PUBLIC-HEALTH EMPLOYMENT UPDATE | Workplace rules effective 15 October 2021
The workplace Green Pass regime introduced by Decree-Law no. 127/2021 became operational on 15 October.
Public and private employers are required to define verification procedures and appoint responsible personnel. A worker without the pass can not access the workplace and faces statutory consequences concerning absence and pay, while sanctions apply in specified cases.
The rule does not allow employers to collect the medical reason behind the certificate or to maintain an informal vaccination list. International policies that asks for proof to be emailed to HR risk exceeding the Italian data-minimisation framework.
Employers need a written checking process, limited records and trained gatekeepers. Any suspected misconduct or repeated refusal requires a separate disciplinary assessment under Article 7 of the Workers’ Statute and the applicable CCNL.