Covid 19 contact tracing guidance for Hospitality

Well done you made it, you are open finally!!! Just one more hurdle to cross now.… how to support the Governments track and trace program.  I am sure that you have heard about this and what you, as a business, need to do.

If you haven’t here is a quick summary;

What is it and why ? 

The Government is asking the general public/hospitality businesses to help stamp out further COVID infections by providing basic information to be used as part of its contact tracing regime. Contact tracing is a crucial part of ensuring that you can continue to trade in the event of a spike in infections. It is critical to support the NHS and avoid a second lock down.

Who and what do you need to record?

The objective is to get enough information on customers and staff to allow local NHS/public health professionals to follow up with them about anyone they may have come into contact with

This does not mean you need to get information on every single customer… thank goodness I hear you cry!

You need to obtain the following;

  • You need to get details from those eating/drinking in the premises/in the gardens/outdoor tables (provided by you)
  • You only need one contact name and phone number for each group i.e. the person making the booking or reservation in advance
  • You don’t need to get a details if its for take away (consumption off the premises)
  • Try and record the time the guests were on the premises e.g. time booking started/how long a table was booked for and rough time of departure (estimates are fine)
  • Keep information on staff working rotas, including start/finish time and where they worked (restricting work areas will minimise disruption if there is an infection as you will be able to rapidly eliminate some staff members)
  • It would help  if you  can record which customers sat at which tables, as that could be used to eliminate customers and staff
  • Its up to you to decide how best obtain and record this information – there are no mandatory requirements about how collection is carried out
  • Details should also be recorded for contractors working on site but not those carrying out deliveries/pick-ups (including third party delivery couriers)
  • Name and number can be taken in advance remotely through a telephone booking, an online reservation, or at point of entry or at point of sale – this is your choice
  • There is no requirement to verify the data collected but you should encourage accurate reporting

If a customer refuses to provide their details, then they do not have to provide it and you can allow service. However, for the safety of staff and customers, you may wish to refuse service. If you do permit service and have collected data for a booking you need to exclude this data from your track and trace dataset.

What do you need to do with the data?

  • You only need to store the data for 21 days
  • The information is only needed if there are outbreaks/chains of infection involving people visiting or working on your premises – you don’t need to do anything else with the information
  • If necessary you will be contacted by local public health departments/NHS contact tracers and asked to provide as much information as possible about those on site at given times/places who may have interacted with person who has tested positive

You are looking to identify those who have been in sustained contact with an infected person – closer than 1m for 1 minute or 2m for 15 minutes – so if you can identify where the person sat or worked you may be able to eliminate members of your team and customers from contact tracing.

What about GDPR

Guidance is available from the Information Commissioners’ Office

https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/contact-tracing-protecting-customer-and-visitor-details/

If you are already capturing data from customers through online booking, reservations, wi-fi or app usage then you will be automatically allowed to share this on request with the NHS or local public health team (unless they have opted out of data provision).

As always if you have any questions please feel free to contact Mercury Support.