Data collection in England – Mandatory requirements to support NHS Test & Trace
Based on latest information – legislation and guidance has yet to be published by Government
- Collection of staff, customer and visitor data is mandatory from 18th Sept – this will mean that customers have to be proactively asked to provide their details. This could be in advance, via booking, or at the venue.
- The NHS Test & Trace app will be launched on 24th
- Venues must also display a NHS QR code that can be scanned using the NHS Test & Trace app. This is a unique code for that venue/location that must be registered and downloaded via the Government website.
- A venue could choose to use the NHS Test & Trace QR code (linked to NHS app) as its primary means of fulfilling the requirement to collect customer details, and therefore stop using any existing in-house system such as their own QR codes. This would be the preference of Government due to the additional functionality and epidemiological information associated with this.
- Alternatively, a venue could choose to continue to operate its own existing system for collecting customer details. If that is the case, an NHS Test & Trace QR code still needs to be displayed prominently in the venue and to be accessible for all customers in case they chose to additionally use it to “check-in”.
- If the NHS Test & Trace QR code is used as a venue’s primary means of collecting customer details, all customers must “check-in” by scanning the QR code. However, if a venue chooses to continue operating its own in-house system for collecting customer details, only the lead customer’s details have to be recorded.
- Regardless of whatever App-based system is used as a method for collecting customer details, all venues must operate a “back-up” system for anyone that does not have a smartphone (c. 8 million adults) or who choose not to use the NHS Test & Trace QR code. This is most likely to be a pen and paper method unless venues are operating a booking-only system that would then capture all lead customer details.
- If customers refuse to provide their details using any of the methods, there will be a duty on the venue to refuse entry/service. Government had indicated they will provide communications materials to support refusals.
- Government will also be monitoring the number of venues registering for the NHS QR code to determine success of take-up.
15th Sept 2020