IMPORTANT: Maintaining records of staff, customers and businesses

Guidance has been issued on collecting details and maintain records of staff, customers and visitors to businesses that are due to open from 4 July in England. The requirement to collect this data applies to:

  • hospitality, including pubs, bars and restaurants (it does not apply to businesses operating a takeaway/delivery only basis)
  • tourism and leisure, including caravan parks 
  • close contact services, including hairdressers, and others as defined here

This guidance 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, e.g. a takeaway outlet. If a business offers a mixture of a sit-in and takeaway service, contact information only needs to be collected for customers who are dining in. It does not apply to drop-off deliveries made by suppliers.

Read Guidance on Maintaining Records.

The data that needs to be collected is:

Staff

  • The names of staff who work at the premises.
  • A contact phone number for each member of staff.
  • The dates and times that staff are at work.

Customers and visitors

  • The name of the customer or visitor. If there is more than one person, then you can record the name of the ‘lead member’ of the group and the number of people in the group.
  • A contact phone number for each customer or visitor, or for the lead member of a group of people.
  • Date of visit and arrival and, where possible, departure time.

If a customer interacts with only one member of staff, the name of the assigned staff member should be recorded alongside the name of the customer If you have a large booking, for example, at a restaurant, you only need to collect the name and contact phone number of the lead member of the party. This data needs to be kept for 21 days.

The Customer Logging Example can be found here along with the FAQ Maintaining Records of Staff Customers and Visitors for NHS Test and Trace which contains information about record keeping of staff and visitors for test and trace, including:

  • How to collect/store the data
  • GDPR implications
  • What to do if someone refuses
  • What will happen if you are contacted by the Test and Trace service

The ICO has also published a statement and a short data protection ABC checklist on customer logs:

Supporting BEIS workplace guidance can be found here: Published guidance for employers, employees and the self-employed.