COVID-19: further guidance on Test and Trace and data protection

On Thursday, the Department of Health and Social Care published Guidance: Maintaining records of staff, customers and visitors to support NHS Test and Trace, on the requirement for organisations in certain sectors should collect details and maintain records of staff, customers and visitors on their premises to support NHS Test and Trace.

“The easing of social and economic lockdown measures following the COVID-19 outbreak is being supported by NHS Test and Trace. You should assist this service by keeping a temporary record of your customers and visitors for 21 days, in a way that is manageable for your organisation, and assist NHS Test and Trace with requests for that data if needed.”

As to the issue of data protection:

“While consent is not required, we recommend that consent is sought in sensitive settings such as places of worship and for any group meetings organised by political parties, trade unions, campaign or rights groups, other philosophical/religious groups or health support groups. This is because of the potentially sensitive nature of the data collected in these circumstances. We will produce a template consent form to help you” [our emphasis].

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