Administrative Procedure 417: COVID-19 Immunization Disclosure Procedure (for Staff)

Legal References

School Board Implementation Resource Guide – COVID-19 Immunization Disclosure Policy for the Education Sector, Ontario Human Rights Code; Municipal Freedom of Information and Protection of Privacy Act; Personal Health Information Protection Act

Related References

1. Purpose

1.1 The purpose of this document is to outline the Avon Maitland District School Board’s expectations with regards to COVID-19 immunization disclosure as it applies to staff, volunteers, third-party contractors, student placements, frequent visitors and other professionals who provide in-person services in schools and who have direct contact with staff and/or students (“The Covered Individuals”).
1.2 All Covered Individuals who are eligible to receive the COVID-19 vaccine are strongly encouraged to receive a COVID-19 vaccine. Requests for exemptions and reasonable accommodations related to a medical condition/disability or religion/creed under The Ontario Human Rights Code will be considered. However, due to the serious health threat COVID-19 presents to the public, this duty to accommodate will be balanced against the board’s obligation to protect the health and safety of employees and students.

2. Background

2.1 The Avon Maitland District School Board recognizes the importance of immunization as a key element to help keep school settings safe. This COVID-19 Immunization Disclosure Procedure aims to protect the Avon Maitland District School Board’s population.
2.2 COVID-19 is an acute respiratory illness caused by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). It may be characterized by fever, cough, shortness of breath, and several other symptoms. Asymptomatic infection is also possible. The risk of severe disease increases with age but is not limited to the elderly and is elevated in those with underlying medical conditions.

3. Application of the Administrative Procedure

3.1 This COVID-19 Immunization Disclosure Procedure applies to all Covered Individuals. For clarity, Covered Individuals include the following groups:
  • All school board employees/staff, including daily and long-term occasional staff;
  • School Board trustees; and,
  • Student transportation drivers.
3.2 The following individuals, if attending the school premises and who have direct contact with staff or students, must provide proof of being fully vaccinated under the COVID-19 Immunization Disclosure Procedure:
  • Students on educational placement, including professional services students on a placement/work-integrated learning visit (e.g., teacher candidate practicums, nurse, psychologist, behavioural therapist, speech-language pathologist, etc.);
  • Volunteers;
  • Those who provide professional services to children at school; and,
  • Visitors, including third party contractors.

4. Procedure

4.1 The Chief Medical Officer of Health (CMOH) has directed the Avon Maitland District School Board to develop, implement and ensure compliance with a COVID-19 Immunization Disclosure Procedure. This procedure requires all individuals covered by the procedure to provide one of the following:
  1. Proof of all required doses of a COVID-19 vaccine approved by the World Health Organization.
  2. Written proof of a medical reason, provided by either a physician or nurse practitioner that sets out:
    1. that the person cannot be vaccinated against COVID-19; and
    2. the effective time period for the medical reason (i.e., permanent or time-limited).
  3. Proof that the individual has completed the educational program prescribed by the Ministry of Education
  4. Request for an exemption under the Human Rights Code which shall be reviewed and considered by the Board. Where an exemption is not granted, the Covered Individual shall be required to comply with subparagraph 1, above.

5. Educational Program

The educational program has been prescribed by the Ministry of Education and addresses the following learning components:
  • How COVID-19 vaccines work;
  • Vaccine safety related to the development of the COVID-19 vaccines;
  • Benefits of vaccination against COVID-19;
  • Risks of not being vaccinated against COVID-19; and
  • Possible side effects of COVID-19 vaccination.

6. Testing Requirements

6.1 Covered Individuals subject to the COVID-19 Immunization Disclosure Procedure who are not fully vaccinated, must regularly complete Rapid Antigen Testing for COVID-19 and demonstrate a negative result, at a minimum interval of twice weekly; and provide verification of the negative test result to the Avon Maitland District School Board.
6.2 Rapid Antigen Test kits are available for Covered Individuals provided by the Avon Maitland District School Board. Alternatively, Covered Individuals may elect to provide in-pharmacy COVID-19 Rapid Antigen Test results from participating pharmacies at their own cost.
6.3 Covered Individuals shall administer or receive Rapid Antigen Testing outside normal working hours.
6.4 The Covered Individual shall take a photograph of the Rapid Antigen Test result as required above and submit it electronically as required. The Board will, from time to time, audit the Rapid Testing and results of Covered Individuals. Should a Covered Individual be unable to produce required photograph(s), the Covered Individual will be subject to corrective measures including discipline up to termination of employment.
6.5 Rapid Antigen Tests provided by the Board are intended for the use of the Covered Individual to whom they are provided only. The Covered Individual shall not give, sell, distribute or otherwise dispose of any Rapid Antigen Test to anyone else. Failure to comply with this requirement will result in discipline up to termination of employment.

7. Non-Compliance

7.1 In accordance with the Avon Maitland District School Board procedures, directives and collective agreements, non-compliance of the COVID-19 Immunization Disclosure Procedure will result in follow up on an individual basis by Human Resource Services and may result in progressive disciplinary or non-disciplinary action.
7.2 False attestations will be treated as fraud and non-compliant with the COVID-19 Immunization Disclosure Procedure and will be considered a serious breach of trust which will be subject to discipline up to and including termination of employment with the Avon Maitland District School Board.

8. Confidentiality Statement

8.1 The Avon Maitland District School Board is required, pursuant to the Chief Medical Officer of Health’s direction, to report statistical information to the Ministry of Education. All statistical information will be provided in depersonalized aggregate form on a monthly basis.
8.2 Only Individual(s) will have access to this data in order to be able to fulfill the requirements as outlined by the Chief Medical Officer of Health and the Ministry of Education.
8.3 This information is being securely stored in our Human Resource Information System (HRIS).
Issued September 2021

Appendix A

Supplementary Educational Resources
The Ministry of Education is providing a mandatory video for all who must participate in an education session. Additional, supplementary resources are offered below for more information:

About COVID-19 Vaccines (Ontario Ministry of Health)
Building Confidence in Vaccines [English] and Accroître la confiance à l’égard des vaccins [French] (Public Health Ontario)
Communicating effectively about immunization: Canadian Immunization Guide
(Government of Canada)
Coronavirus disease (COVID-19): Awareness resources (Government of Canada – available in many languages)
COVID-19 Info (Immunize Canada)
COVID-19 vaccines and workplace health and safety: Learn how COVID-19 vaccines help protect you and make your workplace safer [English] and
Les vaccins contre la COVID-19 et la santé et la sécurité au travail: Découvrez comment les vaccins contre la COVID-19covid 19 contribuent à vous protéger et à rendre votre lieu de travail plus sécuritaire [French] (Ontario Ministry of Labour, Training and Skills Development)
COVID-19: Vaccines | Centre for Effective Practice - Digital Tools
(Centre for Effective Practice)
COVID-19 Vaccines Explained (World Health Organization)
COVID-19 Vaccine Information Sheet (Ontario Ministry of Health)
COVID-19: Vaccine Resources and in American Sign Language
(City of Toronto – available in many languages)
Documents multilingues sur la vaccination contre la COVID-19 (Alliance des communautés culturelles pour l’égalité dans la santé et les services sociaux – available in many languages)
Gashkiwidoon Toolkit: covid-19 vaccine implementation (Indigenous Primary Health Care Council)
Ontario’s doctors answer COVID-19 vaccine questions (Ontario Medical Association)
Sunnybrook COVID-19 e-learning module (Sunnybrook Health Sciences Centre)
Updates on COVID-19 (National Collaborating Centre for Indigenous Health)