Detailed guide: Maintaining records of staff, customers and visitors to support NHS Test and Trace


The UK is currently experiencing a public health emergency as a result of the coronavirus (COVID-19) pandemic. It is therefore critical that organisations take a range of measures to keep everyone safe.The easing of social and economic lockdown measures following the COVID-19 outbreak is being supported by NHS Test and Trace.

Venues in hospitality, the tourism and leisure industry, close contact services and local authority facilities must:

  • ask at least one member of every party of customers or visitors (up to 6 people) to provide their name and contact details
  • keep a record of all staff working on their premises and shift times on a given day and their contact details
  • keep these records of customers, visitors and staff for 21 days and provide data to NHS Test and Trace if requested
  • display an official NHS QR code poster from 24 September 2020, so that customers and visitors can check in using this option as an alternative to providing their contact details
  • adhere to General Data Protection Regulations

Hospitality venues must also refuse entry to those who refuse to participate.

Failure to do any of these requirements will result in fixed penalty fines.

This guidance provides further instructions on how to fulfil these requirements in a proportionate and effective way.

NHS Test and Trace

NHS Test and Trace is a key part of the countrys ongoing COVID-19 response. If we can rapidly detect people who have recently come into close contact with a new COVID-19 case, we can take swift action to minimise transmission of the virus. This is important to help avoid further societal and economic restrictions, including local lockdowns, and will allow us to return to a more normal way of life.

NHS Test and Trace includes dedicated contact tracing staff working at national level who work closely with local public health experts. Local public health experts include Public Health England (PHE), health protection teams and local authority public health staff.

You can read further information on how NHS Test and Trace works.

The purpose of maintaining records and displaying an official NHS QR poster

By maintaining records of staff, customers and visitors, and displaying an official NHS QR poster, you will help NHS Test and Trace to identify and notify people who may have been exposed to the virus.

You must register for an official NHS QR code and display the official NHS QR poster from 24 September 2020.

The NHS COVID-19 app has a feature that allows users to quickly and easily check in to your venue by scanning the code. The information stays on the users phone. In England, you do not have to ask people who choose to check in using the official NHS QR code to provide their contact details. If there is an outbreak associated with a venue, a message will be sent to the relevant app users with the necessary public health advice.

This will help to avoid the reintroduction of lockdown measures and support the country to return to, and maintain, a more normal way of life.

In addition to maintaining and sharing records where requested and displaying an official NHS QR poster, you must also continue to follow other government guidance to minimise the transmission of COVID-19. This includes maintaining a safe working environment and following social distancing guidelines.

Sectors that this guidance applies to

There is a higher risk of transmitting COVID-19 in premises where customers and visitors spend a longer time in one place and potentially come into close contact with other people outside of their household.

To manage this risk, establishments in the following sectors, whether indoor or outdoor venues or mobile settings, must request contact details from staff, customers and visitors, and display the official NHS QR code poster:

  • hospitality, including pubs, bars, restaurants and cafs
  • tourism and leisure, including hotels, museums, cinemas and amusement arcades
  • close contact services, including hairdressers, barbershops and tailors
  • facilities provided by local authorities, including community centres, libraries and village halls

A full list of organisations within scope in these sectors can be found in annex A.

This requirement 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.

This could be asked for at the counter, rather than the point of entry, when servers can more easily ask the customer whether they are dining in or taking away.

Some venues might have communal or open-plan dining areas such as food courts. In this situation, the responsibility lies with the legal owner, however the operator could ask the individual outlets to conduct this on their behalf if more practical.

Places of worship, including when the venue is used for events and other community activities, are not included in these regulations but are still strongly encouraged to maintain staff, customer and visitor logs and to display an official NHS QR code poster. Consent should still be sought from individuals entering your establishment.

This requirement does not apply to services that are designed to feed homeless people.

Information to collect

Venues must ask every customer and visitor for the following details (unless they have checked in using the NHS COVID-19 app):

  • the name of the customer or visitor. If there is more than one person, then you can record the name of the lead member of the group (of up to 6 people) and the number of people in theat group
  • a contact phone number for each customer or visitor, or for the lead member of a group of people. If a phone number is not available, you should ask for their email address instead, or if neither are available, then postal address
  • date of visit, arrival time and, where possible, departure time
  • the name of the assigned staff member, if a customer or visitor will interact with only one member of staff (for example, a hairdresser). This should be recorded alongside the name of the customer or visitor

Recording both arrival and departure times (or estimated departure times) will help reduce the number of customers or staff needing to be contacted by NHS Test and Trace. We recognise, however, that recording departure times will not always be practicable and this is not required by law.

All designated venues must also keep a record of all staff working on the premises on a given day, the time of their shift, and their contact details. This covers anyone providing a service or activity including volunteers.

No additional data should be collected for this purpose.

In England, you do not have to request details from people who check in with the official NHS QR poster, and venues should not ask them to do both. Venues must not make the specific use of the NHS QR code a precondition of entry (as the individual has the right to choose to provide their contact details if they prefer). Should someone choose to check in with the official NHS QR poster, a venue should check their phone screen to ensure they have successfully checked in.

Many organisations that routinely take bookings already have systems for recording their customers and visitors including restaurants, hotels, and hair salons. Due to the COVID-19 outbreak, more organisations have, or are planning to implement, an advanced booking only service to manage the numbers of people on the premises. These booking systems can serve as the source of the information that you need to collect. Customers or visitors can still scan the official NHS QR code if they wish, to help remind them where they have been if asked by NHS Test and Trace.

You should collect this information in a way that is manageable for your establishment. If not collected in advance, this information should be collected at the point that visitors enter the premises. It should be recorded electronically if possible, for example through an online booking system, but a paper record is acceptable. If you are keeping a paper record, this should be out of public sight and stored securely. You must ensure that there are options for people to leave their contact details if they do not own a smartphone.

Venues introducing new systems to manage contact details must conduct a data protection impact assessment under the General Data Protection Regulations. The Information Commissioners Office (ICO) has



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