The University of Waterloo's "vaccination requirement" and the Covid-19 Immunity Task Force
UW president Vivek Goel's undisclosed conflict of interest
Vivek Goel began his tenure as University of Waterloo (UW) president on 1 July 2021. Since July 1 is a holiday, his first day on the job was July 2. To kick off his presidency, he published an opinion piece (paywalled) where he called for a "great reset" for the "postpandemic university." Foreshadowing things to soon come, the piece's first noun phrase was "the rapid pace of vaccination."
In the year before arriving at UW, while UW was searching for its next president, Goel served on Canada's Covid-19 Immunity Task Force. To pursue this opportunity, he resigned from a successful vice presidency at the University of Toronto.
Goel said at the time,
I'm just trying to ... spend my time where I can focus on big public health issues.
He didn’t want to focus on other things while the public health situation was "raging out of control."
"Public health," Goel explained, works with "entire populations," which he found more satisfying than working as a "primary care physician," who works with patients "as individuals."
PublicHealth.org concisely explains the distinction between the two approaches to health:
The Covid-19 Immunity Task Force
The Covid-19 Immunity Task Force “works closely” with “public health agencies," supports “public health efforts," and prioritizes public health over personal health. One of its “guiding principles” is to “establish an ethos” in which “the broad public interest over-rides any considerations of personal” interests regarding information on covid-19.
Inspection of research funded by the Task Force, its news feed, and social media reveals that it supports “mandatory vaccination,” policies that “require people to provide proof of immunization,” and considers it “urgent” to “vaccinate the world” against covid-19.
Goel’s service to the Task Force is a source of accolades and personal benefit for him. It was cited by the Fields Institute when awarding Goel a fellowship (see p. 63 of this document).
Goel's decisions
Within weeks of becoming UW's president, Goel issued a series of unprecedented and coercive orders that aligned closely with the Task Force's mission and priorities.
Goel ordered a "vaccination requirement" first for students living in campus residences (22 July 2021), then for the entire community — all students, staff and faculty (24 August 2021). Goel motivated these decisions by appealing to public health:
Ensuring high rates of vaccination remains the most important way we can protect public health during the pandemic.
To defend Goel's decisions, UW repeatedly lied by claiming it was legally required to impose a vaccination requirement.
Although the instructions from Ontario's top public health official allowed individuals to "declin[e] vaccination for any reason," Goel declared that at UW accommodations would be "rare" and limited to specific medical and human-rights grounds. By October 2021, Goel further narrowed accommodations to "unique cases."
More recently, when Ontario's top public health official informed UW that vaccination policies should be removed, Goel defied that guidance.
UW policies
UW's Policy 69: Conflict of Interest "obligates" its members to avoid "conflicts of interest which may impede or compromise their" responsibilities. Policy 69's "fundamental tenet" is proactive disclosure of conflicts or potential conflicts of interest.
Professional ethics and common decency demand the same.
Policy 69 defines a “conflict of commitment” as an “external activity or undertaking which places an individual in a position which interferes with or prevents the discharge of her/his University responsibilities.” In such a case, the individual has “divided loyalty.”
UW's Policy 34: Health, Safety and Environment recognizes the individual's primary responsibility for their own safety, behavior, and effects on others; it also places the highest value on individual health and safety:
UW's Policy 50: The President of the University says, unsurprisingly, that the president is “responsible for overseeing and upholding policies and for maintaining the ... integrity of the University."
Goel's conflict of interest
The Covid-19 Immunity Task Force's agenda of compulsory vaccination and prioritizing public health over individual health conflicts with UW's Policy 34. In particular, the Task Force's agenda conflicts with the priority of individual health and with the individual's responsibility for their own safety and actions.
Goel's service to the Task Force puts him in a position of conflict between that external organization's agenda and his responsibility as president to uphold UW Policy 34. This is a conflict of commitment.
Not only does this conflict exist but the nature of Goel's decisions regarding UW's "vaccination requirement" leaves no doubt which side of the conflict prevailed. Goel's commitments clearly interfered with his responsibility to uphold UW's Policy 34.
Goel's failure to disclose
In the summer and fall of 2021, Goel failed to disclose to the individuals whom he was coercively ordering to take covid-19 vaccines that he serves an external organization that promotes covid-19 vaccines and vaccination requirements.
Goel also failed to disclose to those same individuals that he serves an external organization that prioritizes public health over individual health.
Every member of the UW community deserved a chance to know of Goel's conflict and to decide, in context, whether his orders were unduly influenced by his personal commitment to an external organization's agenda.
Appropriate proactive disclosure would have involved Goel stating at least two things in the context of issuing his coercive medical orders:
his commitment to the Task Force, and
the specific nature of his conflict arising from the Task Force's agenda and existing UW policies, especially Policy 34.
Goel is a member of the UW Board of Governors. Here is what the Board's bylaw obligates governors to do regarding conflicts:
By this standard, Goel was obligated to not only proactively disclose the conflict but also to recuse himself from any official discussion or decision-making on covid-19 vaccination policies. He should not even have been in meetings where the matter was discussed, let alone issuing orders.
A weak defense
Some UW members defend Goel by arguing that when UW announced he would be its next president in November 2020, it mentioned his involvement with the Task Force. The announcement included this sentence:
The public health physician currently serves as a scientific advisor on the federal government’s COVID-19 Immunity Task Force[.]
In response, this isn’t a conflict disclosure because it doesn't even hint at a potential conflict. It merely asserts an affiliation. It doesn’t describe the inconsistency between the Task Force's agenda and UW’s health and safety policy. Nor, importantly, could it have done so in relation to Goel’s coercive medical orders, which wouldn’t be issued for another seven months.
Moreover, thousands of new students and dozens of new staff and faculty join UW every year. Most new members arrive in the summer. Even if UW's fall 2020 announcement counted as a disclosure, which it doesn’t, individuals arriving in summer 2021 didn’t receive it. But they still received Goel’s coercive medical orders, so they were owed disclosure too.
Other UW members defend Goel by arguing that because other Ontario universities implemented similar policies, Goel therefore didn’t have a conflict of interest.
In response, the fact that other people did similar things doesn’t negate Goel's evident conflict or his disclosure obligations. Researchers receiving money from a drug company to test their drug's safety must disclose that funding even if other researchers reached the same conclusion about the drug.
It’s worth repeating that UW's disclosure requirements apply to not only actual conflicts, but also potential and perceived conflicts. There will often be controversy and reasonable disagreement over whether a conflict is real or apparent, but there won’t always be enough time to settle the matter before decisions must be made. Proactive disclosure requirements err on the side of caution, which minimizes suspicion and potential feelings of betrayal.
Conclusion
Goel failed to disclose his conflict of interest in the context of issuing coercive medical orders to tens of thousands of individuals and restricting accommodations to a quota of “rare” and “unique” cases. This is a serious breach of trust and a violation of university policy. A thorough, transparent investigation and accountability are called for.
Especially when it comes to decisions about their health, people deserve a chance to decide for themselves whether a potential conflict is real and significant. This is not a mere technicality but a matter of respecting their agency and autonomy.
In the end, Goel used the powers of his office at UW to “focus on big public health issues.” But a university presidency is not a public health office. Treating it as such corrupts the institution and damages its integrity.