Call for Evidence: COVID 19 Vaccine Certification

30 April 2021 — Paul Modaley

[Unfortunately, this PDF document contains only the author’s name and the date of its creation and I’ve not been able to find any other information on him. WB]

I have grave concerns over recent rhetoric, from government and private businesses, regarding the introduction of COVID-Status certificates and/or COVID-19 vaccine certificates/immunity passports.

This document, which consists of two parts, sets out the following:


  • Clinical / medical considerations
  • Legal considerations
  • Operational / delivery considerations
  • Considerations relating to the operation of venues that could use a potential COVID-status certification scheme
  • Considerations relating to the responsibilities or actions of employers under a potential COVID-status certification scheme
  • Ethical considerations
  • Equalities considerations
  • Privacy considerations


  • Global context
  • Proposed Medical Freedom Bill to Safeguard UK Citizens
  • Conclusion


Clinical / medical considerations:

  • There is no scientific evidence that COVID-19 vaccines prevent either infection with or transmission of Sars-CoV-2, as the clinical trials were not designed to assess these endpoints12. Therefore, the COVID-19 vaccines have not been shown to have a wider public health benefit beyond the vaccine13.
  • There is currently no knowledge of the duration of any protective effect from vaccination beyond 3 months, or whether subsequent booster doses may be required, and how frequently14.
  • There is evidence that naturally acquired immunity from COVID-19 is long-lasting15 16, yet ‘Immunity Passports’ are only proposed for vaccinated individuals and not those who have had COVID-19 and have natural immunity. This is discriminatory.
  • COVID-19 vaccines are still experimental and under emergency-use authorisation. Clinical safety trials will not be completed until the beginning of 2023.
  • There is currently only limited short-term safety data and NO long-term safety data to rule out late onset side-effects such as autoimmune diseases, neurological conditions, infertility. or cancers, for any of the COVID-19 vaccines.
  • Many of the COVID-19 vaccines are based on a completely novel technology (mRNA vaccines) that has never previously been approved for use in humans, therefore long-term safety cannot be inferred.
  • Since the COVID-19 vaccine rollout began in December 2020, there already have been thousands of reports of serious adverse events and deaths to the VAERS Database in the US17, the Eudravigilance Database in Europe18 and the MHRA in the UK19.
  • Concerns that COVID-19 vaccines may cause antibody-dependent immune enhancement (ADE) have not been addressed in any clinical trials on humans or animals. ADE causes an exaggerated immune response on exposure to coronaviruses following vaccination, leading to more severe illness20. This possibility has not been ruled out and is a known and accepted risk to those who accept the vaccines.
  • It is unethical and unlawful to bring in any measure that puts pressure on an individual to submit themselves to a medical intervention that is still experimental and for which the long-term safety profile is unknown.

Legal considerations:

  • Vaccine/Immunity Passports will face legal challenges using current human rights and equality laws.
  • The International Health Regulations (IHR) 2005 prohibit health measures that are discriminatory and impede international travel23. However, the UK does not have laws to expressly address discrimination experienced by those without “immune privilege”. The IHR (2005) and other international laws require states to respect human rights and avoid discrimination. Under the IHR, states must comply with their obligations to report additional measures, to base measures on scientific principles and evidence, and to use the least restrictive measures available24.
  • The Parliamentary Assembly of the Council of Europe passed Resolution number 2361 of 2021 on 27 January 202125, in which it was stated that:

• Paragraph 7.3.1 – ensure that citizens are informed that the vaccination is NOT mandatory and that no one is politically, socially, or otherwise pressured to get themselves vaccinated, if they do not wish to do so themselves

• Paragraph 7.3.2 – ensure that no one is discriminated against for not having been vaccinated, due to possible health risks or not wanting to be vaccinated.

  • The Universal Declaration on Bioethics and Human Rights protects an individual’s bodily autonomy, the right to informed consent and the right to refuse medical interventions without penalty or restriction. It states that any preventive, diagnostic and therapeutic medical intervention must only be carried out with the prior, free, and informed consent of the person concerned, based on adequate information. The consent should, where appropriate, be express and may be withdrawn by the person concerned at any time and for any reason without disadvantage or prejudice26.
  • Conservative MP Steve Baker recently raised the issue of “implicit coercion” in Parliament, saying:

Will [you] agree with me, it’s not enough for the government merely to refrain from coercing people, the government’s also got to pay attention to implicit coercion. That is, if the government turns a blind eye to allowing businesses like airlines and restaurants to refuse to let people in unless they’ve had the vaccination. The government’s got to decide whether it’s willing to allow people to discriminate on that basis.”22

  • Given the significant risk to individual basic freedoms and division in society, it is urgent that the UK government passes domestic legislation to make it illegal for businesses to discriminate against those who have not been vaccinated and to outlaw Vaccine Passports.

Operational / delivery considerations:

  • A certification system delivered via smartphones or other technologies would exclude those unable or unwilling to use such devices.
  • Digital infrastructure for a certification scheme would be a target for cybercriminals.
  • Costs of operating and delivering such a system would be an astronomical financial burden and poor use of taxpayers’ money.
  • The government’s track record of operating and delivering technologies during the pandemic is poor – Test & Trace had many failings.

Considerations relating to the operation of venues that could use a potential COVID-status certification scheme:

  • Organisations would need to consider the legal and financial consequences of discriminating against members of the public based on vaccine status where goods and/or services have been purchased under contract or similar terms and conditions (e.g. season tickets for sports teams, pre-booked holidays and flights, etc).
  • A digitised certification scheme would not be compatible with certain public venues, including schools and hospitals where the use of digital devices such as smartphones can present certain risks.

Considerations relating to the responsibilities or actions of employers under a potential COVID-status certification scheme:

  • There may be costly legal ramifications for employers that might terminate a person’s employment based on the COVID certification status.
  • It would take a considerable amount of time for employers to become sufficiently aware of the legal framework that would surround COVID certification. Such a framework could be burdensome for employers and hamper British industries in their hiring processes.

Ethical considerations:

The concept of issuing vaccine passports has significant scientific, ethical, legal, social, economic, and political implications9. The government has denied it will make COVID-19 vaccines mandatory, as that would breach human rights laws and be disastrous for public relations. However, the introduction of an official government Vaccine Passport would result in an indirect mandate, allowing pressure to be applied by private companies and other authorities, who will be able to demand a valid Vaccine Passport as a condition of service provision.

Under existing laws against discrimination10, the government may not be able to prevent businesses from requiring proof of vaccination and may only be able to issue a warning against it, which would have no legal standing. Parliament must update the legislation as a matter of urgency. International Health Regulations prohibit health measures that are discriminatory and impede international travel11. UK laws should provide the same protections for its citizens.

Furthermore, there are significant concerns about unlawful practices within the government, whereby government officials award lucrative contracts to friends and family members, as was the case with Health Secretary Matt Hancock who has been deemed to have acted ‘unlawfully’.

Equalities considerations:

  • People unable or unwilling to have COVID-19 tests or vaccines, will not be able to “prove” their health status, thus having their basic freedoms de facto restricted.
  • Vaccine/Immunity Passports risk enshrining such discrimination in law and undermine the right to health, of individuals and the population21.
  • Vaccine Passports would be amenable to both corruption and implicit bias. They may exacerbate the harm inflicted by COVID-19 on already vulnerable people, who may be more hesitant to seek medical care due to discriminatory access. Any large-scale deployment of Vaccine Passports could disproportionately segment society and breach rights to equality and non-discrimination.
  • Labelling people based on their COVID-19 immunity or vaccine status may fuel a societal stratification along lines of access to medical care, housing, education, public transport, cultural events, hospitality, travel, etc. This concern was raised by the Information Commissioner who stated that issuing ‘freedom passports’ to people who have been vaccinated would risk creating “a two-tier society”22.
  • Labelling people based on their COVID-19 immunity status may exacerbate conflict between groups of citizens with the potential for violence and breakdown of society.
  • In workplaces, there is a serious risk that social and financial inequalities may be amplified under a system that disenfranchises unvaccinated employees. If a Vaccine Passport limits the duties that workers can take on, outcomes may be devastating for their livelihoods and lead to polarisation within society.

Privacy considerations:

COVID certifications pose essential questions for the protection of data privacy and human rights, given that they use sensitive personal health information to create a new distinction between individuals based on their health status, which can be used to determine the degree of freedoms individuals may enjoy.


Global context

The WHO released a statement on 15 January 2021 saying that it was opposed “for the time being” to the introduction of “vaccine passports” against COVID-19 as a condition for allowing international travellers entry into other countries, stating, “There are still too many fundamental unknowns in terms of the effectiveness of vaccines in reducing (virus) transmission and vaccines are still only available in limited quantities” 27.

Despite the WHO’s position, there appears to be a global push towards restriction on individual liberty using health and immunity passports. The highly influential World Economic Forum (WEF) has been promoting the idea of COVID-19 Passports for several months, as part of their “Great Reset” agenda28. The new digital “Common Pass” health passport scheme, backed by the WEF, was piloted for the first time in October, for passengers flying from the UK to the US29.

In November 2020, the Chinese leader Xi Jinping, in his address to other world leaders at the virtual G20 summit, promoted the Chinese model of QR access codes, based on health certificates, to re-enable international travel. Many non-governmental organisations and private corporations are lobbying governments for this technology to be adopted around the world, including the Tony Blair Institute30. This demand is not coming from the public and overrides the democratic process.

Private companies are also working on bringing in their own versions of Vaccine Passports such as IATA and IAG, the parent company of British Airways and Iberia. They have been working on a digital passport system to “manage, share and verify test data matched with traveller identities” to support the safe reopening of borders. The IATA Travel Pass comprises four key parts: a global registry of health requirements, a global registry of testing and vaccination centres, an app for labs and test centres to upload test and vaccination certificates, and an app for passengers to access these certificates, share them with airlines and authorities and to operate as a digital ‘passport’.31 This would constitute a gross intrusion into the private lives and medical information of individuals by a private company and governments.

In Israel – who have vaccinated a higher proportion of their population than any other country – a disturbing rhetoric is coming from their government. Israeli Health Minister Yuli Edelstein wants to encourage widespread vaccination by offering advantages to those who take the vaccine, and by limiting the options of those who do not. He is quoted as saying “Whoever doesn’t vaccinate will only go out to supermarkets or pharmacies, while the vaccinated will go to stadiums and gyms”32.

Iceland and Denmark have also recently announced plans to adopt Vaccine Passports33 34, and the EU has also raised the possibility of EU COVID-19 Vaccine Passports35.

Proposed Medical Freedom Bill to Safeguard UK Citizens

Save Our Rights, supported by the UK Medical Freedom Alliance and Lawyers for Liberty are currently campaigning, through lobbying MPs and Government, for a Medical Freedom Bill to be brought into law which actively protects and preserves individual medical freedom and bodily autonomy, and to ensure that no individual can be discriminated against, penalised or have restrictions imposed on them, based on their vaccine status36. I urge the government to support this important addition to individual legal protections for UK citizens.


In the context of the much-hailed success of the UK COVID-19 vaccine rollout and the desperate public desire for a return to normal life and freedom, I urge the government to allow a return to individual responsibility for our own health.

After a difficult and damaging year of unprecedented and draconian restrictions, which have removed so many of our rights and freedoms in the name of COVID-19, it is disproportionate and unnecessary to go down the route of further restrictions and loss of freedoms that a Vaccine/Immunity Passport would entail. It would permanently increase state power over our lives and set a dangerous precedent, which would effectively require the public to accept all vaccines and boosters that the Government or private businesses wish to add to the passport requirements in the future, to be able to enjoy basic human freedoms of movement and association.

Vaccine Passports have no place in a democratic and free society and would be a profoundly illiberal, undemocratic, and un-British policy. I urge the government not to pursue this dangerous path.



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