Detailed guide: Maintaining records of staff, customers and visitors to support NHS Test and Trace

The government is committed to ensuring the right levels of intervention in the right places to manage outbreaks, suppress the virus and keep R below 1.

From 2 December 2020, a tiered system has been reintroduced. There are 3 tiers for local restrictions:

You can use the postcode checker to find out the restrictions in your area or an area you plan to visit.

Depending on the tier in which your business is located, you may or may not be allowed to remain open, and each tier has different requirements for different sectors. Further information about how and which businesses can operate in which tiers.

If your venue can stay open in your allocated tier, then you must continue to follow the guidance on this page.

If your venue must close in your allocated tier, then you must follow the guidance on this page when you are allowed to reopen.

The UK is currently experiencing a public health emergency as a result of the coronavirus (COVID-19) pandemic. It is therefore critical that organisations take a range of measures to keep everyone safe.

Venues in hospitality, the tourism and leisure industry, close contact services, community centres and village halls must:

  • ask at least one member of every party of customers or visitors (up to 6 people) to provide their name and contact details
  • keep a record of all staff working on their premises and shift times on a given day and their contact details
  • keep these records of customers, visitors and staff for 21 days and provide data to NHS Test and Trace if requested
  • display an official NHS QR code poster so that customers and visitors can check in using this option as an alternative to providing their contact details
  • adhere to General Data Protection Regulations (GDPR)

Hospitality venues must also take reasonable steps to refuse entry to those who refuse to participate.

Failure to do any of these requirements could result in fixed penalty fines.

This guidance provides further instructions on how to fulfil these requirements.

NHS Test and Trace

NHS Test and Trace is a key part of the countrys ongoing COVID-19 response. If we can rapidly detect people who have recently come into close contact with a new COVID-19 case, we can take swift action to minimise transmission of the virus.

NHS Test and Trace includes dedicated contact tracing staff working at national level who work closely with local public health experts. Local public health experts include Public Health England (PHE), health protection teams and local authority public health staff.

You can read further information on how NHS Test and Trace works.

The purpose of maintaining records and displaying an official NHS QR poster

By maintaining records of staff, customers and visitors, and displaying an official NHS QR poster, you will help NHS Test and Trace to identify and notify people who may have been exposed to the virus.

You must register for an official NHS QR code and display the official NHS QR poster.

The NHS COVID-19 app has a feature that allows users to quickly and easily check in to your venue by scanning the code. The information stays on the users phone. In England, you do not have to ask people who choose to check in using the official NHS QR code to provide their contact details. If there is an outbreak associated with a venue, a message will be sent to the relevant app users with the necessary public health advice.

In addition to maintaining and sharing records where requested and displaying an official NHS QR poster, you must also continue to follow other government requirements and guidance to minimise the transmission of COVID-19. This includes maintaining a safe working environment and following social distancing guidelines.

Sectors that this guidance applies to

There is a higher risk of transmitting COVID-19 in premises where customers and visitors spend a longer time in one place and potentially come into close contact with other people outside of their household.

To manage this risk, establishments in the following sectors, whether indoor or outdoor venues or mobile settings, must request contact details from staff, customers and visitors, and display the official NHS QR code poster:

  • hospitality, including pubs, bars, restaurants and cafs
  • tourism and leisure, including hotels, museums, cinemas and amusement arcades
  • close contact services, including hairdressers, barbershops and tailors
  • community centres, libraries and village halls

A full list of organisations within scope in these sectors can be found in annex A.

This requirement applies to any establishment that provides an on-site service and to any events that take place on its premises. It does not apply where services are taken off site immediately, for example, a food or drink outlet which only provides takeaways. If a business offers a mixture of a sit-in and takeaway service, contact information only needs to be sought for customers who are dining in.

This could be asked for at the counter, rather than the point of entry, when servers can more easily ask the customer whether they are dining in or taking away.

If you have multiple points of entry you will need to ensure that you have a system that meets the legal requirements. This may mean adapting the way that customers and visitors circulate in your premises.

Multi-use premises

If your business contains several individual venues, then you as the wider venue are still required to collect details of staff, customers and visitors at the main entrance.

If your business is within a larger venue then you are only required to collect details of customers, visitors and staff in addition to the main entrance if you are a hospitality service, for example a cafe within a museum.

Other types of businesses are not required to collect details, when they exist within a larger premises in scope.

Cinemas

Food and drink sold in cinemas will be considered a takeaway service, and there is no requirement to refuse custom to people who do not provide their contact details or check in with the NHS QR code.

Venues with open-plan dining areas

Some venues might have communal or open-plan dining areas such as food courts. In this situation, the responsibility lies with the legal owner of the space, who is liable for these requirements.

If your business operates within a food court, where food and/or drink is sold and consumed solely in communal dining areas, then you as an individual business owner within the food court are not required to collect details of customers, visitors and staff. However, the legal owner of the wider venue is required to collect visitor details at a designated entrance to the food court. Where an outlet has their own seating area, the legal owner of that outlet is responsible.

Workplace canteens

Workplace canteens which are open only to staff at that workplace are not required to collect the details of their staff who visit the canteen.

If a workplace canteen may be accessed by members of the public however (for example, anyone who is not an employee), then this venue would be required to collect the details of customers, visitors and staff.

Heritage sites

The requirement to collect contact details does not apply to unstaffed, unticketed heritage sites that are open to the public (for example, ruins or prehistoric sites) or archaeological and historic sites which are not open to the public.

Further education settings

If a venue within a further education college is open to the public, such as a caf or swimming pool, then that venue is required to collect details of customers, visitors and staff and to display an official NHS QR code poster.

These requirements are not applicable to these venues when they are accessed by students only.

Community centres and village halls

Community centres and village halls, which may host a variety of social, cultural and recreational activities, must collect information for all



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