Guidance Published on Recording Contact Tracing Details

The ICO have, today, published their guidance on protecting customer details collected for the purposes of contact tracing, whilst adhering to GDPR. This relates to Section 2.1 of the government guidelines on restaurant and bar re-opening which states: - ‘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.’ The ICO say that they ‘understand that organisations have lots of new measures to put in place so that they can re-open safely to the public. For many, this includes collecting customers’ and visitors’ personal information for the first time, to support the various contact tracing schemes in the UK.  It doesn’t need to be complicated - there’s no need for you to develop special apps or digital solutions – just choose the process that best suits your business.’ Their five simple ABC steps to help ensure that data protection is not a barrier to recovery are set out below. Ask for only what’s needed You should only ask people for the specific information that has been set out in government guidance. This may include things like their name, contact details and time of arrival for example. You should not ask people to prove their details with identity verification, unless this is a standard practice for your business, e.g. ID checks for age verification in pubs. Be transparent with customers You should be clear, open and honest with people about what you are doing with their personal information. Tell them why you need it and what you’ll do with it. You could do this by displaying a notice in your premises, including it on your website or even just telling people. If you already collect customer data for bookings, you should make it clear that their personal data may also be used for contact tracing purposes. Carefully store the data You must look after the personal data you collect. That means keeping it secure on a device if you’re collecting the records digitally or, for paper records, keeping the information locked away. See the ICO guidance on simple security measures you can take here Don’t use it for other purposes You cannot use the personal information that you collect for contact tracing for other purposes, such as direct marketing, profiling or data analytics. Erase it in line with government guidance You should not keep the personal data for longer than the government guidelines specify. It’s important that you dispose of the data securely to reduce the risk of someone else accessing the data. Shred paper documents and permanently delete digital files from your recycle bin or back-up cloud storage, for example. Further government guidance will be issued on this topic. If you need more help, the ICO are there to answer your questions...
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