The government has made it mandatory for all businesses in the hospitality sector, leisure and tourism sector and close contact businesses, such as barbers and beauticians, in England to collect customer information for the test and trace programme.
The Scottish and Welsh governments have also mandated certain organisations to ask for customer and visitor information.
This does not need to be complicated.
The ICO is advising organisations across the UK to follow five simple steps so they handle people’s information responsibly.
Ask for data that is 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, eg ID checks for age verification in pubs.
Tell customers how you will use their data
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.
Look after personal 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 and out of public sight.
See our guidance on simple security measures you can take here.
Only use data for the purpose you said you would
You cannot use the personal information that you collect for contact tracing for other purposes, such as direct marketing, profiling or data analytics.
Erase data 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.