Maintaining records of customers and visitors
Maintaining records of customers and visitors
The Health Protection (Coronavirus, Collection of Contact Details etc and Related Requirements) Regulations 2020 came into force in England on 18 September 2020 and apply to all hospitality businesses (including pubs, bars, restaurants and cafés), tourism and leisure (including hotels, museums, cinemas, zoos and theme parks) close contact services (including hairdressers, nail bars and tattooists) and local authority facilities such as community centres and village halls.
The regulations require the request of certain details where an individual seeks to enter relevant premises (unless that individual is under 16 or has a mental or physical disability that means they are unable to provide the details). The responsibility for obtaining details rests with the ‘relevant person’ who operates or occupies the premises.
The details required are:
- the name of the individual;
- a telephone number on which the individual may be contacted;
- an e-mail address if the individual is unable to provide a telephone number;
- a postal address if the individual is unable to provide an email address;
- the date and time that the individual entered the relevant premises;
where a group (up to 6 people) is seeking permission to enter relevant premises together, the ‘relevant person’ must either request each member of the group provide those details or that one member provide the details for all members of the group and the number of people in that group.
Details must be retained for a period of 21 days and provide data to NHS Test and Trace if requested.
The person providing the service must take all reasonable steps to prevent access to an individual who refuses to provide the requisite details, or where none of the group has done so in accordance with the regulations. This requirement applies where the information collected is incomplete or the relevant person believes it to be inaccurate.
With effect from 24 September 2020 this does not apply to individuals who have scanned in a QR code.
It is an offence to contravene an obligation imposed by the regulations and failure to meet the requirements will result in fixed penalty fines.
QR Codes
From 24 September 2020, relevant persons must display and make available an NHS QR code at relevant premises they occupy or operate to enable certain individuals who seek to enter the premises to scan that QR code as, or immediately after, they enter the premises.
Government guidance on Test and Trace can be found here.
Relevant businesses must register for an official NHS QR code and display the official NHS QR poster from 24 September 2020.