Check In - customer contact information recording for NHS Test and Trace

Check In

Customer contact recording for NHS Test & Trace


A Guide to Test & Trace Customer Information requirements.

As part of setting up the Check In service, we've done a lot of research into the government guidance and the equally important privacy requirements under the General Data Protection Regulations (GDPR).

We've summarised both to provide a handy guide to venue managers who need to understand whether they need to gather customer information, and how best to go about it.

For simplicity we've referred to "customers" throughout; this can be taken to apply equally to "visitors" as well.


The requirement to gather customer information

The most useful piece of Government guidance on collecting customer information was released on 2nd July 2020. You can read the full text here

A summary of the main points follows:

Recording of Customer Contact Information is a legal requirement as of Monday 14th September 2020.

It is essential that venues co-operate with NHS Test & Trace in order to keep everybody safe and minimise the risk of further major outbreaks of COVID-19

In our view, as well as considering the strictly legal aspects of the requirement, venue managers should consider how the failure to comply might reflect on their brand and image, and whether visitors will be discouraged from attending their venue if they feel their safety is not being taken seriously. 


Venues that should record Customer Contact Information

Any venue providing on-site services indoors, for example


The Customer Contact Information that should be recorded

The customer's name and contact phone number should be recorded, along with their arrival and departure times wherever possible. No other personal information should be collected in relation to NHS Test & Trace.

The guidance states that it is acceptable to just record the information for the lead member of a group - but it is clearly preferable to record all customers' information wherever possible.

Check In records all the above information and takes just seconds to use.

Venues should also keep records of all staff and their hours of attendance. Check In can also be used for this purpose.


How Customer Contact Information should be recorded

Preferably, digital records should be kept, though paper records are acceptable.

Check In records are all digital. In the event of an NHS Test & Trace disclosure request, we can make the relevant data available in minutes.

The government recommends Customer Contact Information should be retained for 21 days, which reflects the 14-day incubation period of COVID-19.

Check In stores Customer Contact Information for a maximum of 28 days, to allow a little leeway in the event of a delayed Test & Trace request.



General Data Protection Regulation (GDPR)

The government guidance referred to above provides a useful overview of GDPR requirements - we'd recommend you read that section in full. However it does not cover the detailed requirements other than by providing links to the Information Commissioner's Office (ICO) website.

All GDPR requirements are mandatory and legally enforceable. Failure to comply may constitute a breach of the Data Protection Act 2018 (DPA 2018).

We've summarised the key GDPR requirements below, as they apply to gathering Customer Contact Information for NHS Test & Trace. You can read the full GDPR guidance on the ICO website.

Check In takes care of this on your behalf, because we handle the data and all of the associated GDPR requirements.