Toolkit for businesses in England keeping customer records for NHS Test and Trace

Posted: Fri 3rd Jul 2020
Enterprise Nation has been sent a detailed toolkit created by the government to help businesses in England record visitor and customer data for use by NHS Test and Trace.
The toolkit is available here and will be regularly updated. We have summarised some of the assets below.
With hospitality and other businesses allowed to open in England from tomorrow (4 July), many companies are being asked to keep details of visitors, customers and staff which can be used to detect people who have recently come into close contact with a COVID-19 sufferer.
The guidance 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
The guidance 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.
The government guidance is here.
Businesses are urged to keep records for 21 days of the following:
The names of staff who work at the premises
A contact phone number for each member of staff
The dates and times that staff are at work
The name of the customer or visitor. If there is more than one person, record the name of the 'lead member' of the group and the number of people in the group
A contact phone number for each customer or visitor, or for the lead member of a group of people
A customer or visitor's date of visit, arrival time and, where possible, departure time
If a customer will interact with only one member of staff (e.g. a hairdresser), the name of the assigned staff member should be recorded alongside the name of the customer
The government says businesses should collect information "in a way that is manageable" for the specific venue. If not collected via an advancebooking, it should be collected when people enter the premises or at the point of service if not possible to do so at the entrance.
Data should be recorded digitally if possible, but a paper record is acceptable too.
Although customers are not legally obliged to share their information, the General Data Protection Regulation allows businesses to request contact information but it must be handled correctly to protect privacy.
The government says companies should display a notice at the premises or on a website setting out what the data will be used for and the circumstances in which it might be accessed by NHS Test and Trace.
A guide to customer logging and messaging for posters and websites is here.
Tips on keeping records of staff, customers and visitors is here.
Helping founders #OpenforBusiness
Enterprise Nation has resources and case studies to help small businesses of all types reopen and trade successfully during the coronavirus pandemic: