COVID-19 antibody testing
New options and challenges for corporates
Many countries are considering the introduction of antibody tests for COVID-19. These are tests to establish whether an individual has built up antibodies to the virus, which might protect them against re-infection and enable them to work and travel without restrictions.
There has been no requirement previously for either the government or corporates to carry out tests on individuals, and given their lack of experience in managing disease-related risks, and they may face difficulties when deciding to conduct them. Implementing antibody testing would have implications for various business functions, such as HR, Risk Management, and procurement and supply, as well as for information security, data privacy, corporate culture in general.
With flattening infection rates for COVID-19, countries are lifting their lockdown restrictions and corporates are aiming toward restoring full operational capacity. A clinically-tested and approved vaccine cannot be expected within the next few months, opening up the risk for a second wave of infections and its economic and social consequences. Antibody (immunity) tests are therefore at the centre of discussions about strategy and planning, in the belief that assurance of immunity will provide protection for employees and enable a return to work.
While clinical testing and research for a vaccine is still ongoing, several COVID-19 antibody tests are now available in Switzerland. Previously testing has mostly been targeted, and carried out by the government; but people want to feel safe again and return to a normal life. Since antibody tests are now available to the general public, new options have opened up for corporates to reconsider their pandemic strategy by providing evidence of ‘fitness to work’.
What are the options?
The herd immunity concept or broad vaccination of the population are still somewhere down the road, and are not practicable strategies at the moment. This means that as a society we are in a transition phase, seeking a solution that protects our workforce while also keeping the economy running. Immunity tests are a specific set of available tools to address the challenge, in one of the following three scenarios, or in a combination of them.
- Scenario 1: Government-enforced testing
- Scenario 2: Strategic initiatives by corporates
- Scenario 3: Private action by employees
A fourth scenario would be to do nothing, but this seems inadvisable in current circumstances. All three scenarios have direct and indirect implications for companies.
If the Federal Government at some stage makes testing compulsory or partially compulsory under Scenario 1, there will likely be guidance about the conduct of testing schemes. Businesses would need to comply with the regulations. Tracking could be managed through immunity passports, which are currently being developed and tested. (A digital health passport could be used to log immunity test results and therefore certify that an individual is immune from the COVID-19 virus.)
The government may not to undertake testing, but leave it to corporates or individuals to decide what they should do. There are various reasons why Scenario 2 or 3 may occur, such as requirements for a ‘pandemic visa’ to travel or a need to obtain a license in order to operate.
Considerations for each scenario
We have mapped some important considerations for each of these scenarios, as a starting point for navigating through the challenges of immunity testing for organisations. The overreaching goal is to protect the health and wellbeing of employees whilst operating a competitive business. In some industry, sectors where social distancing at work and hygiene measures are not possible, manageable but affordable solutions for flexible work patterns must be found. Business models may need to change temporarily into a pandemic mode, which most companies have not previously applied.
- Consider and address COVID-19 risks and workforce shortages in Target Operating Model
HR (human capital)
- Test results may become a criterion for employment
- Talent selection criteria for industries unable to apply social distancing at work
- Pandemic visa concept: potential immunity passport to facilitate free movement
Leadership and culture
- Requirement for corporate strategy and communication about testing
- Cyber security and data privacy issues
- Data privacy considerations with respect to managing medical data
Supply chain and procurement
- Consider local (Swiss) vs offshore (e.g. Asia) procurement with respect to supply chain risks
- Need for capability to manage risk of fake tests, fraudulent test results
- Manage distribution process internally and testing facilities externally
- Dedicated management of the operational risks from COVID-19
- Address and consider COVID-19 risks and workforce shortages in Target Operating Model
HR (human capital)
- Inclusive leadership strategy to be adopted
- Questionable capability to validate test results
- More reliable workforce planning due to reduction in uncertainty
- Oversight of eligibility to request 'Kurzarbeit' / governmental support
- Employment criteria for industries unable to apply social distancing at work
Leadership and culture
- Manage employees who neglect hygiene and social distancing rules after proven immunity
- Encourage correct behaviour and make rogue behaviour difficult
- Creating and maintaining a feeling of inclusion
Cyber security and data privacy
- Data input, processing, storage, reporting, deletion of medical data require highest data privacy protection standards
- Maintain data consistency when tacking and logging test results
- Define strategy for multinational organisations
- Define and apply standards and benchmarks
- Apply stringent rule-based access management
- Address and consider COVID-19 risks and shortage of workforce in Target Operating Model
HR (human capital)
- Address issues of pressure to conduct tests for maintaining competitiveness on job market
- Diligent handling of test results and implications
Leadership and culture
- Requirement for adopting corporate strategy and communication
- Culture of peer pressure
- Cyber security and data privacy
- Data privacy considerations in respect to managing medical data
There are also positive aspects to the crisis: The COVID-19 crisis can be an opportunity for business leaders to foresee challenges and seek ways of overcoming them.
Allowing functions such as Human Resources or Risk Management to deal independently with the implications of testing and returning to previous “normality” can leave too many loose ends. If a company cannot manage the associated risks in a cross-functional way, it should become a leadership and cultural imperative to empower everyone in the organisation to address the challenges of COVID-19.
Navigating businesses to a “new normal” in the months ahead will need a holistic approach to finding solutions. Challenges should not be addressed in functional silos, but on an overarching level. It is a time to progress, and an opportunity to evolve.
How Deloitte can help
Depending on the business area where support is requested, Deloitte can assist by bringing in subject matter expertise, to ensure that the COVID-19 crisis can be handled and associated pitfalls avoided, making the risk management framework and operations even stronger and more robust:
- Addressing fraud risks in procurement and managing exceptions in the overall execution of an immunity test program.
- Helping you organise your workforce and providing support with change management to the “new normal”.
- Advising on risk management in this “new normal”, to embed the necessary controls and risk frameworks.
- Providing advice and support for handling employees’ medical data, which will require a high level of security.
- Optimising business processes, and automating supply chain activities across your value chain. This can mean integrating immunity testing into operational processes.
- We can also help you manage sensitive medical data and with setting up secure and confidential reporting channels.
Philipp is a Partner in Forensic, Financial Advisory, focusing on companies in the Life Sciences and Industrial sectors. He advises on the field of forensic investigations, anti-bribery compliance, the analysis of the financial relationships of a company, cybercrime, corporate compliance management, asset tracing in an international context, crisis management. In addition to that he acts as a trainer and an ombudsman. Philipp has chaired different Swiss working groups around the topic fraud prevention and corporate compliance.
Nadines experience ranges from quality and risk management to sustainable finance regulation and sustainability topics relating to health and security. With an educational background in human security focusing on pandemics, Nadine is also member of the Deloitte Switzerland pandemic working group. Nadine focus is on risk management across all industries.