3G Rule Implementation in the Workplace

November 23rd, 2021 | by

3G Rule for Employees

The new 3G rule applies to all RWTH employees – including all students and research assistants as well as instructors – whenever they work on site. All employees must have valid proof of vaccination, recovery, or a negative test result (usually no older than 24 hours) when they start their working day at RWTH. If it is possible to carry out a supervised self-test in the respective university institution, this must be agreed in advance with the supervisor, carried out immediately upon entering the workplace, and appropriately documented. This supervised self-test then counts as proof.

Instructions for performing supervised self-tests and a documentation template are available here (PDF).

3G Compliance Check

According to the requirements of the Infection Protection Act, a daily, complete check of the 3G proof has to be carried out. At RWTH, this obligation is delegated to the head of the respective university institution or to individuals appointed by them. As this is a sensitive matter, this task should only be delegated upon mutual agreement.

Provided that proof of vaccination or recovery has been checked once and this check has been documented (see below), employees with valid poof of vaccination or recovery can then, in principle, be exempted from these daily checks. They must, however, have this proof on them at all times. The focus of the checks is the validity of the test certificates.

Employees who cannot provide the required proof shall be denied access to the workplace. The relevant HR department will offer advice on such matters as required.

Documenting 3G Compliance Checks

In order to comply with the data minimization principle of the data protection regulations, it is sufficient to “tick off” the first name and last name of the employees on a list on the respective day of the check if appropriate proof has been provided by the employee. For your convenience, a corresponding template is available here (PDF).

When it comes to vaccinated and recovered individuals, proof of a valid certificate only needs to be recorded and documented once. The end date of the recovered status must also be documented. A template is also available for this (PDF).

Proof of vaccination and recovery status and negative test certificates is subject to particularly stringent data protection. For this reason, the data, including the lists, must be kept securely in the respective university institution, separate from other files or data. In particular, it must be ensured that unauthorized individuals (external third parties, but also employees not entrusted with the documentation) cannot gain knowledge of the recorded data.

The data must be deleted or destroyed six months after collection.

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