MEDICALE
CANADIENNE
[I:
CANADIAN
MEDICAL
ASSOCIATION
CMA POLICY
Vaccine
c
ertificates
Policy position recommendation
1.
The CMA supports the development of a pan
-
Canadian vaccine certificate program for domestic
purposes in some circumstances, in addition to the establishment of a vaccine
passport system to
support international travel, led by the federal government. Recognizing the potential for an
emerging patchwork of approaches, the CMA calls on federal and provincial/territorial governments
to ensure interoperability of vaccine certifi
cate programs, including tools and systems, across all
jurisdictions within Canada. Interoperability of vaccine certificate programs will ensure people in
Canada do not experience mobility barriers and associated unintended, negative consequences.
2.
The CMA
recognizes that vaccine certificates
a
could be a valuable tool in some circumstances to
complement public health. Reasons for implementation include facilitating access to one’s digital
immunization records, supporting re
-
opening, reducing the need for mo
re restrictive public health
measures (e.g., lockdowns), managing risk of transmission in discretionary and non
-
discretionary
settings, and protecting those at high risk of infection and at high risk of severe illness or death
resulting from COVID
-
19.
3.
Bas
ed on the evolution of the pandemic, it would be prudent to implement a vaccine certificate
program to reduce the need for continued more restrictive public health measures and manage risk
of transmission in discretionary and non
-
discretionary settings.
It
is imperative that any vaccine
certificate program meets key ethical, legal, and scientific standards.
4.
Where they are introduced, it is in the public interest for governments to develop clear and
consistent standards for vaccine certification to ensure t
hat they are legitimate, meet public health
objectives, respect equity and non
-
discrimination, and protect privacy.
5.
The CMA supports people in Canada having access to their digital immunization records that are
already held in provincial and territorial r
epositories. People in Canada can more easily access their
COVID immunization records via a vaccine certificate program.
6.
A vaccine certificate program allows people in Canada to access their digital immunization records in
a way that is authentic and throu
gh a valid issuer. This prevents the release of fraudulent records.
a
Also referre
d to as “vaccine passports” or “COVID passports”.
© 202
1
Canadian Medical Association. You may, for your non
-
commercial use, reproduce, in whole or in part and in any form or manner,
unlimited copies of CMA Policy Statements provided that credit is given to Canadian Medical Association.
The CMA further supports that these records are presented in a way that are easily scanned and
accessed by a third
-
party to confirm proof of vaccination.
7.
It is critical that individuals k
now what vaccine they received and when they received them because
as evidence on immunity evolves, access to one’s digital immunization records
allows for a best
estimate of immunity/protection. Access to this information is important to protect individua
ls, to
allow for the best medical decisions to be made about them, and for public
-
health decision
-
making.
8.
Development and maintenance of vaccine certificate programs, including tools and systems, must
minimize implications for health providers and health s
ystems. Appropriate remuneration should be
established.
9.
The use of vaccine certificates reinforces the need to ensure that vaccines are distributed equitably
and according to fair, publicly justified criteria and requires the continued use of essential pub
lic
health measures to support implementation.
10.
Further research must be conducted to gather evidence of vaccine certificates to meet their
intended objectives. Similarly, measures must be put in place to evaluate the impacts of vaccine
certificates, such a
s their intended/unintended consequences, to ensure the fair distribution of
benefits and burdens, and to make system changes to minimize or eliminate harms.
A.
Background
•
As vaccination rates rise across the country, there is a growing expectation that public
health measures to control the spread and reduce the risk of COVID
-
19 will be eased
and our desire to return to our routines such as work, recreational activities, sch
ool, and
travel will be realized.
•
Domestically, proof of vaccination requirements is being considered by both
government and the private sector.
•
At the international level, many countries are considering including vaccine certificates
as part of entry req
uirements.
•
In the past, proof of immunization requirements for other diseases have been
implemented in Canada.
1
•
The Chief Science Advisor of Canada has stated that the “domestic use of vaccination
certificates raises additional socio
-
ethical
-
legal questio
ns that need careful
consideration in order to promote both vaccine acceptance and social cohesion.”
2
•
The federal, provincial, and territorial privacy commissioners released a joint statement
regarding vaccine certificates stating that these should also i
ncorporate privacy best
practices to achieve the highest level of privacy protection commensurate with the
sensitivity of the personal health information that will be collected, used or disclosed.
3
•
Further, in view of the risks to privacy involved, priv
acy commissioners have stated that
the “necessity, effectiveness and proportionality of vaccine certificates must be
established for each specific context in which they will be
used.”
3
•
There is concern that vaccine certificate requirements could create a sense of coercion
that could diminish public trust and vaccine acceptance.
2
•
It is important to remember that access to vaccines requires consideration of the
disproportionate impact that COVID
-
19 is having on population groups with pre
-
existing
social and medical vulnerabilities.
•
Inequitable acc
ess to technologies and lack of digital literacy may be a barrier to
accessing digital vaccine certificates, so provisions should be made to secure alternative
forms of the certificate.
B.
Rationale
•
Vaccine certificates must meet ethical and legal condition
s to be considered legitimate.
•
Vaccination certificate requirements could theoretically reduce the risk of transmission.
4
•
Clarity is required about the objectives of a vaccine certificate program, ongoing public
health measures, and what the certificates can reasonably be understood as
representing scientifically.
•
Vaccine certificates implementation must be equitable, such
that everyone is
guaranteed the right
—
and thus necessary conditions and resources required
—
to obtain
and hold one, including barrier
-
free access to vaccination and securing alternative forms
of the vaccine certificate. Conversely, implementation must not
create or exacerbate
barriers for equity relevant groups, including those who lack digital literacy, those who
have poor access to vaccination, and those groups who may have a lower rate of vaccine
acceptance based on historic and ongoing systemic racism a
nd discrimination.
5
•
To ensure that vaccine certificates are consistent with privacy laws and minimize privacy
impacts on certificate holders, government should lead their development and the
framework for their use. This should not be left to the privat
e sector to navigate.
•
Private entities should ensure that their use of vaccine certification is fair and adheres
with governmental policies aimed at minimizing the worsening of social disparities as a
result of the pandemic.
2
•
Vaccine certificates should be developed to ensure the tool is available for use as
evidence emerges to support how they could best be used to support public health and
other o
bjectives.
•
Vaccine certificate programs should account for evolving real
-
world evidence about
different vaccines, strains, and whether individuals have received necessary doses or
boosters. Certificates may also need to be revoked or modified to reflect e
volving
evidence.