The information collected should include the names and contact numbers of staff alongside the dates and times they are at work.
For customers, if there is more than one person in a group, pubs can record the name of the lead member and the number of people in said group.
This is alongside the date of their visit, arrival time and where possible, departure time.
If pubs already have a booking system in place that takes these details, the booking system can serve as the source of information that is collected.
If the details are not recorded in advance of customers' visits, it should be collected at the point they enter the pub or at the point of service, if impractical to do so at the entrance.
The guidance says information should be digitally recorded if possible but a paper record is acceptable.
The Government states this is voluntary but operators should encourage customers to share their details to support the NHS Test and Trace scheme.
However, customers can choose to opt out and if they do so, operators should not share their information used for booking purposes with NHS Test and Trace.
Identity verification
The guidance applies to any venue that provides an on-site service and to any events that take place on the premises but not to businesses where services are taken off site immediately, such as pubs offering takeaways.
It also does not apply to drop-off deliveries made by suppliers or contractors.
Pubs do not need to verify the identity of customers and the accuracy of the information provided will be the responsibility of that individual.
Records should be held for 21 days (a reflection of the Covid-19 incubation period, which can be up to 14 days with an additional seven days to allow time for testing and tracing).
After these three weeks, the information should be securely disposed or deleted and in a way that does not risk unintended access such as shredding paper documents and ensuring permanent deletion of electronic files.
Any data collected must be handled in accordance with general data protection regulation (GDPR) to help protect the privacy of staff and customers.
It is not necessary to seek consent from each person but operators should make it clear why the information is being collected and what it will be used for.
Pubs don’t need to inform each customer individually but could display a notice at the venue or on the website and the Government will provide a template to help with this.
The data collected must only be used to share with NHS Test and Trace and not used for any other purposes such as marketing or other purposes unrelated to contact tracing, or operators will be in breach of GDPR.
Collecting the information is not mandatory but businesses are strongly encouraged to participate.
Core component
NHS Test and Trace executive chair Dido Harding said: “As we get ready to enjoy the additional freedoms that are coming this weekend, its vital that we keep up the amazing work that everyone has done across the country to protect their friends, family and communities from the spread of the virus.
“Thanks to the information members of the public are already sharing, NHS Test and Trace has already helped contact over 130,000 people who may otherwise have transmitted coronavirus.
“The virus has not gone, but we can live more safely alongside it. As we all start to visit more places and come into contact with a wider group of people in the coming weeks, we now need businesses and the public to play their part in this new national effort by sharing their contact details. That way, if someone does test positive our dedicated team at NHS Test and Trace can quickly spring-into-action to contact those who may be at risk and advise them to self-isolate, helping everyone stay safe.”
UKHospitality, the British Beer & Pub Association and the British Institute of Innkeeping have also issued guidance on the information pubs should collect from customers and staff, which is in line with the Government advice.
In a joint statement, the trade bodies said: “There has been a significant amount of interest from both businesses and customers about the track and trace scheme and some confusion also.
“It is a core component of the safe reopening of businesses and it is something that all venues are going to have to get to grips with. This can help us to avoid a second spike and the disastrous consequences that would entail, for society and business.
“This guidance provides clear instructions to businesses on their obligations and reminds them why it is important that they make a success of the scheme. It is in the interests of everyone in the country that we all understand our role in the scheme and its importance in the context of the COVID-19 pandemic.
“Businesses are urged to read the guidance thoroughly and ensure that they have the proper procedures in place before they reopen their doors to customers. If they are unsure abut any element, they should contact their trade association immediately.”
