Version of 13 August 2021

The Australian Privacy Foundation (APF) is the country’s leading privacy advocacy organisation. Our COVID-19 Surveillance Policy Statement is a foundation of this Digital COVID-19 Vaccine Passport Position Statement.1

Part 1

An Australian digital COVID-19 Vaccine Passport is not useful for the introduction of proof of domestic vaccination measures.2 Emerging evidence has shown that while vaccines are effective in lowering the risk of severe illness, they do not prevent individuals from spreading the virus itself. This concern is particularly relevant in the context of new and emerging variants of the virus.1

Incorrect information stored on COVID digital certificates combine with function creep, growing fraud concerns, and the Australian digital divide to undermine APF trust in COVID-19 Vaccine Passports, as articulated in Part 2.

Mask-wearing, good hygiene practices and social distancing measures, in addition to vaccination itself, are essential if Australians are to work our way out of the COVID-19 pandemic.

Part 2

1. Context

Ongoing quarantine controls, known as ‘lockdowns’, have been mandated by Australian States and Territories as a response to the growing threat of the COVID-19 pandemic. The current variant, Delta, is more infectious and resistant to vaccines than earlier variants. The plausibility of exponential COVID variants emerging over time indicates these will be characterised by a higher reproduction ratio, proving more dangerous to peoples’ health and wellbeing than Delta.

The Australian Immunisation Register (AIR), which records an individual’s COVID vaccine status, is available online through a myGov account and the Express Medicare app; the digital records can be stored on a third party application installed on person’s smart phone, but no rights to cross state and territorial borders or avoid lockdowns are linked to these records at present.3-4 Current community, parliamentary and health authority debate over formal rights linked to a government-issued Digital COVID-19 Vaccine Passport (the Passport) for application for everyday life during lockdown, and as a condition of employment for people in some businesses and industry sectors, has prompted this statement.3-4

1.1. Direct Benefit of Vaccination

The direct benefit of COVID-19 vaccines in preventing infection generally ranges from higher than 80% to more than 90%. People who are fully vaccinated against COVID-19 can still acquire the virus and spread it to others despite the substantial control of this risk. Immunisation does not completely control the spread of COVID-19.1-2 Also, emerging evidence indicates that full immunisation against the virus may last around 8 months, so information stored in the Passport might prove useless after that time unless an individual has received regular booster vaccinations and these are recorded on AIR.1 Reliance on the Passport to provide information about the spread of COVID-19 is therefore quite troubling.

1.2. Unequal Access to Vaccine

Australians do not have equal access to COVID-19 vaccines. For example, many shift-workers, casual and contract workers do not benefit from terms and conditions of employment that facilitate time taken off for acquiring a vaccine. Should Australia depend on a digital passport system for avoiding lockdown, these people will be inherently disadvantaged and their participation in community life may be constrained.

1.3 The Digital Divide

Australia’s digital divide is substantial and growing over time.8 More than 2.5 million Australians have no access to the Internet and so are excluded from all digital tools, while many mobile phone end-users do not own devices capable of functions other than telephony and basic text message services. These Australians will be unable to access digital COVID vaccination certificates or the Passport at all.

2. Specific APF Concerns

2.1 Fake Passports

The market for fake COVID-19 vaccine passports is booming.6 In recognition of this fact, a QR code will need to be added to the federal government’s COVID Digital Certificate for validation as a Passport.3 Function creep is already emerging in discussions of the Passport. The evidence shows that time and again, governments have used national digital systems “that have suffered from scope and function creep and have used data retrospectively in ways that were never intended”.9 Evidence suggests additional linkages will be added to the Digital Certificate Passport, adding to the behemoth of information currently held by the federal government about Australian citizens. Australians have no legally enforceable right to privacy. We therefore question the capacity of the Passport to maintain our civil liberties.

2.2 Flawed AIR Database

The AIR database, which records peoples’ vaccine status, informs an individual’s COVID Digital Certificate. But AIR records are not reliable. Some errors in the records mean that people cannot receive a COVID vaccination because the AIR show this has already happened, while other errors mean vaccinations are not recorded at all.7 This puts all AIR data in doubt. The poor quality of information stored in the government database means that records stored on the Passport are incorrect, forgeries notwithstanding. Logically, these mistakes erode any confidence people or businesses may have in Passport accuracy.

2.3 Secure Personal Devices & the Digital Index

Recent research findings measuring Australia’s digital inclusion index highlight significant barriers to digital ability, especially in technological skills domains, across the population. Mobile phone and tablet only endusers on the Internet, more than 19% of people, score well below the national average in digital ability regardless of their level of engagement with services and applications.8 Working with Internet privacy and security tools on personal devices is a major technical challenge for many of these individuals. When these figures are added to the approximately 10% of people with no access to the Internet at all found in the inclusion study, almost a third of Australians, many of whom are already considered members of vulnerable groups in society, will find a digital Passport (and their inability to use one) to be a direct impediment to their daily lives.8

3. Conclusion

This position statement is not intended to discourage Australians from COVID-19 vaccination. Combined with mask-wearing, good hygiene practices and social distancing measures, vaccination is a core means of working our way out of lockdown, containing, and finally eliminating the health and wellbeing costs currently linked to the COVID-19 pandemic. Rather, we feel federal government health authorities can do better than apply a poor-quality digital Passport Band-Aid to the novel pandemic as Australia steers its way out of this crisis.

The APF would be glad to help authorities develop appropriate responses to the issues discussed in this statement.


  1. Australian Privacy Foundation (APF) COVID-19 Surveillance; Policy Statement, 12 May 2021.
  2. Koer, N. & Baylis, F. Nope. A Covid-19 Travel Pass isn’t just like the Yellow Card, the Hastings Centre. 13 May 2021.
  3. McDonald, K. COVID-19 Digital Certificate can be added to Apple Wallet and Google Pay, Pulse IT. August 3, 2021. +eNewsletters&utm_campaign=b8c2445f41- PulseIT_eNews_05_08_2021&utm_medium=email&utm_term=0_b39f06f53f-b8c2445f41- 413218536&goal=0_b39f06f53f-b8c2445f41-413218536&mc_cid=b8c2445f41&mc_eid=8fccaf7520
  4. Ziffer, D. Australians have a ‘vaccine passport’ to avoid border closures. We’re not using it. Yet, ABC News, 28 June 2021.
  5. Hon. Craig Lundy MP. No Domestic COVID Vaccine Passports Bill 202: A Bill for an Act to protect the right of Australians to make their own health decisions in relation to COVID vaccination, and for related purposes. Presented and read a first time 21 June 2021, second reading moved 21 June 2021. The Parliament of the Commonwealth of Australia, HOUSE OF REPRESENTATIVES. 6724
  6. Bacchi, U. Booming market for fake COVID-19 vaccine passports sparks alarm, Rueters. 9 April 2021.
  7. Knaus, C. “I am still waiting”: some Australians turned away from getting Covid vaccine because of register errors, The Guardian. 3 August 2021.
  8. Thomas, J. & Barraket, J. et al. Measuring Australia’s digital divide. The Australian Digital Inclusion Index 2020.Telstra.
  9. Michael, K. & Abbas, R. The coronavirus contact tracing app won’t log your location, but it will reveal who you hang out with, The Conversation. April 16 2020. 136387