Guidance on Vaccine Passport and Vaccination Policies

Sep 17, 2021
Friday, September 17 Update
Guidance on Vaccine Passport and
Vaccination Policies
At the OMA, we have received several questions regarding proof of vaccination and museums. Throughout this rapidly evolving situation, we've collected and shared information as it was released. Recent editions of ONmuseums and webinars on reopening are available on our website HERE and HERE. Our webinar with Public Services Health and Safety Association on how to reopen museums safely is available HERE

The information in this eNews is gathered for general reference. 
Ultimately, the Ministry of Health is responsible for all proof of vaccination policy and associated guidance, and we recommend that you seek official confirmation. 

An official Ministry of Health resource, Questions and Answers (issued Tuesday, September 14) is available for information HERE. 
Read the Ministry of Health's "Questions and Answers" Document HERE
From discussions with our Ministry of Heritage, Sport, Tourism and Culture Industries colleagues, we understand that proof of vaccination for patrons is not required for museums and galleries. As detailed in the government’s announcement from September 1st, Ontario to Require Proof of Vaccination in Select Settings, museums and galleries are not listed as one of the mandatory settings where patrons must be fully vaccinated to access the facilities:
  • Indoor areas of restaurants, bars, and other food and drink establishments
  • without dance facilities
  • Indoor and outdoor areas of food or drink establishments with dance facilities,
  • including nightclubs, restoclubs, and other similar establishments
  • Indoor areas of meeting and event spaces with limited exceptions
  • Indoor areas of facilities used for sports and recreational fitness activities,
  • including waterparks, and personal physical fitness training with limited exemptions: Includes gyms, fitness/sporting/recreational facilities, pools, leagues, sporting events, waterparks, and indoor areas of facilities where spectators watch events
  • Indoor areas of casinos, bingo halls, and other gaming establishments
  • Indoor areas of concert venues, theatres, and cinemas
  • Indoor areas of bathhouses, sex clubs and strip clubs
  • Indoor areas of horse racing tracks, car racing tracks and other similar venues
  • Indoor areas where commercial film and TV productions take place with studio audiences
(O. Reg. 364/20 Rules for Areas at Step 3 and at the Roadmap Exit Step)

Indoor meeting and event spaces within museums and galleries will require proof of vaccination for all patrons attending the meeting or event, subject to limited exceptions. However, proof of vaccination for attendees is not required if the space is rented out for:  

  • a day camp or overnight camp for children described in section 19 of Schedule 2 (O. Reg. 364/20 Rules for Areas at Step 3 and at the Roadmap Exit Step);  
  • to a provider of child care within the meaning of the Child Care and Early Years Act, 2014
  • for the purpose of the provision of social services;  
  • for the purpose of delivering or supporting the delivery of court services;  
  • for operations by or on behalf of a government; or  
  • for the purpose of delivering or supporting the delivery of government services

We strongly recommend that you check with the Ministry of Health regarding any proof of vaccination policy. 

  • Read the Ministry of Health's Guidance to Support Proof of Vaccination Policy HERE.
  • Read the Ministry of Health's Questions and Answers on Vaccination Policy document HERE.
  • Read Ontario Regulation 364/20 (under the Reopening Ontario (A Flexible Response to COVID-19) Act, 2020) HERE. 
Questions and Answers
From the Ministry of Health's "Questions and Answers" document, please find a few example questions and answers below. 
Read the Ministry of Health's "Questions and Answers" Document HERE
Question 8.
Can I choose to have my business require individuals to show proof of vaccination at the point of entry to gain access?

Can my restaurant require proof of vaccination for the outdoor patio?
"While only specified businesses or organizations are legally required to ask their patrons for proof of identification and proof of being fully vaccinated against COVID-19, O. Reg. 364/20 and the Ministry’s Guidance do not prevent other businesses or organizations from establishing a vaccination policy.

O. Reg. 364/20 and the Ministry’s Guidance also do not prevent the specified businesses or organizations from establishing additional policies or requirements pertaining to their patrons. This could include businesses or organizations that want to implement policies or requirements for part of their business (e.g., entire restaurant including the outdoor patio). Businesses or organizations considering creating their own additional policies or requirements may wish to consult a lawyer.

However, all Ontarians, regardless of their vaccination status, should continue to have access to necessary medical care, food from grocery stores, and basic medical supplies."
Question 14.
Are businesses and organizations able to keep or retain any information related to proof of vaccination?
"As per O. Reg. 364/20, a business or an organization shall not retain any information
provided by a patron as it relates to proof of vaccination."
Question 10.
Are businesses and organizations able to implement workplace vaccination policies for employees?
"Businesses and organizations can choose to implement workplace vaccination
policies. They may also choose to leverage provincial guidance and technology to support implementation.

Businesses and organizations may wish to consult their legal counsel before
Read the Ministry of Health's "Questions and Answers" Document HERE
For any questions or comments, please contact Marie Lalonde, Executive Director, ( or by phone at: 416-348-8672 or toll free, 1 866 662 8672. 

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