Collecting Customer Data for NHS Test and Trace

Understanding how to gather data and what to do with it

The easing of lockdown restrictions means a return to business for many in the hospitality sector. However, this is not ‘business as usual’ – pubs, cafes and restaurants are expected to operate in very different ways in order to minimise the risk of spreading infection – including the collection of data to support the NHS Test and Trace scheme.

Guidelines released by the UK Government request that businesses where customers eat and / or drink on site collect data that can be supplied to NHS tracers if someone on those premises is later found to have contracted Covid-19. The purpose of collection is to alert others who might have come in contact with an infected person and therefore be at risk themselves. This does not apply to businesses that sell takeaway food or drink for off site consumption only.

What data should be collected?

Data should be collected for everyone on your premises – including staff, customers and other visitors if you have them. You may already gather all relevant data as part of your staff rotas and your customer booking system – if so, there is not need to collect it again, as long as you inform people that you will submit this data to the Test and Trace scheme on request, and customers are given an option to opt out of this. If you don’t have a system already in place, you might want to use our templates to do so – click for our customer record, staff record and visitor record.

The following details should be collected:

Staff:

  • Name
  • Contact phone number
  • Dates and times present at work

Customers:

  • Name of ‘lead member’ of group and number of people in group
  • Contact phone number of ‘lead member’ of group
  • Date of visit, arrival and departure times (estimated if necessary)
  • If they interact with a single staff member, the name of the assigned staff member 

Think about your method of collection – if you are asking for data on arrival, will the customer type in details on your device, or write down using your paper and pen. If so – how will you minimise the risk of transmission via these objects? If you ask them to tell you the information and you complete the form – how will you ensure their details are not overheard by another customer?

Data protection

Although businesses should encourage customers to provide these details, the customer does have the right to refuse to supply data. Any data you collect must be kept privately and securely, should be held for 21 days, and should be securely destroyed after this time period has elapsed, whether held as paper or digital records.

Important Links

For more information regarding the NHS Test and Trace scheme, click here

For more information from the Government about the role of your business in Test and Trace, click here

For more information from the ICO about keeping Test and Trace data safe, click here

Guidance for food businesses on coronavirus (COVID-19)

Reopening and adapting your food business during COVID-19

Food Hygiene and Health & Safety courses offered by the Safer Food Group