In early July, the Executive Chair of NHS Test and Trace encouraged everyone in the UK to “play their part in new national effort” to stop the spread of COVID-19.
Known as ‘contact tracing’, the scheme relies on the cooperation of people who have been in close contact with someone found to have COVID-19.
If you develop coronavirus symptoms and test positive for the disease, you’ll hear from the NHS either by text, email, or phone. They’ll ask you to access the new NHS Test and Trace website and provide key details about where you’ve been and who you’ve come into contact with recently.
The people whom you’ve come into contact with will then be asked to self-isolate for two weeks.
Retailers and hospitality businesses are being asked to help the Test and Trace effort by maintaining records of staff, customers and visitors.
How does Test and Trace work if I’m a retailer or hospitality business?
The government has launched an informative Test and Trace website which provides the details you need to support the scheme, but there’s no escaping the fact that it will require a fair amount of effort on behalf of operators.
However, by maintaining these records and sharing them with the NHS when requested, you’ll be helping the national effort to identity people who may have been exposed to the virus.
This is vital in limiting the spread of COVID-19 and will go a long way to avoiding further lockdowns which could cause even greater problems for the retail and hospitality sectors.
What information do I need to collect?
If you want to do your bit and support Test and Trace, you’ll need to collect the following information.
- names of all staff who work at the premises
- contact phone numbers for each member of staff
- dates and times worked by staff
Customers and visitors
- name of customer or visitor (if there’s more than one person, you can record the lead member’s name and the number of people in the group)
- contact phone number for each customer or visitor
- date of visit, arrival time and departure time
- name of assigned staff member, if applicable (e.g. the person who waited their table)
This of course means you’ll need a simple, easy-to-use spreadsheet for the task.
Good news - we’ve created one for you. Download below!
Download our free contact tracing spreadsheet
Guidance on maintaining test and trace records
The NHS is asking venues to retain their test and trace records for 21 days. This is linked to the incubation period for COVID-19 with some headroom to allow for testing and tracing.
Once the 21 days period is up, you can (and should) delete the information completely from your records.
It’s important to note that the records you’ll be keeping as part of test and trace will largely consist of personal data, therefore you’ll need to follow the GDPR guidelines to store it in a compliant fashion.
Under GDPR rules, you can request personal data from staff, visitors and customers and share it with the NHS. You won’t need to seek consent from each person to do so, but you do need to make it clear why you’re collecting the information.
For example, if you’re already collecting personal data as part of your marketing strategy, you’ll need to indicate that the same data might be used to support the test and trace scheme.
Here are some key points to bear in mind:
- you don’t need to inform people individually about the collection of data for test and trace;
- it’s best to display a notice at your premises or on your website (both, ideally) which explains that you’re participating in test and trace and therefore may ask for personal data which could in turn be shared with the NHS;
- make sure you offer the same information in different languages, if your clientele consists of multiple nationalities;
- the information you collect for test and trace must only be used for that purpose and shared with the NHS when requested - not with any other party; and
- you mustn’t misuse the data in any way that might be misleading - i.e. for marketing purposes or sharing with a partner business.
Recommended reading: GDPR tips: How to comply with the General Data Protection Regulation (ComputerWorld)
Which sectors does this apply to?
If you’re a hotel, cafe, restaurant, pub, or bar, the test and trace scheme applies to you.
The scheme isn’t mandatory, and the guidance doesn’t apply if your services are taken off site immediately - for instance, if you’re running a takeaway only operation.
This is the official list of sectors to which the guidance applies:
- tourism and leisure
- close contact services (e.g. hairdressers and tailors)
- local authority facilities (e.g. community centres)
- places of worship
If your business mixes a sit-in service with takeaway, the contact tracing information only needs to be collected for customers who choose to dine in.
How long will we have to do this for?
At the time of writing, there is no definitive end date for the test and trace scheme. By its nature, it’s designed to run its course along with the anticipated decrease in the COVID-19 reproduction rate.
Our advice is to get involved if you fall within the sectors above, and make your life as easy as possible by downloading our free contact tracing spreadsheet.