WHO guidance details recommendations for domestic uses of COVID certificates

The World Health Organization issued a 'Technical specifications and implementation guidance' for digital COVID certificates. More precisely, the document is centred around the concept of "Digital Documentation of COVID-19 Certificates (DDCC)", which is defined "as a mechanism by which a person’s COVID-19-related health data can be digitally documented via an electronic certificate."

The WHO guidance considers two main use cases for the DDCC: "continuity of care", in which the certificate is intended as "part of an individual's medical records, starting from birth"; and "proof of vaccination", which can "provide proof of vaccination status for purposes not related to health care."

The document lists some important minimum requirements for DDCC adoption -- among them, crucially, "the potential benefits, risks and costs of implementing" such a solution "should be assessed before introducing a DDCC:VS (i.e. a DDCC for vaccination status) system and its associated infrastructure."

Furthermore, ethics and equal treatment should be top priorities when considering the deployment of such a tool, the WHO argues.

Trust is therefore essential in fighting "digital exclusion", which may result as a consequence of a "too burdensome" digital infrastructure for COVID certificates. Some procedural "values" to make an ethical and equitable use of DDCC are listed by the WHO:

  • Transparency, according to which "accurate and publicly accessible information about the basis for the policy and the process by which it is made" should be available "from the onset"
  • Inclusiveness in decision-making: "all relevant stakeholders" should be able to participate in its design -- starting from those who are most affected by the introduction of DDCC
  • Accountability, which means clarifying responsibilities, in particular about enforcement
  • Responsiveness, i.e. "providing mechanisms and opportunities to review and revise decisions and policies based on evolving scientific evidence and other relevant data."

What's arguably even more interesting is the set of considerations and requirements that the WHO document puts forward concerning the domestic uses of the DDCC (e.g., to enter restaurants, bars, museums, shops, gyms, large public events, etc.) that an increasing number of countries is being adopting, and fast. The WHO labels such DDCC schemes "health pass."

First of all, "individual vaccination status is private information, and protections need to be in place to ensure that no individual is forced to disclose or publicly display a DDCC:VS to access any public area or activity", reads the document. "Such a practice and/or the lack of a DDCC:VS itself may result in the stigmatization of individuals without a DDCC:VS and may exacerbate the risk of harms."

Health passes also imply a series of specific "potential ethical problems for individuals and communities, and human rights challenges."

A first set of risks concerns "current scientific uncertainties regarding COVID-19 vaccines", e.g. their actual efficacy in preventing transmission. "In this context of scientific uncertainty", the document reads, "use of a DDCC:VS as a health pass based solely on individual vaccination status may increase the risk of disease spread."

The health pass also risks promoting "potential behavioural responses" that may "undermine individual and public health", such as:

  • incentivize fraud, especially when benefits of the health pass are significant
  • refrain subjects from sharing their medical history
  • increase vaccine hesitancy, rather than boost vaccination campaigns ("because of privacy and other concerns that the vaccination record could be linked to personal data and be used for functions other than those originally intended (e.g. surveillance of individual health status), or be used by unintended third parties (e.g. immigration, commercial entities, researchers)").

"Unfair advantages and injustices" may also result from a rushed application of the health pass, the WHO document reads.

A series of recommendations consequently follows:

  • scope of the health pass should be clearly defined ("each Member State that introduces one should be clear about which uses are proposed and that a DDCC:VS should not be used for other purposes")
  • adoption of the pass should be "based on scientific evidence" and "not imposed in an arbitrary, unreasonable or discriminatory manner"
  • potential risks, benefits and costs should be assessed before deployment
  • information concerning its use should be communicated clearly and transparently
  • its deployment should be as fair and inclusive as possible ("to achieve this, it may be necessary to provide alternative, cost-effective DDCC:VS solutions, including paper-based certificates")
  • its use should be constantly monitored for impact and adjusted to the dynamics of the pandemic ("post implementation" monitoring).





COVID certificate, Vaccine passports


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