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

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The government has published the COVID-19 Response Spring 2021 setting out the roadmap out of the current lockdown for England. This explains how restrictions will be eased over time.

From 12 April 2021 some businesses are permitted to reopen.

The rules on what you need to do when a group enters your venue have changed. You must ask every customer or visitor to scan the NHS QR code using their NHS COVID-19 app, or provide their name and contact details, not just a lead member of the group.

This is to ensure that everyone receives the necessary public health advice in a timely manner.

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 every customer or visitor (over the age of 16) 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 the NHS COVID-19 app as an alternative to providing their contact details
  • adhere to General Data Protection Regulations (GDPR)

Hospitality venues have additional requirements and must also take reasonable steps to refuse entry to anyone who refuses to participate. What is reasonable will depend on the type of venue and context in question. The venue should satisfy themselves that they have done all that could reasonably be expected to refuse entry.

Failure to comply with 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 poster and display one at every entrance to your venue.

The NHS COVID-19 app has a feature that allows users to quickly and easily check in to your venue by scanning the code. 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 are 2 or more positive cases who have been in a venue on the same day, 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 code 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.


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 activities and events taking place within the venue. This should be collected by the person who hires the space. The venue must also display an official NHS QR code poster which can be used for every activity that takes place there.

Places of worship

Places of worship, including when the venue is used for events an

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