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 comes into effect from 15 July. From this date, premises within the sectors listed below should gather minimal contact details from customers to support NHS Scotland's Test and Protect service. This measure will form part of the national effort to suppress COVID-19, and support the country to return to a more normal way of life.
Test and Protect - Introduction
Test and Protect was launched across Scotland on 28 May 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, will assist 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 will also be 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 will support 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 businesses to gather contact information from members of the public and staff. Where members of the public are attending as a small household group, the contact details for one member - a 'lead member' - will be sufficient alongside the size of the group. 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, in the settings which this guidance applies to, is voluntary, but it is important that both premises and individuals cooperate, as it will be crucial to national efforts to suppress the virus. This measure forms part of enabling premises and those working in other people’s homes to open safely, minimising the risk of the number of infections increasing, and will reduce the risk of requiring future restrictions.
Easing of restrictions are set out in the Scottish Government's route map. At present, the following changes are planned for the sectors covered by this guidance:
- Reopening of indoor hospitality settings - 15 July
- Reopening places of worship for congregational services and communal prayer and contemplation - 15 July
- Museums, galleries, monuments, libraries, various other visitor attractions, cinemas (including drive-ins and venues screening films) - 15 July
- Hairdressers and barbers can re-open - 15 July
- Easing of restrictions on attendance at funerals, marriage ceremonies and civil partnership registrations - 15 July
- Other personal retail services such as beauticians and tailors can re-open - 22 July
The above are, where relevant, subject to other public health measures such as physical distancing, limited numbers, hygiene measures and restrictions remaining in place on other sectors e.g. hospitality sectoral guidance in the case of a wedding reception or funeral wake.
The following guidance sets out the contact information that premises will 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 GuidanceThis 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.