Scottish Government publishes new guidance ahead of outdoor areas opening today
OPERATORS opening outdoor areas today (July 6) are being encouraged to collect customer contact details to help support NHS Scotland’s Test and Protect system.
The Scottish Government published updated guidance for the hospitality sector on Friday (July 3) outlining the “minimum contact details” it wants hospitality businesses to gather and store for 21 days as part of its efforts to curb the spread of Coronavirus.
The guidance states that “collecting customer contact details will be voluntary, but it is important that both businesses and individuals co-operate, as it will be crucial to national efforts to suppress the virus”.
In addition to names and contact numbers of all staff and the dates and times they are at work, operators should collate, “where possible”:
- the name of each customer or, when customers are attending as a small household group, the contact details for one member of that group;
- a contact phone number for each customer, or for the ‘lead member’ of a small household group (if a customer does not have a mobile number, a postal or email address may be taken);
- the date of visit and arrival and, where possible, departure time.
Contact data should be collected upon arrival or through an advanced booking; and the Scottish Government has produced posters for hospitality businesses to display informing customers that they will be asked to provide contact details, and a privacy notice which should be displayed in line with GDPR requirements to inform customers of how their information will be used and protected. Click here to view the poster and click here to access the privacy notice.
Data should be recorded digitally if possible, but the guidance states that a paper record is acceptable. To gather and store customer information securely, businesses may need to register with the Information Commissioner’s Office (ICO) and can check by calling the ICO helpline on 0303 123 1113. All records should be stored securely and deleted or destroyed at the end of the 21-day retention period.
“You should encourage the individual to share their details in order to support NHS Test and Protect and advise them that this will only be used in the event of an outbreak or if a number of new cases are tracked back to the premises; their information will then be used to inform them if they may have been exposed to a positive case or cases,” says the guidance.
“If the individual still does not want to share their details but wishes to proceed with a booking and/or use your service, you should make a note not to share this if you still need to collect their details for booking purposes. If you do not need their details for booking purposes, then simply do not collect their details.
“There is no legal requirement that individuals provide their data for NHS Test and Protect purposes, so if you want to continue to offer your services to customers or visitors that do not choose to provide their information, then you can do so. Employers should make clear to their employees the approach that they wish them to take in these circumstances.
“You can play a significant role in helping your staff and customers to understand the value of NHS Scotland’s Test and Protect service, and the importance of playing their part to identify people who may have been in contact with the virus. Please do this by explaining why you are asking for contact information and encouraging them to provide it.”
The guidance comes as operators across Scotland gear up to open outdoor areas today (July 6).
First minister Nicola Sturgeon visited the outdoor area at Cold Town House in Edinburgh to see the measures that have been implemented to ensure staff and customers can socialise safely.
“I hope that as we take these first gradual steps out of lockdown people will begin to feel more of the sense of normality that we have worked so hard for – although it is important to remember that the virus has not gone away so we cannot get complacent,” she said.
“No beer garden or café should feel the same as it did before. The vast majority of the hospitality industry will be following the rules and putting in place new procedures to help control the virus. People should look for those safety measures and be aware of the need to follow the FACTS at all times when out in the community.
“If we continue to stick to the rules we will be able to drive the virus down further and live less restricted lives in the weeks and months ahead.
“Until then support local businesses if you can, socialise safely and make sure that while you enjoy yourself you also protect others.”
Stephen Montgomery, president of the Scottish Licensed Trade Association (SLTA), said: “We understand that there will be changes in place to reduce the spread of COVID-19 which we are sure customers will understand.
“We would encourage customers to keep to physical distancing measures and work with premises to ensure public health is maintained, including providing staff with contact details to support Test and Protect.”
