Government has published new guidance to help organisations in certain sectors collect details and maintain records of staff, customers and visitors on their premises, as of Saturday 4 July, to support NHS Test and Trace. This applies to:
- hospitality, including pubs, bars and restaurants
- tourism and leisure, including hotels, museums, cinemas, zoos and theme parks
- close contact services, including hairdressers, and others as defined here
- facilities provided by local authorities, including town halls and civic centres for events, community centres, libraries and children’s centres
- places of worship, including use for events and other community activities
This guidance applies to any establishment that provides an on-site service and to any events that take place on its premises. It does not apply where services are taken off-site immediately, for example, a food or drink outlet which only provides takeaways.
If a business offers a mixture of a sit-in and takeaway service, contact information only needs to be collected for customers who are dining in. It does not apply to drop-off deliveries made by suppliers.
Keeping a temporary record of your customers and visitors for 21 days will help NHS Test and Trace to help identify people who may have been in contact with the virus and help minimise the onward spread of COVID-19. This could help contain clusters or outbreaks.
Government wants to ensure businesses can remain open by mitigating the risk of local outbreaks and have designed a package of supporting materials which can be found in the google file here. They include:
- FAQ’s
- Customer Logging – a toolkit for business including example messaging
- A template privacy notice for organisations to personalise and use
- Social media content you can share across your channels
The ICO has also published a Statement and a short data protection A,B,C Checklist on customer logs which may be useful.