Can we share employee vaccination status with managers so they can enforce any policies based on that information, such as masking and social distancing?

Yes. Obviously, managers will need this information if they are expected to enforce vaccination-dependent policies, and employers should train them on how they should be enforcing the policies and how and when to escalate issues to HR or a higher level of management. However, you should not share this information any more widely than necessary. Vaccination status is medical information that must be kept confidential.

While anonymized information is okay to share widely—e.g., “80% of our employees are vaccinated!”—each employee’s vaccination status should be treated as confidential, even if the fact that they are wearing a mask to work seems to reveal their status publicly.