COVID vaccination

27 January 2022

Dear 

ATISN 15759 – Vaccination of children

Thank you for your request to the Welsh Government for information under the Freedom of Information Act (2000) received on 6 December 2021. Your request is outlined below:

1) Your representation in the consultation about and the approval of the COVID-19 vaccine roll-out, specifically to children 

a)    Please send a copy of your job description as well as details of all your responsibilities to the Welsh Government and to the people of Wales in your role as Chief Medical Officer.

b)    Please disclose whether you are personally and /or ultimately responsible for medical advice received by the Welsh Government.

c)    If not, please disclose if there is any other individual who is responsible for medical advice received by the Welsh Government and what are their qualifications?

2) Responsibility for approving the COVID-19 vaccine roll-out to children aged 12-15 in Wales 

a)    Please detail the scientific studies you have relied upon to come to the conclusion to vaccinate children aged 12-15.

b)    Please detail the specific scientific evidence that has prompted you to overrule the JCVI decision not to recommend COVID-19 vaccination for children aged 12-15.

c)    If there is no single individual who is ultimately responsible for advising the Welsh Government on health issues, please disclose how decisions are made - for example, whether there is an advisory body who is responsible for the approval of the COVID-19 vaccine roll out, specifically to children, and whether you are part of this advisory body.

d)    If so, please detail those members, their job titles, their qualifications and if any are currently working with clinical responsibilities.

3) Contractual obligations between the Welsh Government and BioNTech/Pfizer that may have influenced the decisions to promote the roll-out of the COVID-19 vaccine to children

a)    Please detail all and any conflicts of interests of any individual involved in the decision to proceed with vaccinating children aged 12-15 in Wales. 

b)    Please detail all and any conflicts of interest of the Welsh Government with regards to rolling out COVID-19 vaccination programs.

c)    Please send copies of the minutes of any meetings relevant to this decision-making process.

Response

In relation to question 1a, Welsh Government holds this information and has previously been published, see ATISN 13039.

In relation to 1b, we can confirm that the Chief Medical Officer is not ultimately responsible for medical advice received by the Welsh Government.

In relation to 1c, no individual is ultimately responsible for medical advice received by the Welsh Government. To contextualise, decisions taken by the Welsh Government are informed by inputs from by a variety of internal and external stakeholders.  

In relation to 2a, the advice to offer COVID vaccinations to 12-15 year olds was provided on a 4 nation basis by the UK’s Chief Medical Officers after reviewing evidence on the public health benefits of extending vaccination to younger people. 

The link attached provides details of the letter sent by the Chief Medical Officers to UK Health Ministers, and includes the terms of reference and key inputs used in coming to their decision. Universal vaccination of children and young people aged 12 to 15 years against COVID-19 (on GOV.UK)

In relation to 2b, it is important to note that the JCVI was not overruled. The JCVI is constituted with expertise to allow consideration of the health benefits and risks of vaccination and it was not considered within the remit of the Committee to incorporate in-depth considerations on wider societal impacts, including educational benefits. The Committee specifically outlined in their statement on 3 September (JCVI statement on COVID-19 vaccination of children aged 12 to 15 years: 3 September 2021 on GOV.UK) that “government may wish to seek further views on the wider societal and educational impacts from the chief medical officers of the 4 nations, with representation from JCVI in these subsequent discussions”.
 
In relation to 2c, JCVI is a statutory advisory committee. The Committee is constituted for the purpose of advising the Secretary of State on “the provision of vaccination and immunisation services being facilities for the prevention of illness”. Essentially the JCVI operates within an advisory capacity. Ultimately, the Secretary of State for Health and Social Care and Ministers within the devolved nations can decide whether or not to accept this advice and are responsible for making the final decision on their governmental policy. 

In relation to 2d, this information can be found at the link below – Joint Committee on Vaccination and Immunisation (on GOV.UK)

In relation to 3a, there are no conflicts of interest in taking the decision of rolling out the vaccination programme.

In relation to 3b, the civil service code states that Officials are responsible for reporting to their line manager and/or their HR Advisor any potential conflicts of interest. I have attached our central conflict of interest register below. I can confirm that there are no conflicts of interest in this particular regard.  

Conflicts of interest register

In relation to 3c, the Minister for Health and Social Services met with the CMO for Wales to discuss the rationale behind the UK’s CMOs’ advice. No minutes were taken at this meeting, however the rationale behind the decision to accept of the advice is explained in the written statement that was issued: Written Statement: COVID-19 Vaccination – JCVI & Chief Medical Officers’ advice on vaccinating 12-15 year olds (14 September 2021)

Additionally, the Minister for Health and Social Services attended two UK-wide Ministerial meetings relating to the vaccination of 12-15 year olds. These meetings were not part of the decision-making process. Minutes relating to these meetings are held by the UK Government’s Department of Health and Social Care. I have provided a contact point below should you wish to contact them separately on this matter.

Ministerial Correspondence and Public Enquiries Unit
Department of Health and Social Care
39 Victoria Street
London
SW1H 0EU
United Kingdom

Next steps

The request you sent me contains personal information about you - for example, your name and address. The Welsh Government will be the data processor for this information and, in accordance with the General Data Protection Regulation, it will be processed in order to fulfil our public task and meet our legal obligations under the Act to provide you with a response.

We will only use this personal information to deal with your request and any matters which arise as a result of it. We will keep your personal information and all other information relating to your request for three years from the date on which your request is finally closed. Your personal information will then be disposed of securely.

Under data protection legislation, you have the right:    

•    to be informed of the personal data we hold about you and to access it
•    to require us to rectify inaccuracies in that data
•    to (in certain circumstances) object to or restrict processing
•    for (in certain circumstances) your data to be ‘erased’
•    to (in certain circumstances) data portability
•    to lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection

For further information about the information which the Welsh Government holds and its use, or if you wish to exercise your rights under the GDPR, please see contact details below:

Data Protection Officer
Welsh Government
Cathays Park    
CARDIFF
CF10 3NQ
Email: DataProtectionOfficer@gov.wales

If you are dissatisfied with the Welsh Government’s handling of your request, you can ask for an internal review within 40 working days of the date of this response. Requests for an internal review should be addressed to the Welsh Government’s Freedom of Information Officer at: 

Information Rights Unit
Welsh Government
Cathays Park
Cardiff
CF10 3NQ 
Email: Freedom.ofinformation@gov.wales   

Please remember to quote the ATISN reference number above. 
You also have the right to complain to the Information Commissioner. The Information Commissioner can be contacted at: 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

However, please note that the Commissioner will not normally investigate a complaint until it has been through our own internal review process.

Yours sincerely,