstated;
6.2.3 Partially vaccinated employees may be subject to temporary measures for the period of time for which they remain partially vaccinated.
6.3 “Other Leave With Pay (699)”, is not available for employees unwilling to be fully vaccinated or unwilling to disclose their vaccination status.
6.4 The 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 branch/work unit, in accordance with existing reference levels.
7. Objectives and expected results
7.1 The objectives of this policy are as follows:
7.1.1 To 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.
7.1.2 To improve the vaccination rate across Canada of CIHR employees through COVID-19 vaccination.
7.1.3 Given 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.
7.2 The expected results of this policy are as follows:
7.2.1 All employees of the CIHR 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.
7.2.2 All organizational units within CIHR monitor the implementation of this policy and report on its implementation to the Human Resources Branch. In addition, the Human Resources Branch provides regular update on the implementation of this policy to the Senior Leadership Committee (SLC).
7.2.3 Personal 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.
8.1 The President is responsible for the following:
8.1.1 Implementing this policy within the CIHR.
8.1.2 Ensuring consistency in approach to implementation of the Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police by the Treasury Board of Canada direction.
8.1.3 Ensuring that the CIHR complies with Treasury Board of Canada requirements in relation to oversight, security, information requirements, and reporting including:
- Collecting and storing data and information regarding vaccine attestations, testing, and testing results whether in electronic or paper form.
8.1.4 Overseeing the implementation of this policy to assess whether the requirements of this policy and its related instruments have been met.
8.1.5 Prescribing any oversight, systems, security, information requirements, or reporting for the purpose of implementing this policy.
8.1.6 Collecting and storing attestation and consent forms once signed for those unable to use the CIHR Vaccine Attestation Tracking System (CIHR-VATS).
8.1.7 Conducting audits on attestations and consent forms.
Duty to accommodate
8.1.8 Implementing this policy and CIHR’s Duty to Accommodate policy for persons unable to be fully vaccinated by:
- Ensuring 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.
- Ensuring 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.
- Implementing measures for employees unwilling to disclose their vaccination status, or who choose not to be fully vaccinated, without an approved accommodation.
8.1.9 Ensuring a respectful, productive, inclusive, and equitable environment, including:
- Ensuring 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.
8.1.10 Ensuring that personal information is collected and managed in accordance with the Privacy Act and its related instruments and other applicable legislation, including the CIHR Act:
- Ensuring that the CIHR privacy breach plans and procedures are up to date;
- Ensuring that privacy breach plans and procedures are readily available to employees and managers; and
- Ensuring that privacy breach plans include:
- Immediate containment measures in the event of a privacy breach; and
- Contact information for the relevant officials.
Director General, Human Resources
8.2 The Director General, Human resources is responsible for:
8.2.1 Communicating with and maintaining up-to-date information from the Treasury Board of Canada Secretariat and the Chief Human Resources Officer on the Government of Canada mandatory vaccine requirements;
8.2.1 Reviewing the need for this policy and the policy contents, at a minimum every six (6) months, and reporting the results to the President and to SLC;
8.2.3 Informing and advising the President and SLC on key COVID-19 vaccination-related labour relations considerations, 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 after consulting with the CIHR ATIP Coordinator, general information management and values and ethics pertaining to this context;
8.2.4 Communicating guidance regarding the duty to accommodate, compliance to the Canada Labour Code, Part II and the CIHR Occupational Health and Safety Policy;
8.2.5 Providing support, advice, and guidance for the consistent implementation of this policy, including advice to the President and SLC on proposed administrative measures related to unwilling employees;
8.2.6 Arranging training related to the requirements set out for employees pursuant to this policy and tracking records of attendance when applicable;
8.2.7 Recommending any other mandatory training requirements related to this policy as needed.
Director General, Digital and Security Services
8.3 The Director General, Digital and Security Services is responsible for:
8.3.1 Developing, managing and maintaining CIHR-VATS.
8.4 Managers are responsible for:
8.4.1 Attending training as required;
8.4.2 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 President (i.e., the CIHR-VATS);
8.4.3 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;
8.4.4 Consulting and collaborating with Labour Relations with regard to requests for accommodation as well as in the context of guidance for employees who are not vaccinated and whose request for accommodation have been reviewed and rejected by CIHR in accordance with the law and the CIHR Duty to Accommodate policy.
8.4.5 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.
8.4.6 Supporting the President’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 managers 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.
8.4.7 Maintaining a respectful, productive, inclusive, and equitable environment.
8.5 Employees are responsible for:
8.5.1 Providing 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 CIHR Code of Conduct and the Values and Ethics Code for the Public Sector and may result in disciplinary action.
8.5.2 Disclosing their vaccination and testing status accurately as required by this policy.
8.5.3 Informing 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.
8.5.4 For all employees employed by CIHR on the effective date, providing their manager with the required supporting documentation for their accommodation request, on the CIHR standardized document when feasible (instances where it may not be feasible include, without being limited to, requests for a reason that is not medical or religious), before November 30, 2021 if required.
8.5.5 Providing their manager with complete and accurate information necessary to identify appropriate accommodation, including information on relevant limitations, restrictions, and if they are partially vaccinated.
8.5.6 Cooperating and collaborating in good faith with their manager and in consultation with Labour Relations 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.
8.5.7 Notifying their manager if their accommodation needs change.
8.5.8 Informing 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.
8.5.9 Attending training as required.
8.5.10 Refraining from directing harassment or any other prohibited conduct toward an individual for any reason, including their vaccination status or accommodation measures.
9.1 Employees should direct enquiries to their manager.
9.2 Enquiries may also be directed to the Occupational Health and Safety mailbox.
- Canadian Human Rights Act
- Canada Labour Code
- Canada Occupational Health and Safety Regulations
- Canadian Institutes of Health Research Act
- Financial Administration Act
- Government Employees Compensation Act
- Privacy Act
- Work Place Harassment and Violence Prevention Regulations
Related policy instruments
- Directive on Privacy Practices
- Policy on Privacy Protection
- Values and Ethics Code for the Public Sector
- CIHR’s Ask a Scientist
- COVID-19 Vaccines: Authorized vaccines - Canada.ca
- Information for Government of Canada employees: Coronavirus disease (COVID-19)
- National Advisory Committee on Immunizations Statement: Recommendations on the use of COVID-19 vaccines
- Public Service Occupational Health Program COVID-19 Guidance
- Provincial and Territorial Operating Condition (GCconnex)
- Date modified: