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| Meta Title | Analysis: Digital vaccine certificates â global patchwork, little transparency - AlgorithmWatch |
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| Boilerpipe Text | This analysis is the first content published within the scope of the Tracing the Tracers Project.
Learn more about the project.
With COVID-19 vaccination campaigns ongoing in an increasing number of countries throughout the world, a global debate is emerging around the idea of issuing a digital document that effectively displays each individualâs COVID-19 vaccination status. The aim, first put forward by countries at an advanced stage of the vaccination process (e.g., Israel) and by the travel and technology industries, is to provide a tool to more safely re-open international travel and tourism routes and, in some cases, to grant broader and safer access to venues â such as gyms, stadiums, and theatres â that have been suffering from lockdown restrictions. This, proponents argue, would empower individuals and enhance their agency and autonomy after more than a year of severe limitations of their liberties and rights, freedom of movement included, due to the SARS-CoV-2 outbreak.
As of March 2021, however, there is no consensus on how to implement such a certificate â generally labeled a âvaccine certificateâ or âvaccine passportâ
[1]
â in an interoperable and globally recognized way. Details and hypotheses around what technology to use, within what broader public health framework â and even around how to name the overall endeavor â are still lacking. This situation forces whoever wants to provide a full picture of the debate to sketch a patchwork of ideas and tools developed at a national and even regional level, rather than the emergence of a global response to the challenges posed by the pandemic.
Besides, the World Health Organization (WHO) is still
urging
caution on adopting vaccine certificates as a condition for travel. âAt the present time,â reads its latest interim position paper on the topic, âit is WHOâs position that national authorities and conveyance operators should not introduce requirements of proof of COVID-19 vaccination for international travel as a condition for departure or entryâ. According to the paper, âthere are still critical unknowns regarding the efficacy of vaccination in reducing transmissionâ.
This doesnât mean that the WHO is not working on resolving such unknowns. On the contrary, it has launched an ad hoc â
Smart Vaccination Certificate Working Group
â, with the aim of developing specifications for an open and interoperable standard of vaccine certification, together with a framework for its recommended governance.
Europe: waiting for the
â
Digital Green Passâ, a plethora of local solutions
In Europe, certain countries have consistently pushed for the creation of a âvaccineâ or âimmunity passportâ over the last months â to âallow citizens to visit restaurants, conferences, music festivals and sports eventsâ (
Denmark
), âto travel abroad on holiday or to meet a loved oneâ (
Sweden
), or simply to revive summer tourism (
Spain
and
Greece
). Others, however, have shown skepticism (
France
,
Germany
), if not outright rejection of the idea (
Belgium
,
Romania
,
Serbia
).
European institutions
struggled
to reconcile the opposing views among its Member States, before reaching, on March 1st, an agreement on a so-called âDigital Green Passâ detailing,
wrote
EU Commission President Ursula von der Leyen, âproof that a person has been vaccinated, results of tests for those who couldnât get a vaccine yetâ, and âinfo on COVID19 recoveryâ.
On March 17th, the EU Commission also
highlighted
some other key elements of the âdigital green passâ, meant to âfacilitate safe free movement inside the EUâ: it will be available free of charge, issued both in paper and in a digital form, and contain a QR code with âkey informationâ and a digital signature to ascertain its authenticity. The Commission will also âbuild a gateway and support Member States to develop software that authorities can use to verify all certificate signatures across the EUâ. A â
trust framework
â for the interoperability of health certificates has been introduced by the eHealth Network, to be implemented by Member States â even though some (
Ireland
, for example) seem reluctant.
According to Commissioner for Justice, Didier Reynders, the pass âwill not be a pre-condition to free movement and it will not discriminate in any wayâ. To ensure this will actually be so, the Commission decided to provide the certificate to both vaccinated and non-vaccinated individuals, and to grant the same rights to all pass holders. Presented as a temporary measure, the pass will allegedly include âonly essential information and secure personal dataâ, namely âname, date of birth, date of issuance, relevant information about vaccine/test/recovery and a unique identifier of the certificateâ.
The design of the infrastructure and tools realizing this common endeavor is supposed to be finalized over the next three months. But in the meantime, some states decided to pave their own way forward.
For example, since May 2020, Estonia has been testing (together with tech startups Transferwise and Bolt) a
digital immunity passport
for workplaces and, since October, has been collaborating with the World Health Organization towards the creation of a digitally enhanced âInternational Certificate of Vaccinationâ or âsmart yellow cardâ. Through the use of a âtemporary QR-code generated after digital authenticationâ, it would âhelp strengthen the effectiveness of the COVAX initiativeâ, and include the development of âa global framework for health data interoperabilityâ.
Iceland has also
started
issuing its own vaccine certificates for the around 4,500 individuals who have already received the second vaccination dose. The aim, as stated on the Icelandic governmentâs website, âis to facilitate the movement of people between countries, so that individuals can present a vaccine certificate at the border and be exempt from COVID-19 border measuresâ.
Similarly, the upper Bavarian district of Altötting also
released
its first vaccination card. Equipped with a QR code, it can be scanned so that relevant data can be transferred and kept on each individualâs smartphone â and on each smartphone only, state the authorities, allegedly guaranteeing a fully privacy-preserving solution.
This is all the more significant given that German Federal authorities have initially been much more cautious in respect to the adoption of vaccine certificates. In fact, the district of Altötting claims to have operated and implemented its solution âcompletely independentlyâ of the Federal Ministry of Health. Germany has since reversed course, with the Ministry
awarding
a contract to develop a nationwide digital vaccine certification infrastructure to both the Cologne-based company, Ubirch â which proposes a solution based on QR codes and a blockchain â and IBM. But, when coupled with other solutions devised at the national level, through state-maintained patient records databases (e.g., in
Finland
) and/or in conjunction with private entities (as in
Denmark
), this local example clearly signals that solving issues of interoperability will be key to a successful implementation of a shared digital âvaccine certificateâ solution, both in and outside Europe.
And yet, even without these shared requirements, Greece is already in talks to agree agreements on travel deals with specific countries: for example,
with Cyprus and Israel
â in which a âgreen passâ has already been
issued
to give exclusive access to malls, gyms, hotels, concerts, and other premises and venues to vaccinated individuals (âWith the green pass, doors just open for youâ, reads the Israeli governmentâs
motto
); and
with the UK
, where a solution involving biometric technologies is being developed by biometric authentication and identity management companies
iProov and Mvine
, to be potentially implemented to even access pubs, restaurants, theatres, and sports events.
Outside Europe, solutions and experiments multiply
Outside of the European context, the debate is similar. In Asia, China has arguably been the first country to call for a shared global mechanism based on QR codes to recognize health certificates in a
speech
by its leader, Xi Jinping, at a G20 meeting in November 2020.
More recently, members of the Association of Southeast Asian Nations have also
declared
that they are considering the possibility of issuing a shared vaccination certificate âespecially to speed up the opening up of sectors most hard hit, such as the tourism industryâ, said Azmin Ali, Malaysia's minister of international trade and industry. Malaysia is also trialing a blockchain-based health passport, âImmuniteeâ, together with Singapore, and in collaboration with Affinidi, a global investment firm headquartered in the city-state. Information contained in the passport will only be accessible through a QR code, but will be relevant not only to government officials,
writes
MobiHealthNews, but also to âhealthcare facilities, immigration systems, hotels or universitiesâ.
A similar joint initiative has been hypothesized by the countries of the Gulf Cooperation Council, according to which a âdigital passportâ may result from an evolution of UAEâs Al Hosni mobile app. âA unified GCC health passport project has been envisaged to identify those who took Covid-19 vaccinations,â a top Omani official has stated,
according
to the Khaleej Times.
In the United States, the possibility of a vaccine certificate is part of the Biden administrationâs COVID-19 response plan. The plan
affirms
that âthe Secretary of State, the Secretary of HHS, and the Secretary of Homeland Security (âŠ), in coordination with any relevant international organizationsâ can be asked to âassess the feasibility of linking COVID-19 vaccination to International Certificates of Vaccination or Prophylaxis (ICVP) and producing electronic versions of ICVPsâ. The Hawaii islands are already
creating
their own digital vaccine passport, however, allowing incoming travelers to avoid the otherwise mandatory 10-day quarantine period.
The push from the flight industry (and tech companies)
In South America, Chile has been at the forefront of
experimenting
with ârelease certificatesâ issued to those who recovered from COVID-19, thus allowing them to âserve their communityâ (e.g., helping neighbors or elderly parents) with little to no risk of infecting others, the Lancet reports. The plan, which was met with controversy, is said to have been inspired by policies in Hong Kong and South Korea, and would not mean that beneficiaries could sidestep basic COVID-19 precautions. Also, the certificate would expire after three months.
Experiments with âvaccine passportsâ predominantly concern the flight and travel industry, with different airlines deploying different solutions. Air France, for example, is about to
trial
the International Chamber of Commerceâs AOK pass blockchain-based solution. Meanwhile, at the beginning of February 2021, it was reported that British Airways was about to begin accepting digital passports using the VeriFLY service and app for flights between the UK and the US. Trials started in November 2020 and even provided faster, separate check-in areas for customers who chose to adopt the digital passport solution, for which a selfie must be submitted.
According to Simple Flying
, customer satisfaction ratings for the service stand at â4.8 out of fiveâ.
Another travel app, SimplyGo, has been trialed on flights between the UAE and Munich, Germany, and from Tallinn, Estonia, to the UAE via Frankfurt. The app was developed by ION Access & Health, an alliance of international health and technology companies Nortal, Ottonova, InHealth, and Daman. It was used in cooperation with technology provider SITA, in a trial to collect the COVID-19 status of passengers and allow only those with a negative test result to board.
Several different solutions have been proposed to achieve similar goals. The International Air Transport Associationâs (IATA) â
Travel Pass
â is an app that can be downloaded to a passengerâs smartphone. Customers have to take a selfie and complete a âliveness testâ (âi.e., move their head, close their eyes in front of the camera as instructedâ), among other requirements. Once the app verifies that the passport data belongs to the person in front of the phoneâs camera, âfacial recognition can be used to swiftly processâ the verified data âat key touch points at the airport without the need to physically exchange passports and boarding passesâ.
The â
Commons Project
ââa self-defined ânon-profit public trust established with support from the Rockefeller Foundation to build global digital services and platforms for the common goodââis also
developing
a solution for a âsecure and verifiable way to documentâ the âhealth statusâ of travelers, together with the World Economic Forum (WEF). Called âCommonPassâ, it aims to become a âglobally-interoperable platformâ for passengers to document their COVID-19 status (âhealth declarations / PCR tests / vaccinationsâ), while at the same time storing their health records securely on their phones (through Apple Health on iOS, and CommonHealth on Android).
However, in the
FAQs
, the project draws a clear distinction between a pass and an âimmunity passportâ: âCommonPass is not an immunity passportâ, it states, âand cannot be used to prove that a person is immune to COVID-19. CommonPass can only verify that a person has recently received a test result, or has been vaccinated, for COVID-19. Neither of these is guarantee of a negative or immune statusâ.
Airlines such as JetBlue, Lufthansa, Swiss International Airlines, United Airlines, and Virgin Atlantic are adopting the solution, and the roll-out for passengers departing from New York, Boston, London, and Hong Kong, is set to start in December.
Technology companies are also deeply involved in the development of such solutions. For example, Microsoft, Oracle, and Salesforce are part of a broader coalition of tech companies, healthcare organizations, nonprofits, and academia called â
The Vaccine Credential Initiative
â
(VCI). It aims to design an open-source standard for vaccination records, so that consumers can âconveniently access, store, and shareâ them. The VCI is working in conjunction with the âCommons Projectâ and the WEF towards that end.
IBM is another tech company that is deeply involved in the healthcare sector. It is also developing a digital health platform called the â
IBM Digital Health Pass
â. It is based on blockchain technology and it is âdesigned to incorporate multiple data sources as specified by each organization â such as test results and onsite temperature scans â which can allow individuals to share their health pass through an encrypted digital wallet on their smartphoneâ. This would result in âa smart way to return to societyâ, according to IBM.
The multiplicity of solutions offered by the air transport and tech industries already led some startups to create a one-stop solution through which to manage all vaccine passport-related credentials. Given that different countries and companies might end up requiring the download of multiple apps to prove a passengerâs COVID-19 status for a single trip, digital identity company Airside Mobile has decided to partner with Vision Box, a Portuguese biometrics company, to provide a certifications manager app that can host not only health-related records but also passport, driverâs license, and other information, all through âend-to-end biometric source verificationâ. âTravelers download the Airside app, identify with us and provide a one-time privacy consent, and then Vision-Box picks up the baton,â says Airside Mobile CEO, Amena Ali, quoted in
Forbes
.
Automated decision-making: too early to look into the specifics
Such a diverse set of proposed solutions to the problem of having a workable and interoperable framework and infrastructure for COVID-19 vaccine certifications makes it difficult to assess how each of them actually works and, therefore, whether and how they could be infringing on fundamental rights, privacy, and security. What kind of shared data infrastructure will be needed to implement a globally interoperable network of digital vaccine certifications? Could it provide leeway for âfunction creepâ (e.g., being deployed outside its scope)? Will it be secure and fraud-proof (this is already
an issue
in Israel)? And what role will be played by the private sector in realizing and managing it? It is simply too early to tell.
Also, and typically for socio-technical automated decision-making (ADM) systems, the urgency with which digital vaccination certificates are being proposed and announced has been usually not met with a corresponding level of transparency and detail over their functionalities. Most digital vaccine certification tools are still in their early or experimental stages, while othersâsuch as the EUâs âdigital green passââhavenât yet been fully designed, at the time of writing. We know that some countries (e.g., the
UK
,
Switzerland
, and
Bahrain
) plan to add this functionality to already deployed contact tracing COVID-19 apps. And we also know that many involve blockchain and biometric technologies. But we donât know much else at this point.
Much is yet to come, and rather than discussing detailed ADM systems, the international discourse around vaccine passports and certificates has mostly focused on more general issues. For example, whether they can be deployed ethically and effectively, whether they make scientific sense, and what kind of activities they would allow in their quest to give people a renewed sense of agency and autonomy, even though the pandemic shows no signs of slowing down.
As has
constantly been the case
for the deployment of other ADM systems in Europe (and beyond), including in the context of the
pandemic
, urgency has also been exploited to deploy technological solutions for COVID-19 vaccine certification in the absence of a meaningful democratic debate around their actual merits and opportunity. In Israel, where a âgreen passâ has already been issued, this resulted in protests against âvaccine coercionâ and the privileges of a âvaccinated classâ in the
streets of Tel Aviv
.
Pros and cons of vaccine certificates
And yet, vaccine certificatesâat least theoreticallyâpresent both opportunities and risks that are being investigated by civil society actors (e.g., the
Ada Lovelace Institute
), research institutions (e.g., the
Royal Society
),
academia
, and in several media analyses and reports.
The opportunities offered by the adoption of an interoperable digital vaccine certification scheme are more clearly expressed by their proponents. Among the benefits they list: 1) an instrument to safely reopen the economy; 2) a way to help individuals more securely return to ânormal lifeâ, thus showing a way out of the pandemic restrictions affecting individual autonomy and agency without compromising collective public health; 3) faster, more efficient, âseamlessâ and mostly touch-less security checks for travelers, thus minimizing the risks of infection while traveling; 4) a tool to more generally reduce COVID-19 transmission within the population.
An interesting and unique addition comes from the Chilean experiment whereby ârelease certificatesâ are offered to those who have recovered from the disease. This solution has been touted as an instrument to enhance care, empathy, and human connection. This certification scheme would link to the idea of âserving the communityâ and help combat feelings of isolation and loneliness during the pandemic.
Vaccine passports proponents argue all of this could be realized without infringing on individual privacy and without the risk of compromising a userâs security. Customers will decide who to share their vaccine and COVID-19-related health information with and for how long, and most solutions claim that digital certification data will only be kept on the userâs phone.
Risks abound, however, and they involve scientific, ethical, and technological challenges.
Scientific challenges relate to the fact that, while vaccines demonstrably work in protecting a vaccinated individual from catching the COVID-19 disease, there is currently no scientific consensus around their capacity to reduce its transmission, preventing a vaccinated individual from infecting others. Also, as COVID-19 variants keep multiplying and spreading, some have been shown to potentially reduce vaccine efficacy. Therefore, a vaccine certificate should be flexible and allow for constant updates and fine-tuning so that a false sense of security provided by an outdated vaccine can be avoided.
Other critical scientific unknowns concern how long the protection granted by the vaccine will last, and whether it also prevents asymptomatic infection â both crucial elements for any plan that implies a âreturn to normalâ on the basis of a digital vaccine certificate scheme. All of this leads the German Ethics Council to
conclude
that âat this point in time there should be no individual withdrawal of state restrictions on civil liberties for vaccinated persons, because their infectiousness cannot be reliably estimated as yet.â
These scientific challenges also bear behavioral consequences. The Ethics Council, for example, notes that âfor as long as not all people can get vaccinated, part of the population would perceive as unjust an individual withdrawal of state restrictions on civil liberties for vaccinated people onlyâ. This could also lead to reduced solidarity and willingness to comply with social distancing rules, ultimately undermining their effectiveness. Problematic behavioral incentives could go as far as individuals actively seeking out infection, âespeciallyâ, notes Georgetown Universityâs Alexandra Phelan on
the Lancet
, âpeople who are unable to afford a period of workforce exclusion, compounding existing gender, race, ethnicity, and nationality inequitiesâ.
Ethical challenges have also been explored in detail, and are far from resolved. On Scientific American, Nicole Hassoun and Anders Herlitz,
argue
that the benefits from vaccination or immunity passports, âwill be dispersed unequallyâ, exacerbating existing inequalities. Furthermore, an editorial in the Lancet
argues
: âIf immunity passports were introduced, marginalised groups would be subject to more scrutiny because of existing inequities and racism (eg, police checks for lockdown regulations) and would be less likely to access testing (and establish immunity) than non-marginalised groups would beâ.
Also, given that vaccine shots are being disproportionately provided to rich countries â it is estimated that â9 out of 10 people living in the poorest countries in the world may not receive the vaccine this yearâ, write Claire Loughnan and Sara Dehm on
The Conversation
â refugees and asylum-seekers are likely to be more severely affected.
However, this has not just to do with unequal availability of vaccination shots: certain individuals might not be able to receive a shot even if it is available. For example, for medical reasons (pregnant women, people with certain allergies, etc.). It can be argued that depriving them of the privileges afforded to the vaccinated would be unethical. This has led Hassoun and Herlitz to argue that âin order for them to be ethicalâ, immunity passports âmust at least include some exceptionsâ. For example, âpeople who cannot access vaccines for health reasons but need to work, attend school, travel and so forth should be able to do so when the benefits exceed the risksâ. Welfare exceptions should also be made. For example, to those who desperately need to go to work âin places that require social interactionâ to support their families.
In addition, if they are not carefully implemented through privacy-preserving technologies, vaccine certificates could also pose privacy risks and even lead to ânormalising health status surveillance by creating long-term infrastructure in response to a time-bounded crisisâ, as the Ada Lovelace Institute wrote in its âRapid Expert Deliberationâ,
published
in February 2021.
Conclusion: clarity and details are urgently needed
Vaccine certification schemes are being debated worldwide as tools to facilitate the reopening of travel routes and the economy, while at the same time progressively ending the severe limitations of rights and freedoms put in place during the pandemic.
Several different solutions have been envisioned, but most have not been described in detail yet, and no global consensus has emerged around any of them. Confusion has ensued in many instances, both in terminology and proposed ADM systems.
Interoperability and infrastructural issues have yet to be solved. At the same time, this raises a complex plethora of considerations that highlight both the promises and the risks of adopting vaccine certificates.
Even though several systems are already being trialed, any meaningful democratic debate is missing, and transparency is still mostly lacking. And yet, in order to actually judge the broader feasibility and opportunity of realizing vaccine certificates for society, we will need to see the specifics of the plans that are being devised, especially at the international level.
[1]
A certain confusion ensues, at times equating vaccine and immunity passports (which may include positive COVID-19 antibody test results as well), or certificates and passports (with the latter term more strongly suggesting a mandatory prerequisite for traveling, rather than mere proof of vaccination). |
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# Analysis: Digital vaccine certificates â global patchwork, little transparency
*by [Fabio Chiusi](https://algorithmwatch.org/en/team/fabio-chiusi)*
**A global debate has sparked around the idea of implementing a digital infrastructure to prove a personâs COVID-19 vaccination status across borders. But as the initiatives multiply across Europe and all over the globe, an international consensus is hard to reach â and issues still abound.**
#### [Publication](https://algorithmwatch.org/en/publications)
#### March 29, 2021
#### [\#covid19](https://algorithmwatch.org/en/hashtag/covid-19/) [\#vaccination](https://algorithmwatch.org/en/hashtag/vaccination/) [\#vaccine](https://algorithmwatch.org/en/hashtag/vaccine/)
[](https://algorithmwatch.org/en/team/fabio-chiusi/)
Fabio Chiusi
Research Associate
[chiusi@algorithmwatch.org](mailto:mailto:chiusi@algorithmwatch.org)
This analysis is the first content published within the scope of the Tracing the Tracers Project. [Learn more about the project.](https://algorithmwatch.org/en/tracing-the-tracers/about-the-project/)
With COVID-19 vaccination campaigns ongoing in an increasing number of countries throughout the world, a global debate is emerging around the idea of issuing a digital document that effectively displays each individualâs COVID-19 vaccination status. The aim, first put forward by countries at an advanced stage of the vaccination process (e.g., Israel) and by the travel and technology industries, is to provide a tool to more safely re-open international travel and tourism routes and, in some cases, to grant broader and safer access to venues â such as gyms, stadiums, and theatres â that have been suffering from lockdown restrictions. This, proponents argue, would empower individuals and enhance their agency and autonomy after more than a year of severe limitations of their liberties and rights, freedom of movement included, due to the SARS-CoV-2 outbreak.
As of March 2021, however, there is no consensus on how to implement such a certificate â generally labeled a âvaccine certificateâ or âvaccine passportâ[\[1\]](https://algorithmwatch.org/en/digital-vaccine-certificates-analysis-march-2021/#_ftn1) â in an interoperable and globally recognized way. Details and hypotheses around what technology to use, within what broader public health framework â and even around how to name the overall endeavor â are still lacking. This situation forces whoever wants to provide a full picture of the debate to sketch a patchwork of ideas and tools developed at a national and even regional level, rather than the emergence of a global response to the challenges posed by the pandemic.
Besides, the World Health Organization (WHO) is still [urging](https://www.who.int/news-room/articles-detail/interim-position-paper-considerations-regarding-proof-of-covid-19-vaccination-for-international-travellers) caution on adopting vaccine certificates as a condition for travel. âAt the present time,â reads its latest interim position paper on the topic, âit is WHOâs position that national authorities and conveyance operators should not introduce requirements of proof of COVID-19 vaccination for international travel as a condition for departure or entryâ. According to the paper, âthere are still critical unknowns regarding the efficacy of vaccination in reducing transmissionâ.
This doesnât mean that the WHO is not working on resolving such unknowns. On the contrary, it has launched an ad hoc â[Smart Vaccination Certificate Working Group](https://www.who.int/groups/smart-vaccination-certificate-working-group)â, with the aim of developing specifications for an open and interoperable standard of vaccine certification, together with a framework for its recommended governance.
## **Europe: waiting for the** â**Digital Green Passâ, a plethora of local solutions**
In Europe, certain countries have consistently pushed for the creation of a âvaccineâ or âimmunity passportâ over the last months â to âallow citizens to visit restaurants, conferences, music festivals and sports eventsâ ([Denmark](https://www.dw.com/en/coronavirus-digest-denmark-plans-covid-vaccination-passport/a-56436606)), âto travel abroad on holiday or to meet a loved oneâ ([Sweden](https://www.thelocal.se/20210204/sweden-to-introduce-digital-vaccine-passport/)), or simply to revive summer tourism ([Spain](https://www.reuters.com/article/us-health-coronavirus-spain-tourism-idUSKBN2AG2CW) and [Greece](https://www.schengenvisainfo.com/news/greece-urges-eu-to-create-vaccination-certificate-to-facilitate-travel/)). Others, however, have shown skepticism ([France](https://www.thelocal.fr/20210217/is-france-likely-to-introduce-a-vaccine-passport-for-travel/), [Germany](https://www.healthcareitnews.com/news/emea/european-leaders-debate-eu-wide-vaccine-passports)), if not outright rejection of the idea ([Belgium](https://twitter.com/Sophie_Wilmes/status/1366380299995795458), [Romania](https://www.euractiv.com/section/coronavirus/news/romania-rejects-divisive-greek-proposal-for-vaccine-certificate/), [Serbia](https://www.aa.com.tr/en/europe/vaccine-passport-idea-in-eu-shameful-serbia/2159298)).
European institutions [struggled](https://www.dw.com/en/coronavirus-eu-leaders-consider-vaccine-passports/a-56682684) to reconcile the opposing views among its Member States, before reaching, on March 1st, an agreement on a so-called âDigital Green Passâ detailing, [wrote](https://twitter.com/vonderleyen/status/1366346729289904128) EU Commission President Ursula von der Leyen, âproof that a person has been vaccinated, results of tests for those who couldnât get a vaccine yetâ, and âinfo on COVID19 recoveryâ.
On March 17th, the EU Commission also [highlighted](https://ec.europa.eu/commission/presscorner/detail/en/ip_21_1181) some other key elements of the âdigital green passâ, meant to âfacilitate safe free movement inside the EUâ: it will be available free of charge, issued both in paper and in a digital form, and contain a QR code with âkey informationâ and a digital signature to ascertain its authenticity. The Commission will also âbuild a gateway and support Member States to develop software that authorities can use to verify all certificate signatures across the EUâ. A â[trust framework](https://ec.europa.eu/health/sites/health/files/ehealth/docs/trust-framework_interoperability_certificates_en.pdf)â for the interoperability of health certificates has been introduced by the eHealth Network, to be implemented by Member States â even though some ([Ireland](https://www.dw.com/en/irish-foreign-minister-urges-caution-with-eu-vaccine-passport-plans/a-56903488), for example) seem reluctant.
According to Commissioner for Justice, Didier Reynders, the pass âwill not be a pre-condition to free movement and it will not discriminate in any wayâ. To ensure this will actually be so, the Commission decided to provide the certificate to both vaccinated and non-vaccinated individuals, and to grant the same rights to all pass holders. Presented as a temporary measure, the pass will allegedly include âonly essential information and secure personal dataâ, namely âname, date of birth, date of issuance, relevant information about vaccine/test/recovery and a unique identifier of the certificateâ.
The design of the infrastructure and tools realizing this common endeavor is supposed to be finalized over the next three months. But in the meantime, some states decided to pave their own way forward.
For example, since May 2020, Estonia has been testing (together with tech startups Transferwise and Bolt) a [digital immunity passport](https://www.reuters.com/article/health-coronavirus-estonia-digital-idUSKBN22W0GE)for workplaces and, since October, has been collaborating with the World Health Organization towards the creation of a digitally enhanced âInternational Certificate of Vaccinationâ or âsmart yellow cardâ. Through the use of a âtemporary QR-code generated after digital authenticationâ, it would âhelp strengthen the effectiveness of the COVAX initiativeâ, and include the development of âa global framework for health data interoperabilityâ.
Iceland has also [started](https://www.government.is/diplomatic-missions/embassy-article/2021/01/25/COVID-19-Digital-vaccine-certificates/) issuing its own vaccine certificates for the around 4,500 individuals who have already received the second vaccination dose. The aim, as stated on the Icelandic governmentâs website, âis to facilitate the movement of people between countries, so that individuals can present a vaccine certificate at the border and be exempt from COVID-19 border measuresâ.
Similarly, the upper Bavarian district of Altötting also [released](https://www.heise.de/news/Bayerischer-Landkreis-vergibt-ersten-digitalen-Corona-Impfpass-5034020.html) its first vaccination card. Equipped with a QR code, it can be scanned so that relevant data can be transferred and kept on each individualâs smartphone â and on each smartphone only, state the authorities, allegedly guaranteeing a fully privacy-preserving solution.
This is all the more significant given that German Federal authorities have initially been much more cautious in respect to the adoption of vaccine certificates. In fact, the district of Altötting claims to have operated and implemented its solution âcompletely independentlyâ of the Federal Ministry of Health. Germany has since reversed course, with the Ministry [awarding](https://www.spiegel.de/netzwelt/gadgets/ubirch-und-ibm-erhalten-zuschlag-fuer-deutschen-digitalen-impfnachweis-a-9f26439b-8fd8-4118-9221-eb8844946c69) a contract to develop a nationwide digital vaccine certification infrastructure to both the Cologne-based company, Ubirch â which proposes a solution based on QR codes and a blockchain â and IBM. But, when coupled with other solutions devised at the national level, through state-maintained patient records databases (e.g., in [Finland](https://yle.fi/uutiset/osasto/news/finland_planning_to_introduce_coronavirus_vaccine_certificate/11775698)) and/or in conjunction with private entities (as in [Denmark](https://www.dw.com/en/coronavirus-digest-denmark-plans-covid-vaccination-passport/a-56436606)), this local example clearly signals that solving issues of interoperability will be key to a successful implementation of a shared digital âvaccine certificateâ solution, both in and outside Europe.
And yet, even without these shared requirements, Greece is already in talks to agree agreements on travel deals with specific countries: for example, [with Cyprus and Israel](https://travelweekly.co.uk/news/air/greece-cyprus-and-israel-agree-vaccine-travel-deals) â in which a âgreen passâ has already been [issued](https://www.jpost.com/israel-news/everything-you-need-to-know-about-israels-green-passport-program-659437) to give exclusive access to malls, gyms, hotels, concerts, and other premises and venues to vaccinated individuals (âWith the green pass, doors just open for youâ, reads the Israeli governmentâs [motto](https://apnews.com/article/coronavirus-vaccination-passports-7a8ce11ce37c309d97969ab71df26e62)); and [with the UK](https://www.theguardian.com/world/2021/feb/24/greece-in-technical-talks-with-the-uk-to-allow-holidays-with-vaccine-passports), where a solution involving biometric technologies is being developed by biometric authentication and identity management companies [iProov and Mvine](https://www.iproov.com/blog/delivering-first-covid-19-antibody-test-status-digital-passport), to be potentially implemented to even access pubs, restaurants, theatres, and sports events.
## **Outside Europe, solutions and experiments multiply**
Outside of the European context, the debate is similar. In Asia, China has arguably been the first country to call for a shared global mechanism based on QR codes to recognize health certificates in a [speech](https://edition.cnn.com/2020/11/23/asia/china-xi-qr-code-coronavirus-intl-hnk/index.html) by its leader, Xi Jinping, at a G20 meeting in November 2020.
More recently, members of the Association of Southeast Asian Nations have also [declared](https://asia.nikkei.com/Economy/ASEAN-eyes-digital-vaccine-certificate-for-post-COVID-travel) that they are considering the possibility of issuing a shared vaccination certificate âespecially to speed up the opening up of sectors most hard hit, such as the tourism industryâ, said Azmin Ali, Malaysia's minister of international trade and industry. Malaysia is also trialing a blockchain-based health passport, âImmuniteeâ, together with Singapore, and in collaboration with Affinidi, a global investment firm headquartered in the city-state. Information contained in the passport will only be accessible through a QR code, but will be relevant not only to government officials, [writes](https://www.mobihealthnews.com/news/apac/malaysia-s-first-health-passport-immunitee-formally-accepted-singapore) MobiHealthNews, but also to âhealthcare facilities, immigration systems, hotels or universitiesâ.
A similar joint initiative has been hypothesized by the countries of the Gulf Cooperation Council, according to which a âdigital passportâ may result from an evolution of UAEâs Al Hosni mobile app. âA unified GCC health passport project has been envisaged to identify those who took Covid-19 vaccinations,â a top Omani official has stated, [according](https://www.khaleejtimes.com/news/gcc-covid-passport-would-store-vaccine-travel-eligibility-info) to the Khaleej Times.
In the United States, the possibility of a vaccine certificate is part of the Biden administrationâs COVID-19 response plan. The plan [affirms](https://www.whitehouse.gov/wp-content/uploads/2021/01/National-Strategy-for-the-COVID-19-Response-and-Pandemic-Preparedness.pdf) that âthe Secretary of State, the Secretary of HHS, and the Secretary of Homeland Security (âŠ), in coordination with any relevant international organizationsâ can be asked to âassess the feasibility of linking COVID-19 vaccination to International Certificates of Vaccination or Prophylaxis (ICVP) and producing electronic versions of ICVPsâ. The Hawaii islands are already [creating](https://www.forbes.com/sites/suzannerowankelleher/2021/02/19/hawaii-is-creating-a-vaccine-passport-that-lets-you-skip-the-10-day-quarantine/?sh=3e21c8334302) their own digital vaccine passport, however, allowing incoming travelers to avoid the otherwise mandatory 10-day quarantine period.
## **The push from the flight industry (and tech companies)**
In South America, Chile has been at the forefront of [experimenting](https://www.thelancet.com/journals/lancet/article/PIIS0140-6736\(20\)31096-5/fulltext) with ârelease certificatesâ issued to those who recovered from COVID-19, thus allowing them to âserve their communityâ (e.g., helping neighbors or elderly parents) with little to no risk of infecting others, the Lancet reports. The plan, which was met with controversy, is said to have been inspired by policies in Hong Kong and South Korea, and would not mean that beneficiaries could sidestep basic COVID-19 precautions. Also, the certificate would expire after three months.
Experiments with âvaccine passportsâ predominantly concern the flight and travel industry, with different airlines deploying different solutions. Air France, for example, is about to [trial](https://www.ledgerinsights.com/air-france-to-pilot-iccs-blockchain-covid-19-credentials-app/) the International Chamber of Commerceâs AOK pass blockchain-based solution. Meanwhile, at the beginning of February 2021, it was reported that British Airways was about to begin accepting digital passports using the VeriFLY service and app for flights between the UK and the US. Trials started in November 2020 and even provided faster, separate check-in areas for customers who chose to adopt the digital passport solution, for which a selfie must be submitted. [According to Simple Flying](https://simpleflying.com/british-airways-health-passports/), customer satisfaction ratings for the service stand at â4.8 out of fiveâ.
Another travel app, SimplyGo, has been trialed on flights between the UAE and Munich, Germany, and from Tallinn, Estonia, to the UAE via Frankfurt. The app was developed by ION Access & Health, an alliance of international health and technology companies Nortal, Ottonova, InHealth, and Daman. It was used in cooperation with technology provider SITA, in a trial to collect the COVID-19 status of passengers and allow only those with a negative test result to board.
Several different solutions have been proposed to achieve similar goals. The International Air Transport Associationâs (IATA) â[Travel Pass](https://www.iata.org/contentassets/2b02a4f452384b1fbae0a4c40e8a5d0c/travel-pass-faqs.pdf)â is an app that can be downloaded to a passengerâs smartphone. Customers have to take a selfie and complete a âliveness testâ (âi.e., move their head, close their eyes in front of the camera as instructedâ), among other requirements. Once the app verifies that the passport data belongs to the person in front of the phoneâs camera, âfacial recognition can be used to swiftly processâ the verified data âat key touch points at the airport without the need to physically exchange passports and boarding passesâ.
The â[Commons Project](https://thecommonsproject.org/)ââa self-defined ânon-profit public trust established with support from the Rockefeller Foundation to build global digital services and platforms for the common goodââis also [developing](http://\(https/static1.squarespace.com/static/5ed685211872ca0609188980/t/5fc90d42ae28fe4947430767/1607011651080/New+CommonTrust+Network+members+and+roll+out+20201124.pdf) a solution for a âsecure and verifiable way to documentâ the âhealth statusâ of travelers, together with the World Economic Forum (WEF). Called âCommonPassâ, it aims to become a âglobally-interoperable platformâ for passengers to document their COVID-19 status (âhealth declarations / PCR tests / vaccinationsâ), while at the same time storing their health records securely on their phones (through Apple Health on iOS, and CommonHealth on Android).
However, in the [FAQs](https://commonpass.org/faqs), the project draws a clear distinction between a pass and an âimmunity passportâ: âCommonPass is not an immunity passportâ, it states, âand cannot be used to prove that a person is immune to COVID-19. CommonPass can only verify that a person has recently received a test result, or has been vaccinated, for COVID-19. Neither of these is guarantee of a negative or immune statusâ.
Airlines such as JetBlue, Lufthansa, Swiss International Airlines, United Airlines, and Virgin Atlantic are adopting the solution, and the roll-out for passengers departing from New York, Boston, London, and Hong Kong, is set to start in December.
Technology companies are also deeply involved in the development of such solutions. For example, Microsoft, Oracle, and Salesforce are part of a broader coalition of tech companies, healthcare organizations, nonprofits, and academia called â[The Vaccine Credential Initiative](https://vaccinationcredential.org/)[â](https://vaccinationcredential.org/) (VCI). It aims to design an open-source standard for vaccination records, so that consumers can âconveniently access, store, and shareâ them. The VCI is working in conjunction with the âCommons Projectâ and the WEF towards that end.
IBM is another tech company that is deeply involved in the healthcare sector. It is also developing a digital health platform called the â[IBM Digital Health Pass](https://www.ibm.com/products/digital-health-pass)â. It is based on blockchain technology and it is âdesigned to incorporate multiple data sources as specified by each organization â such as test results and onsite temperature scans â which can allow individuals to share their health pass through an encrypted digital wallet on their smartphoneâ. This would result in âa smart way to return to societyâ, according to IBM.
The multiplicity of solutions offered by the air transport and tech industries already led some startups to create a one-stop solution through which to manage all vaccine passport-related credentials. Given that different countries and companies might end up requiring the download of multiple apps to prove a passengerâs COVID-19 status for a single trip, digital identity company Airside Mobile has decided to partner with Vision Box, a Portuguese biometrics company, to provide a certifications manager app that can host not only health-related records but also passport, driverâs license, and other information, all through âend-to-end biometric source verificationâ. âTravelers download the Airside app, identify with us and provide a one-time privacy consent, and then Vision-Box picks up the baton,â says Airside Mobile CEO, Amena Ali, quoted in [Forbes](https://www.forbes.com/sites/suzannerowankelleher/2021/02/25/this-one-stop-digital-id-app-wants-to-cut-through-the-vaccine-passport-noise/?sh=1d5cb1a5220e).
## **Automated decision-making: too early to look into the specifics**
Such a diverse set of proposed solutions to the problem of having a workable and interoperable framework and infrastructure for COVID-19 vaccine certifications makes it difficult to assess how each of them actually works and, therefore, whether and how they could be infringing on fundamental rights, privacy, and security. What kind of shared data infrastructure will be needed to implement a globally interoperable network of digital vaccine certifications? Could it provide leeway for âfunction creepâ (e.g., being deployed outside its scope)? Will it be secure and fraud-proof (this is already [an issue](https://www.haaretz.com/israel-news/tech-news/.premium-anyone-can-still-fake-israel-s-coronavirus-vaccination-certification-1.9549889) in Israel)? And what role will be played by the private sector in realizing and managing it? It is simply too early to tell.
Also, and typically for socio-technical automated decision-making (ADM) systems, the urgency with which digital vaccination certificates are being proposed and announced has been usually not met with a corresponding level of transparency and detail over their functionalities. Most digital vaccine certification tools are still in their early or experimental stages, while othersâsuch as the EUâs âdigital green passââhavenât yet been fully designed, at the time of writing. We know that some countries (e.g., the [UK](https://www.thetimes.co.uk/article/nhs-app-to-be-converted-for-vaccine-passports-r0xx0mflp), [Switzerland](https://www.thelocal.ch/20210222/a-ticket-back-to-normality-swiss-support-for-vaccination-pass-grows/), and [Bahrain](https://www.mobihealthnews.com/news/emea/bahrain-launches-digital-covid-19-vaccine-passport)) plan to add this functionality to already deployed contact tracing COVID-19 apps. And we also know that many involve blockchain and biometric technologies. But we donât know much else at this point.
Much is yet to come, and rather than discussing detailed ADM systems, the international discourse around vaccine passports and certificates has mostly focused on more general issues. For example, whether they can be deployed ethically and effectively, whether they make scientific sense, and what kind of activities they would allow in their quest to give people a renewed sense of agency and autonomy, even though the pandemic shows no signs of slowing down.
As has [constantly been the case](https://automatingsociety.algorithmwatch.org/) for the deployment of other ADM systems in Europe (and beyond), including in the context of the [pandemic](https://algorithmwatch.org/en/automating-society-2020-covid19/), urgency has also been exploited to deploy technological solutions for COVID-19 vaccine certification in the absence of a meaningful democratic debate around their actual merits and opportunity. In Israel, where a âgreen passâ has already been issued, this resulted in protests against âvaccine coercionâ and the privileges of a âvaccinated classâ in the [streets of Tel Aviv](https://www.jpost.com/israel-news/protesters-demonstrate-against-vaccine-coercion-green-passports-in-tel-aviv-660106).
## **Pros and cons of vaccine certificates**
And yet, vaccine certificatesâat least theoreticallyâpresent both opportunities and risks that are being investigated by civil society actors (e.g., the [Ada Lovelace Institute](https://www.adalovelaceinstitute.org/summary/covid-19-vaccine-passports/)), research institutions (e.g., the [Royal Society](https://royalsociety.org/news/2021/02/12-challenges-for-vaccine-passports/)), [academia](https://socialsciences.exeter.ac.uk/media/universityofexeter/collegeofsocialsciencesandinternationalstudies/lawimages/research/Policy_brief_-_Digital_Health_Passports_COVID-19_-_Beduschi.pdf), and in several media analyses and reports.
The opportunities offered by the adoption of an interoperable digital vaccine certification scheme are more clearly expressed by their proponents. Among the benefits they list: 1) an instrument to safely reopen the economy; 2) a way to help individuals more securely return to ânormal lifeâ, thus showing a way out of the pandemic restrictions affecting individual autonomy and agency without compromising collective public health; 3) faster, more efficient, âseamlessâ and mostly touch-less security checks for travelers, thus minimizing the risks of infection while traveling; 4) a tool to more generally reduce COVID-19 transmission within the population.
An interesting and unique addition comes from the Chilean experiment whereby ârelease certificatesâ are offered to those who have recovered from the disease. This solution has been touted as an instrument to enhance care, empathy, and human connection. This certification scheme would link to the idea of âserving the communityâ and help combat feelings of isolation and loneliness during the pandemic.
Vaccine passports proponents argue all of this could be realized without infringing on individual privacy and without the risk of compromising a userâs security. Customers will decide who to share their vaccine and COVID-19-related health information with and for how long, and most solutions claim that digital certification data will only be kept on the userâs phone.
Risks abound, however, and they involve scientific, ethical, and technological challenges.
Scientific challenges relate to the fact that, while vaccines demonstrably work in protecting a vaccinated individual from catching the COVID-19 disease, there is currently no scientific consensus around their capacity to reduce its transmission, preventing a vaccinated individual from infecting others. Also, as COVID-19 variants keep multiplying and spreading, some have been shown to potentially reduce vaccine efficacy. Therefore, a vaccine certificate should be flexible and allow for constant updates and fine-tuning so that a false sense of security provided by an outdated vaccine can be avoided.
Other critical scientific unknowns concern how long the protection granted by the vaccine will last, and whether it also prevents asymptomatic infection â both crucial elements for any plan that implies a âreturn to normalâ on the basis of a digital vaccine certificate scheme. All of this leads the German Ethics Council to [conclude](https://www.ethikrat.org/fileadmin/Publikationen/Ad-hoc-Empfehlungen/englisch/recommendation-special-rules-for-vaccinated-people.pdf) that âat this point in time there should be no individual withdrawal of state restrictions on civil liberties for vaccinated persons, because their infectiousness cannot be reliably estimated as yet.â
These scientific challenges also bear behavioral consequences. The Ethics Council, for example, notes that âfor as long as not all people can get vaccinated, part of the population would perceive as unjust an individual withdrawal of state restrictions on civil liberties for vaccinated people onlyâ. This could also lead to reduced solidarity and willingness to comply with social distancing rules, ultimately undermining their effectiveness. Problematic behavioral incentives could go as far as individuals actively seeking out infection, âespeciallyâ, notes Georgetown Universityâs Alexandra Phelan on [the Lancet](https://www.thelancet.com/pdfs/journals/lancet/PIIS0140-6736\(20\)31034-5.pdf\)), âpeople who are unable to afford a period of workforce exclusion, compounding existing gender, race, ethnicity, and nationality inequitiesâ.
Ethical challenges have also been explored in detail, and are far from resolved. On Scientific American, Nicole Hassoun and Anders Herlitz, [argue](https://www.scientificamerican.com/article/how-to-make-immunity-passports-more-ethical/) that the benefits from vaccination or immunity passports, âwill be dispersed unequallyâ, exacerbating existing inequalities. Furthermore, an editorial in the Lancet [argues](https://www.thelancet.com/journals/laninf/article/PIIS1473-3099\(20\)30766-0/fulltext): âIf immunity passports were introduced, marginalised groups would be subject to more scrutiny because of existing inequities and racism (eg, police checks for lockdown regulations) and would be less likely to access testing (and establish immunity) than non-marginalised groups would beâ.
Also, given that vaccine shots are being disproportionately provided to rich countries â it is estimated that â9 out of 10 people living in the poorest countries in the world may not receive the vaccine this yearâ, write Claire Loughnan and Sara Dehm on [The Conversation](https://theconversation.com/a-covid-vaccine-passport-may-further-disadvantage-refugees-and-asylum-seekers-155287) â refugees and asylum-seekers are likely to be more severely affected.
However, this has not just to do with unequal availability of vaccination shots: certain individuals might not be able to receive a shot even if it is available. For example, for medical reasons (pregnant women, people with certain allergies, etc.). It can be argued that depriving them of the privileges afforded to the vaccinated would be unethical. This has led Hassoun and Herlitz to argue that âin order for them to be ethicalâ, immunity passports âmust at least include some exceptionsâ. For example, âpeople who cannot access vaccines for health reasons but need to work, attend school, travel and so forth should be able to do so when the benefits exceed the risksâ. Welfare exceptions should also be made. For example, to those who desperately need to go to work âin places that require social interactionâ to support their families.
In addition, if they are not carefully implemented through privacy-preserving technologies, vaccine certificates could also pose privacy risks and even lead to ânormalising health status surveillance by creating long-term infrastructure in response to a time-bounded crisisâ, as the Ada Lovelace Institute wrote in its âRapid Expert Deliberationâ, [published](https://www.adalovelaceinstitute.org/wp-content/uploads/2021/02/COVID-19-vaccine-passports-rapid-expert-deliberation.pdf) in February 2021.
## **Conclusion: clarity and details are urgently needed**
Vaccine certification schemes are being debated worldwide as tools to facilitate the reopening of travel routes and the economy, while at the same time progressively ending the severe limitations of rights and freedoms put in place during the pandemic.
Several different solutions have been envisioned, but most have not been described in detail yet, and no global consensus has emerged around any of them. Confusion has ensued in many instances, both in terminology and proposed ADM systems.
Interoperability and infrastructural issues have yet to be solved. At the same time, this raises a complex plethora of considerations that highlight both the promises and the risks of adopting vaccine certificates.
Even though several systems are already being trialed, any meaningful democratic debate is missing, and transparency is still mostly lacking. And yet, in order to actually judge the broader feasibility and opportunity of realizing vaccine certificates for society, we will need to see the specifics of the plans that are being devised, especially at the international level.
***
[\[1\]](https://algorithmwatch.org/en/digital-vaccine-certificates-analysis-march-2021/#_ftnref1) A certain confusion ensues, at times equating vaccine and immunity passports (which may include positive COVID-19 antibody test results as well), or certificates and passports (with the latter term more strongly suggesting a mandatory prerequisite for traveling, rather than mere proof of vaccination).
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With COVID-19 vaccination campaigns ongoing in an increasing number of countries throughout the world, a global debate is emerging around the idea of issuing a digital document that effectively displays each individualâs COVID-19 vaccination status. The aim, first put forward by countries at an advanced stage of the vaccination process (e.g., Israel) and by the travel and technology industries, is to provide a tool to more safely re-open international travel and tourism routes and, in some cases, to grant broader and safer access to venues â such as gyms, stadiums, and theatres â that have been suffering from lockdown restrictions. This, proponents argue, would empower individuals and enhance their agency and autonomy after more than a year of severe limitations of their liberties and rights, freedom of movement included, due to the SARS-CoV-2 outbreak.
As of March 2021, however, there is no consensus on how to implement such a certificate â generally labeled a âvaccine certificateâ or âvaccine passportâ[\[1\]](https://algorithmwatch.org/en/digital-vaccine-certificates-analysis-march-2021/#_ftn1) â in an interoperable and globally recognized way. Details and hypotheses around what technology to use, within what broader public health framework â and even around how to name the overall endeavor â are still lacking. This situation forces whoever wants to provide a full picture of the debate to sketch a patchwork of ideas and tools developed at a national and even regional level, rather than the emergence of a global response to the challenges posed by the pandemic.
Besides, the World Health Organization (WHO) is still [urging](https://www.who.int/news-room/articles-detail/interim-position-paper-considerations-regarding-proof-of-covid-19-vaccination-for-international-travellers) caution on adopting vaccine certificates as a condition for travel. âAt the present time,â reads its latest interim position paper on the topic, âit is WHOâs position that national authorities and conveyance operators should not introduce requirements of proof of COVID-19 vaccination for international travel as a condition for departure or entryâ. According to the paper, âthere are still critical unknowns regarding the efficacy of vaccination in reducing transmissionâ.
This doesnât mean that the WHO is not working on resolving such unknowns. On the contrary, it has launched an ad hoc â[Smart Vaccination Certificate Working Group](https://www.who.int/groups/smart-vaccination-certificate-working-group)â, with the aim of developing specifications for an open and interoperable standard of vaccine certification, together with a framework for its recommended governance.
## **Europe: waiting for the** â**Digital Green Passâ, a plethora of local solutions**
In Europe, certain countries have consistently pushed for the creation of a âvaccineâ or âimmunity passportâ over the last months â to âallow citizens to visit restaurants, conferences, music festivals and sports eventsâ ([Denmark](https://www.dw.com/en/coronavirus-digest-denmark-plans-covid-vaccination-passport/a-56436606)), âto travel abroad on holiday or to meet a loved oneâ ([Sweden](https://www.thelocal.se/20210204/sweden-to-introduce-digital-vaccine-passport/)), or simply to revive summer tourism ([Spain](https://www.reuters.com/article/us-health-coronavirus-spain-tourism-idUSKBN2AG2CW) and [Greece](https://www.schengenvisainfo.com/news/greece-urges-eu-to-create-vaccination-certificate-to-facilitate-travel/)). Others, however, have shown skepticism ([France](https://www.thelocal.fr/20210217/is-france-likely-to-introduce-a-vaccine-passport-for-travel/), [Germany](https://www.healthcareitnews.com/news/emea/european-leaders-debate-eu-wide-vaccine-passports)), if not outright rejection of the idea ([Belgium](https://twitter.com/Sophie_Wilmes/status/1366380299995795458), [Romania](https://www.euractiv.com/section/coronavirus/news/romania-rejects-divisive-greek-proposal-for-vaccine-certificate/), [Serbia](https://www.aa.com.tr/en/europe/vaccine-passport-idea-in-eu-shameful-serbia/2159298)).
European institutions [struggled](https://www.dw.com/en/coronavirus-eu-leaders-consider-vaccine-passports/a-56682684) to reconcile the opposing views among its Member States, before reaching, on March 1st, an agreement on a so-called âDigital Green Passâ detailing, [wrote](https://twitter.com/vonderleyen/status/1366346729289904128) EU Commission President Ursula von der Leyen, âproof that a person has been vaccinated, results of tests for those who couldnât get a vaccine yetâ, and âinfo on COVID19 recoveryâ.
On March 17th, the EU Commission also [highlighted](https://ec.europa.eu/commission/presscorner/detail/en/ip_21_1181) some other key elements of the âdigital green passâ, meant to âfacilitate safe free movement inside the EUâ: it will be available free of charge, issued both in paper and in a digital form, and contain a QR code with âkey informationâ and a digital signature to ascertain its authenticity. The Commission will also âbuild a gateway and support Member States to develop software that authorities can use to verify all certificate signatures across the EUâ. A â[trust framework](https://ec.europa.eu/health/sites/health/files/ehealth/docs/trust-framework_interoperability_certificates_en.pdf)â for the interoperability of health certificates has been introduced by the eHealth Network, to be implemented by Member States â even though some ([Ireland](https://www.dw.com/en/irish-foreign-minister-urges-caution-with-eu-vaccine-passport-plans/a-56903488), for example) seem reluctant.
According to Commissioner for Justice, Didier Reynders, the pass âwill not be a pre-condition to free movement and it will not discriminate in any wayâ. To ensure this will actually be so, the Commission decided to provide the certificate to both vaccinated and non-vaccinated individuals, and to grant the same rights to all pass holders. Presented as a temporary measure, the pass will allegedly include âonly essential information and secure personal dataâ, namely âname, date of birth, date of issuance, relevant information about vaccine/test/recovery and a unique identifier of the certificateâ.
The design of the infrastructure and tools realizing this common endeavor is supposed to be finalized over the next three months. But in the meantime, some states decided to pave their own way forward.
For example, since May 2020, Estonia has been testing (together with tech startups Transferwise and Bolt) a [digital immunity passport](https://www.reuters.com/article/health-coronavirus-estonia-digital-idUSKBN22W0GE)for workplaces and, since October, has been collaborating with the World Health Organization towards the creation of a digitally enhanced âInternational Certificate of Vaccinationâ or âsmart yellow cardâ. Through the use of a âtemporary QR-code generated after digital authenticationâ, it would âhelp strengthen the effectiveness of the COVAX initiativeâ, and include the development of âa global framework for health data interoperabilityâ.
Iceland has also [started](https://www.government.is/diplomatic-missions/embassy-article/2021/01/25/COVID-19-Digital-vaccine-certificates/) issuing its own vaccine certificates for the around 4,500 individuals who have already received the second vaccination dose. The aim, as stated on the Icelandic governmentâs website, âis to facilitate the movement of people between countries, so that individuals can present a vaccine certificate at the border and be exempt from COVID-19 border measuresâ.
Similarly, the upper Bavarian district of Altötting also [released](https://www.heise.de/news/Bayerischer-Landkreis-vergibt-ersten-digitalen-Corona-Impfpass-5034020.html) its first vaccination card. Equipped with a QR code, it can be scanned so that relevant data can be transferred and kept on each individualâs smartphone â and on each smartphone only, state the authorities, allegedly guaranteeing a fully privacy-preserving solution.
This is all the more significant given that German Federal authorities have initially been much more cautious in respect to the adoption of vaccine certificates. In fact, the district of Altötting claims to have operated and implemented its solution âcompletely independentlyâ of the Federal Ministry of Health. Germany has since reversed course, with the Ministry [awarding](https://www.spiegel.de/netzwelt/gadgets/ubirch-und-ibm-erhalten-zuschlag-fuer-deutschen-digitalen-impfnachweis-a-9f26439b-8fd8-4118-9221-eb8844946c69) a contract to develop a nationwide digital vaccine certification infrastructure to both the Cologne-based company, Ubirch â which proposes a solution based on QR codes and a blockchain â and IBM. But, when coupled with other solutions devised at the national level, through state-maintained patient records databases (e.g., in [Finland](https://yle.fi/uutiset/osasto/news/finland_planning_to_introduce_coronavirus_vaccine_certificate/11775698)) and/or in conjunction with private entities (as in [Denmark](https://www.dw.com/en/coronavirus-digest-denmark-plans-covid-vaccination-passport/a-56436606)), this local example clearly signals that solving issues of interoperability will be key to a successful implementation of a shared digital âvaccine certificateâ solution, both in and outside Europe.
And yet, even without these shared requirements, Greece is already in talks to agree agreements on travel deals with specific countries: for example, [with Cyprus and Israel](https://travelweekly.co.uk/news/air/greece-cyprus-and-israel-agree-vaccine-travel-deals) â in which a âgreen passâ has already been [issued](https://www.jpost.com/israel-news/everything-you-need-to-know-about-israels-green-passport-program-659437) to give exclusive access to malls, gyms, hotels, concerts, and other premises and venues to vaccinated individuals (âWith the green pass, doors just open for youâ, reads the Israeli governmentâs [motto](https://apnews.com/article/coronavirus-vaccination-passports-7a8ce11ce37c309d97969ab71df26e62)); and [with the UK](https://www.theguardian.com/world/2021/feb/24/greece-in-technical-talks-with-the-uk-to-allow-holidays-with-vaccine-passports), where a solution involving biometric technologies is being developed by biometric authentication and identity management companies [iProov and Mvine](https://www.iproov.com/blog/delivering-first-covid-19-antibody-test-status-digital-passport), to be potentially implemented to even access pubs, restaurants, theatres, and sports events.
## **Outside Europe, solutions and experiments multiply**
Outside of the European context, the debate is similar. In Asia, China has arguably been the first country to call for a shared global mechanism based on QR codes to recognize health certificates in a [speech](https://edition.cnn.com/2020/11/23/asia/china-xi-qr-code-coronavirus-intl-hnk/index.html) by its leader, Xi Jinping, at a G20 meeting in November 2020.
More recently, members of the Association of Southeast Asian Nations have also [declared](https://asia.nikkei.com/Economy/ASEAN-eyes-digital-vaccine-certificate-for-post-COVID-travel) that they are considering the possibility of issuing a shared vaccination certificate âespecially to speed up the opening up of sectors most hard hit, such as the tourism industryâ, said Azmin Ali, Malaysia's minister of international trade and industry. Malaysia is also trialing a blockchain-based health passport, âImmuniteeâ, together with Singapore, and in collaboration with Affinidi, a global investment firm headquartered in the city-state. Information contained in the passport will only be accessible through a QR code, but will be relevant not only to government officials, [writes](https://www.mobihealthnews.com/news/apac/malaysia-s-first-health-passport-immunitee-formally-accepted-singapore) MobiHealthNews, but also to âhealthcare facilities, immigration systems, hotels or universitiesâ.
A similar joint initiative has been hypothesized by the countries of the Gulf Cooperation Council, according to which a âdigital passportâ may result from an evolution of UAEâs Al Hosni mobile app. âA unified GCC health passport project has been envisaged to identify those who took Covid-19 vaccinations,â a top Omani official has stated, [according](https://www.khaleejtimes.com/news/gcc-covid-passport-would-store-vaccine-travel-eligibility-info) to the Khaleej Times.
In the United States, the possibility of a vaccine certificate is part of the Biden administrationâs COVID-19 response plan. The plan [affirms](https://www.whitehouse.gov/wp-content/uploads/2021/01/National-Strategy-for-the-COVID-19-Response-and-Pandemic-Preparedness.pdf) that âthe Secretary of State, the Secretary of HHS, and the Secretary of Homeland Security (âŠ), in coordination with any relevant international organizationsâ can be asked to âassess the feasibility of linking COVID-19 vaccination to International Certificates of Vaccination or Prophylaxis (ICVP) and producing electronic versions of ICVPsâ. The Hawaii islands are already [creating](https://www.forbes.com/sites/suzannerowankelleher/2021/02/19/hawaii-is-creating-a-vaccine-passport-that-lets-you-skip-the-10-day-quarantine/?sh=3e21c8334302) their own digital vaccine passport, however, allowing incoming travelers to avoid the otherwise mandatory 10-day quarantine period.
## **The push from the flight industry (and tech companies)**
In South America, Chile has been at the forefront of [experimenting](https://www.thelancet.com/journals/lancet/article/PIIS0140-6736\(20\)31096-5/fulltext) with ârelease certificatesâ issued to those who recovered from COVID-19, thus allowing them to âserve their communityâ (e.g., helping neighbors or elderly parents) with little to no risk of infecting others, the Lancet reports. The plan, which was met with controversy, is said to have been inspired by policies in Hong Kong and South Korea, and would not mean that beneficiaries could sidestep basic COVID-19 precautions. Also, the certificate would expire after three months.
Experiments with âvaccine passportsâ predominantly concern the flight and travel industry, with different airlines deploying different solutions. Air France, for example, is about to [trial](https://www.ledgerinsights.com/air-france-to-pilot-iccs-blockchain-covid-19-credentials-app/) the International Chamber of Commerceâs AOK pass blockchain-based solution. Meanwhile, at the beginning of February 2021, it was reported that British Airways was about to begin accepting digital passports using the VeriFLY service and app for flights between the UK and the US. Trials started in November 2020 and even provided faster, separate check-in areas for customers who chose to adopt the digital passport solution, for which a selfie must be submitted. [According to Simple Flying](https://simpleflying.com/british-airways-health-passports/), customer satisfaction ratings for the service stand at â4.8 out of fiveâ.
Another travel app, SimplyGo, has been trialed on flights between the UAE and Munich, Germany, and from Tallinn, Estonia, to the UAE via Frankfurt. The app was developed by ION Access & Health, an alliance of international health and technology companies Nortal, Ottonova, InHealth, and Daman. It was used in cooperation with technology provider SITA, in a trial to collect the COVID-19 status of passengers and allow only those with a negative test result to board.
Several different solutions have been proposed to achieve similar goals. The International Air Transport Associationâs (IATA) â[Travel Pass](https://www.iata.org/contentassets/2b02a4f452384b1fbae0a4c40e8a5d0c/travel-pass-faqs.pdf)â is an app that can be downloaded to a passengerâs smartphone. Customers have to take a selfie and complete a âliveness testâ (âi.e., move their head, close their eyes in front of the camera as instructedâ), among other requirements. Once the app verifies that the passport data belongs to the person in front of the phoneâs camera, âfacial recognition can be used to swiftly processâ the verified data âat key touch points at the airport without the need to physically exchange passports and boarding passesâ.
The â[Commons Project](https://thecommonsproject.org/)ââa self-defined ânon-profit public trust established with support from the Rockefeller Foundation to build global digital services and platforms for the common goodââis also [developing](http://\(https/static1.squarespace.com/static/5ed685211872ca0609188980/t/5fc90d42ae28fe4947430767/1607011651080/New+CommonTrust+Network+members+and+roll+out+20201124.pdf) a solution for a âsecure and verifiable way to documentâ the âhealth statusâ of travelers, together with the World Economic Forum (WEF). Called âCommonPassâ, it aims to become a âglobally-interoperable platformâ for passengers to document their COVID-19 status (âhealth declarations / PCR tests / vaccinationsâ), while at the same time storing their health records securely on their phones (through Apple Health on iOS, and CommonHealth on Android).
However, in the [FAQs](https://commonpass.org/faqs), the project draws a clear distinction between a pass and an âimmunity passportâ: âCommonPass is not an immunity passportâ, it states, âand cannot be used to prove that a person is immune to COVID-19. CommonPass can only verify that a person has recently received a test result, or has been vaccinated, for COVID-19. Neither of these is guarantee of a negative or immune statusâ.
Airlines such as JetBlue, Lufthansa, Swiss International Airlines, United Airlines, and Virgin Atlantic are adopting the solution, and the roll-out for passengers departing from New York, Boston, London, and Hong Kong, is set to start in December.
Technology companies are also deeply involved in the development of such solutions. For example, Microsoft, Oracle, and Salesforce are part of a broader coalition of tech companies, healthcare organizations, nonprofits, and academia called â[The Vaccine Credential Initiative](https://vaccinationcredential.org/)[â](https://vaccinationcredential.org/) (VCI). It aims to design an open-source standard for vaccination records, so that consumers can âconveniently access, store, and shareâ them. The VCI is working in conjunction with the âCommons Projectâ and the WEF towards that end.
IBM is another tech company that is deeply involved in the healthcare sector. It is also developing a digital health platform called the â[IBM Digital Health Pass](https://www.ibm.com/products/digital-health-pass)â. It is based on blockchain technology and it is âdesigned to incorporate multiple data sources as specified by each organization â such as test results and onsite temperature scans â which can allow individuals to share their health pass through an encrypted digital wallet on their smartphoneâ. This would result in âa smart way to return to societyâ, according to IBM.
The multiplicity of solutions offered by the air transport and tech industries already led some startups to create a one-stop solution through which to manage all vaccine passport-related credentials. Given that different countries and companies might end up requiring the download of multiple apps to prove a passengerâs COVID-19 status for a single trip, digital identity company Airside Mobile has decided to partner with Vision Box, a Portuguese biometrics company, to provide a certifications manager app that can host not only health-related records but also passport, driverâs license, and other information, all through âend-to-end biometric source verificationâ. âTravelers download the Airside app, identify with us and provide a one-time privacy consent, and then Vision-Box picks up the baton,â says Airside Mobile CEO, Amena Ali, quoted in [Forbes](https://www.forbes.com/sites/suzannerowankelleher/2021/02/25/this-one-stop-digital-id-app-wants-to-cut-through-the-vaccine-passport-noise/?sh=1d5cb1a5220e).
## **Automated decision-making: too early to look into the specifics**
Such a diverse set of proposed solutions to the problem of having a workable and interoperable framework and infrastructure for COVID-19 vaccine certifications makes it difficult to assess how each of them actually works and, therefore, whether and how they could be infringing on fundamental rights, privacy, and security. What kind of shared data infrastructure will be needed to implement a globally interoperable network of digital vaccine certifications? Could it provide leeway for âfunction creepâ (e.g., being deployed outside its scope)? Will it be secure and fraud-proof (this is already [an issue](https://www.haaretz.com/israel-news/tech-news/.premium-anyone-can-still-fake-israel-s-coronavirus-vaccination-certification-1.9549889) in Israel)? And what role will be played by the private sector in realizing and managing it? It is simply too early to tell.
Also, and typically for socio-technical automated decision-making (ADM) systems, the urgency with which digital vaccination certificates are being proposed and announced has been usually not met with a corresponding level of transparency and detail over their functionalities. Most digital vaccine certification tools are still in their early or experimental stages, while othersâsuch as the EUâs âdigital green passââhavenât yet been fully designed, at the time of writing. We know that some countries (e.g., the [UK](https://www.thetimes.co.uk/article/nhs-app-to-be-converted-for-vaccine-passports-r0xx0mflp), [Switzerland](https://www.thelocal.ch/20210222/a-ticket-back-to-normality-swiss-support-for-vaccination-pass-grows/), and [Bahrain](https://www.mobihealthnews.com/news/emea/bahrain-launches-digital-covid-19-vaccine-passport)) plan to add this functionality to already deployed contact tracing COVID-19 apps. And we also know that many involve blockchain and biometric technologies. But we donât know much else at this point.
Much is yet to come, and rather than discussing detailed ADM systems, the international discourse around vaccine passports and certificates has mostly focused on more general issues. For example, whether they can be deployed ethically and effectively, whether they make scientific sense, and what kind of activities they would allow in their quest to give people a renewed sense of agency and autonomy, even though the pandemic shows no signs of slowing down.
As has [constantly been the case](https://automatingsociety.algorithmwatch.org/) for the deployment of other ADM systems in Europe (and beyond), including in the context of the [pandemic](https://algorithmwatch.org/en/automating-society-2020-covid19/), urgency has also been exploited to deploy technological solutions for COVID-19 vaccine certification in the absence of a meaningful democratic debate around their actual merits and opportunity. In Israel, where a âgreen passâ has already been issued, this resulted in protests against âvaccine coercionâ and the privileges of a âvaccinated classâ in the [streets of Tel Aviv](https://www.jpost.com/israel-news/protesters-demonstrate-against-vaccine-coercion-green-passports-in-tel-aviv-660106).
## **Pros and cons of vaccine certificates**
And yet, vaccine certificatesâat least theoreticallyâpresent both opportunities and risks that are being investigated by civil society actors (e.g., the [Ada Lovelace Institute](https://www.adalovelaceinstitute.org/summary/covid-19-vaccine-passports/)), research institutions (e.g., the [Royal Society](https://royalsociety.org/news/2021/02/12-challenges-for-vaccine-passports/)), [academia](https://socialsciences.exeter.ac.uk/media/universityofexeter/collegeofsocialsciencesandinternationalstudies/lawimages/research/Policy_brief_-_Digital_Health_Passports_COVID-19_-_Beduschi.pdf), and in several media analyses and reports.
The opportunities offered by the adoption of an interoperable digital vaccine certification scheme are more clearly expressed by their proponents. Among the benefits they list: 1) an instrument to safely reopen the economy; 2) a way to help individuals more securely return to ânormal lifeâ, thus showing a way out of the pandemic restrictions affecting individual autonomy and agency without compromising collective public health; 3) faster, more efficient, âseamlessâ and mostly touch-less security checks for travelers, thus minimizing the risks of infection while traveling; 4) a tool to more generally reduce COVID-19 transmission within the population.
An interesting and unique addition comes from the Chilean experiment whereby ârelease certificatesâ are offered to those who have recovered from the disease. This solution has been touted as an instrument to enhance care, empathy, and human connection. This certification scheme would link to the idea of âserving the communityâ and help combat feelings of isolation and loneliness during the pandemic.
Vaccine passports proponents argue all of this could be realized without infringing on individual privacy and without the risk of compromising a userâs security. Customers will decide who to share their vaccine and COVID-19-related health information with and for how long, and most solutions claim that digital certification data will only be kept on the userâs phone.
Risks abound, however, and they involve scientific, ethical, and technological challenges.
Scientific challenges relate to the fact that, while vaccines demonstrably work in protecting a vaccinated individual from catching the COVID-19 disease, there is currently no scientific consensus around their capacity to reduce its transmission, preventing a vaccinated individual from infecting others. Also, as COVID-19 variants keep multiplying and spreading, some have been shown to potentially reduce vaccine efficacy. Therefore, a vaccine certificate should be flexible and allow for constant updates and fine-tuning so that a false sense of security provided by an outdated vaccine can be avoided.
Other critical scientific unknowns concern how long the protection granted by the vaccine will last, and whether it also prevents asymptomatic infection â both crucial elements for any plan that implies a âreturn to normalâ on the basis of a digital vaccine certificate scheme. All of this leads the German Ethics Council to [conclude](https://www.ethikrat.org/fileadmin/Publikationen/Ad-hoc-Empfehlungen/englisch/recommendation-special-rules-for-vaccinated-people.pdf) that âat this point in time there should be no individual withdrawal of state restrictions on civil liberties for vaccinated persons, because their infectiousness cannot be reliably estimated as yet.â
These scientific challenges also bear behavioral consequences. The Ethics Council, for example, notes that âfor as long as not all people can get vaccinated, part of the population would perceive as unjust an individual withdrawal of state restrictions on civil liberties for vaccinated people onlyâ. This could also lead to reduced solidarity and willingness to comply with social distancing rules, ultimately undermining their effectiveness. Problematic behavioral incentives could go as far as individuals actively seeking out infection, âespeciallyâ, notes Georgetown Universityâs Alexandra Phelan on [the Lancet](https://www.thelancet.com/pdfs/journals/lancet/PIIS0140-6736\(20\)31034-5.pdf\)), âpeople who are unable to afford a period of workforce exclusion, compounding existing gender, race, ethnicity, and nationality inequitiesâ.
Ethical challenges have also been explored in detail, and are far from resolved. On Scientific American, Nicole Hassoun and Anders Herlitz, [argue](https://www.scientificamerican.com/article/how-to-make-immunity-passports-more-ethical/) that the benefits from vaccination or immunity passports, âwill be dispersed unequallyâ, exacerbating existing inequalities. Furthermore, an editorial in the Lancet [argues](https://www.thelancet.com/journals/laninf/article/PIIS1473-3099\(20\)30766-0/fulltext): âIf immunity passports were introduced, marginalised groups would be subject to more scrutiny because of existing inequities and racism (eg, police checks for lockdown regulations) and would be less likely to access testing (and establish immunity) than non-marginalised groups would beâ.
Also, given that vaccine shots are being disproportionately provided to rich countries â it is estimated that â9 out of 10 people living in the poorest countries in the world may not receive the vaccine this yearâ, write Claire Loughnan and Sara Dehm on [The Conversation](https://theconversation.com/a-covid-vaccine-passport-may-further-disadvantage-refugees-and-asylum-seekers-155287) â refugees and asylum-seekers are likely to be more severely affected.
However, this has not just to do with unequal availability of vaccination shots: certain individuals might not be able to receive a shot even if it is available. For example, for medical reasons (pregnant women, people with certain allergies, etc.). It can be argued that depriving them of the privileges afforded to the vaccinated would be unethical. This has led Hassoun and Herlitz to argue that âin order for them to be ethicalâ, immunity passports âmust at least include some exceptionsâ. For example, âpeople who cannot access vaccines for health reasons but need to work, attend school, travel and so forth should be able to do so when the benefits exceed the risksâ. Welfare exceptions should also be made. For example, to those who desperately need to go to work âin places that require social interactionâ to support their families.
In addition, if they are not carefully implemented through privacy-preserving technologies, vaccine certificates could also pose privacy risks and even lead to ânormalising health status surveillance by creating long-term infrastructure in response to a time-bounded crisisâ, as the Ada Lovelace Institute wrote in its âRapid Expert Deliberationâ, [published](https://www.adalovelaceinstitute.org/wp-content/uploads/2021/02/COVID-19-vaccine-passports-rapid-expert-deliberation.pdf) in February 2021.
## **Conclusion: clarity and details are urgently needed**
Vaccine certification schemes are being debated worldwide as tools to facilitate the reopening of travel routes and the economy, while at the same time progressively ending the severe limitations of rights and freedoms put in place during the pandemic.
Several different solutions have been envisioned, but most have not been described in detail yet, and no global consensus has emerged around any of them. Confusion has ensued in many instances, both in terminology and proposed ADM systems.
Interoperability and infrastructural issues have yet to be solved. At the same time, this raises a complex plethora of considerations that highlight both the promises and the risks of adopting vaccine certificates.
Even though several systems are already being trialed, any meaningful democratic debate is missing, and transparency is still mostly lacking. And yet, in order to actually judge the broader feasibility and opportunity of realizing vaccine certificates for society, we will need to see the specifics of the plans that are being devised, especially at the international level.
***
[\[1\]](https://algorithmwatch.org/en/digital-vaccine-certificates-analysis-march-2021/#_ftnref1) A certain confusion ensues, at times equating vaccine and immunity passports (which may include positive COVID-19 antibody test results as well), or certificates and passports (with the latter term more strongly suggesting a mandatory prerequisite for traveling, rather than mere proof of vaccination). |
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