# EUROPEAN VACCINATION CARD (EVC) - PREREQUISITES

## Operational

The implementing Member State must be able to identify the health professionals or the health structures that are allowed to perform vaccinations, and therefore to deliver EVCs.

These health professionals must have access to an EHR application where master records can be securely kept.

The Member State must have a digital signature operator belonging to the GDHCN.

## Legal and ethical

Each entity keeping the master records must be entitled to keep them for the lifetime of the regarded persons, regardless of whether these persons had still interactions with the entity. This may be an exception to the MS general rule regarding the archiving of health records, stating that vaccination master records should be kept until an age where death is certain. Such exceptions already exist for blood derived products or received radiations.

Yet, these long-term records, used only when investigating an abnormal situation, do not need to be kept into an active database. Health facilities generally keep intermediate records, accessible only from a dedicated archive management interface. 

## Political

### Opposition to the principle of the EVC

Due to the Digital Covid Certificate precedent, there is a vocal minority opposed to the EVC, ignoring all the differences between a voluntary, home-based personal health record and a mandatory document driving rights under a centralized control. This minority should not be influential enough to block the execution of the project.

### Reluctance of the EHR suppliers

There could also be an opposition from the EHR suppliers, not willing to face the challenges relating to the implementation.

## Technical

A reliable communication infrastructure is required between the issuing EHR applications and the signature servers.

# Filling the gaps

*Meeting the prerequisites is generally a long-term action that goes far beyond the scope of the implementation plans. This section presents workarounds that could help to initiate the implementation despite the lack of some prerequisites, although background effort will be required to catch up.*

## Operational

As a transient solution, the health professionals or structures delivering EVCs can be registered within the signature infrastructure without being backed by a national identification scheme.

Also, the signature infrastructure can be prepared in compliance with the GDHCN procedures while the formal application process is still ongoing.

## Legal and ethical

Health structures are assumed to keep records for their patients for long periods, typically 10 years after their last visit. This gives some time to arrange for the lifetime retention of master records.

## Political

The crucial differences between a vaccination card and a vaccination certificate or passport have to be clearly stated.

A standalone public solution to import and deliver EVCs can be proposed as a first step and an incitement for EHRs suppliers to integrate the feature. This is particularly relevant if there is already a centralizing infrastructure for health records.

## Technical

Although this makes the management and securing of keys more complex, the signature servers can be decentralised to accommodate for connectivity issues.