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Cayman Islands: Ombudsman issues guidance on vaccination and COVID-19 status checks for fitness establishments

The Office of the Ombudsman released, on 29 September 2021, guidance on vaccination and COVID-19 status checks for fitness establishments. In particular, the guidance aims to help owners and operators of gyms, fitness centres, and other indoor fitness areas understand their obligations in relation to the Data Protection Act (2021 Revision) in complying with the requirement to check vaccination certificates or PCR test results of any person (other than an employee) entering their premises. 

As such, the guidance details that vaccination status or PCR test results are considered medical data and therefore considered to be sensitive personal data under the Act and subject to stringent requirements including:

  • compliance with fair and lawful processing principles;
  • establishing a process for checking vaccination status and PCR test results which includes requirements around having a privacy notice and complying with data collection obligations; and
  • compliance with the purpose limitation principle and the data minimisation principle, among others.

You can read the guidance here.