Publication - Advice and guidance

Coronavirus (COVID-19) Test and Protect: multi-sector guidance on collection of customer and visitor contact details – July 2020

Guidance to support customer and visitor data gathering for businesses and other establishments to assist contact tracing as part of NHS Scotland's Test and Protect system.

Coronavirus (COVID-19) Test and Protect: multi-sector guidance on collection of customer and visitor contact details – July 2020
2. Registration with the Information Commissioner's Office

2. Registration with the Information Commissioner's Office

In order to gather and store customer information securely, establishments may need to be registered with the Information Commissioner's Office (ICO). This will be the case if you are using an electronic system to gather and store data.

To establish if you need to register your organisation with the ICO please complete the registration self-assessment at https://ico.org.uk/for-organisations/data-protection-fee/self-assessment/.

If your business is already a data controller, you should already be registered with the ICO. A data controller can be any organisation or sole trader who processes personal information such as CCTV, staff or customer details.

However, if you are using an electronic system to store customer data and not already a data controller, or have not already registered as one, you may need to register with the ICO. If you are unsure whether you need to register, please contact the ICO via their helpline on 0303 123 1113, or visit www.ico.org.uk.

The cost of the data protection fee depends on the size and turnover of the business, but for most businesses it will cost £40 or £60. The form will take around 15 minutes to complete. The ICO has published its own detailed guidance on collecting customer and visitor details for contact tracing, available at https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/coronavirus-recovery-data-protection-advice-for-organisations/collecting-customer-and-visitor-details-for-contact-tracing/.


Contact

Email: CPE@gov.scot