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The Information Commissioner’s Office has issued guidance to businesses collecting personal data for contact tracing.
The ICO guidance encourage business to follow our five simple steps to help ensure that data protection is not a barrier to your recovery:
Ask for only what’s needed
You should only ask people for the specific information that has been set out in government guidance. This may include things like their name, contact details and time of arrival for example.
You should not ask people to prove their details with identity verification, unless this is a standard practice for your business, eg ID checks for age verification in pubs.
Be transparent with customers
You should be clear, open and honest with people about what you are doing with their personal information. Tell them why you need it and what you’ll do with it. You could do this by displaying a notice in your premises, including it on your website or even just telling people.
If you already collect customer data for bookings, you should make it clear that their personal data may also be used for contact tracing purposes.
Carefully store the data
You must look after the personal data you collect. That means keeping it secure on a device if you’re collecting the records digitally or, for paper records, keeping the information locked away.
Don’t use it for other purposes
You cannot use the personal information that you collect for contact tracing for other purposes, such as direct marketing, profiling or data analytics.
Erase it in line with government guidance
You should not keep the personal data for longer than the government guidelines specify. It’s important that you dispose of the data securely to reduce the risk of someone else accessing the data. Shred paper documents and permanently delete digital files from your recycle bin or back-up cloud storage, for example.
Deputy Chief Executive Paul Arnold said:
“For the public health benefits to be realised from these new measures it is important people feel able to share their personal data with confidence. So people can have this trust and confidence in the way their personal data will be kept safe and used properly as they prepare to return to their favourite pubs, restaurants and local businesses, we want to help businesses to get things right first time as they adapt to new ways of working.
“We’ve published ICO advice - clear, simple steps that businesses can take as they introduce customer and visitor records. And we’ll be supporting government guidance with a series of Q and As on our coronavirus online hub that will give more detail. We also have a team of experts offering advice and support through our small business helpline.
“We appreciate the challenge that many small businesses face in introducing unfamiliar arrangements at speed. Our focus is on supporting and enabling them to handle people's data responsibly from the outset and, while we will act where we find serious, systemic or negligent behaviour, our aim is to help the thousands of businesses that are doing their best to do the right thing.
“We’ll continue to update our guidance on this and other coronavirus-related data protection issues on our dedicated web hub.”