On the 23rd June 2020 the UK government announced that from the 4th July, restaurants, bars, cafes, etc. can open provided they open in a COVID-secure way. Part of the guidance (s2.1) for this included the requirement that venues keep a contact record for customers and visitors in case it is need by the NHS Test & Trace programme:
The opening up of the economy following the COVID-19 outbreak is being supported by NHS Test and Trace. You should assist this service by keeping a temporary record of your customers and visitors for 21 days, in a way that is manageable for your business, and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks.
Many businesses that take bookings already have systems for recording their customers and visitors – including restaurants, hotels, and hair salons. If you do not already do this, you should do so to help fight the virus. We will work with industry and relevant bodies to design this system in line with data protection legislation, and set out details shortly.
Given that the government are yet to set out what this looks like in practice, particularly around data protection and privacy concerns, I ran a free GDPR webinar on Monday 29th June to help those in the hospitality sector who don’t currently have booking systems and therefore are unlikely to maintain records of customers. My aim was to provide an overview of GDPR and how it will apply to the recording of customer contacts.
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