As employees return to the office, what can employers ask employees about COVID-19 vaccines and tests? What can employers require of employees? How should any information gathered be handled internally and how can it be disclosed externally? This second installment of a two-part article series answers those questions and others to shed light on employers’ obligations and risks related to gathering, storing, providing access to and disclosing COVID-related employee data. Part one explored the applicable privacy and employment laws and provided steps companies can take to find the right balance when developing vaccine and testing policies. See our three-part series on how to facilitate a safe and privacy-compliant return to work: “Laws and Guidance” (May 13, 2020); “Policies and Protocols” May 20, 2020; “Contact Tracing” (May 27, 2020).