1. Overview – Supporting the National Effort
This guidance is a tool to support customer and visitor data gathering for businesses and other establishments in Scotland where the nature of the premises means there may be an increased risk of transmission of COVID-19 due to a higher degree of interaction between unknown individuals. It sets out how to collect individual contact details in a safe and secure manner which is compliant with data protection legislation, to assist NHS Scotland in responding to outbreaks of COVID-19. It sets out key actions and information around the collection of customer and visitor data as restrictions relating to the COVID-19 pandemic are eased. This guidance came into effect from 15 July 2020. From this date, premises within the sectors listed below were advised to gather minimal contact details from customers to support NHS Scotland's Test and Protect service. This measure forms part of the national effort to suppress COVID-19, and supports the country to return to a more normal way of life.
The timetable for planned phased reopening of sectors includes a substantial reopening of many settings from 26 April 2021.
The Scottish Government has updated this guidance, in advance of reopenings during Spring 2021, to request the collection of the name and contact details for every visitor to premises, to create consistency across the range of settings where this is requested or mandated in Scotland, and at the same time ensure that relevant data is captured to assist the Test and Protect contact tracing service.
Test and Protect – Introduction
Test and Protect was launched across Scotland on 28 May 2020 (an updated Testing Strategy was published on 17 March 2021 following the update to Scotland's Strategic Framework on 23 February 2021) and aims to prevent the spread of coronavirus in the community by:
- identifying cases of coronavirus through testing
- tracing the people who may have become infected by spending time in close contact with them
- supporting those close contacts to self-isolate, so that if they have the disease they are less likely transmit it to others
The gathering of contact information from customers or visitors by premises, in a secure and safe manner, assists NHS Scotland's Test and Protect service to identify and contact individuals who may have been exposed to the virus, and request them to take appropriate steps to prevent the potential onward spread of the virus. This could involve asking individuals to self-isolate for 10 days. The data is helpful to the NHS and key local partners to manage and contain location-specific outbreaks.
Containing outbreaks early is crucial to reduce the spread of COVID-19, protect the NHS and save lives, and avoid the reintroduction of social and economic lockdown. This supports the country to return to, and maintain, a more normal way of life.
Maintaining Customer and Visitor Records
As progress is made in suppressing the virus, restrictions on different sectors are being eased. However, this can only take place with appropriate measures in place to prevent the number of cases rising again. In order to support NHS Scotland's Test and Protect service, once premises return to welcoming customers and visitors, it is necessary for settings to gather contact information from members of the public and staff, and provide this data to public health when asked.
We strongly recommend that settings collect the details of all visitors to premises and not just the lead adult of a household. If premises offer a mixture of an on-site and collection service, contact information only needs to be collected for customers who remain on-site.
You can play a significant role in helping your staff, customers and visitors 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. You should also display a notice on your premises or on your website. We have provided a template to help you to do this, though please be aware that some people may need additional support in accessing or understanding this information.
In addition to maintaining and sharing records where requested, you must also continue to follow other government guidance to minimise the transmission of COVID-19. This includes maintaining a safe working environment and following physical distancing guidelines. More information on this can be found in sectoral guidance, available on the Scottish Government website.
Collecting contact details is voluntary, but it is important that both premises and individuals cooperate, as it is crucial to national efforts to suppress the virus. This guidance forms part of measures enabling premises and those working in other people's homes to open safely, minimising the risk of the number of infections increasing, and reducing the risk of requiring future restrictions.
Check In Scotland App
In December 2020, we launched the free Check In Scotland app. Visitors to venues are able to download the app from Google Play and the Apple App Store. Both the Check In Scotland online form and the app have been carefully designed to give visitors a choice in the way they submit contact details, and data is kept securely, in line with the requirements set out within this guidance. As well as providing choice, the app service also allows for offline use if visitors cannot connect to the internet. Each individual visitor to a premises should submit their contact details. We would strongly encourage settings to consider implementing the Check In Scotland digital solution to enable straightforward compliance with the measures required by this guidance.
Reopening of settings
We have already been able to initiate some careful but significant easing of restrictions, and will continue to do so subject to the data permitting.
Indicative dates are set out in the Strategic Framework Update section: timetable for easing restrictions.
This guidance sets out the contact information that premises have to gather, and how they should go about this, in order to make it possible to reopen while continuing to suppress the virus.
Application of the Guidance
This guidance applies to any establishment or operator in sectors that provide an on-site service or work in other people's homes to deliver a service. This includes, but is not limited to:
- Tourism and leisure, including theme parks, museums and cinemas
- Close contact services, including hairdressers, barbers, beauticians, tattooists, sports and massage therapists, dress fitters, tailors and fashion designers
- Facilities provided by local authorities, such as libraries, leisure centres and registration offices
- Cremation authorities, burial authorities, places of worship or funeral director service rooms offering funeral services
- Places of worship which are reopening for congregational services and communal prayer or contemplation.
It does not, however, apply where services are taken off-site immediately, for example, a library operating a click-and-collect service. If premises offer a mixture of an on-site and collection service, contact information only needs to be collected for customers who remain on-site.
Guidance specific to the hospitality sector, where collecting the contact details of visitors to premises is mandatory, can be found at Collecting customer contact details.