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ICO guidance to businesses collecting personal data for contact tracing

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The ICO has published guidance for businesses that will be asked to record and maintain personal data upon reopening. Certain businesses will need to collect and process data relating to customers, staff and visitors in support of the Covid-19 test and trace scheme. For many, this will be a challenge, which is why the ICO has issued guidance to assist with collecting customers’ and visitors’ personal information for the first time. The guidance encourages following its “five simple steps”:

1. 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, e.g. ID checks for age verification in pubs).

2. 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.

3. 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. There are some basic security measures for collecting customer and visitor details:

  • Lock it away when not in use
  • Brief staff on their responsibilities
  • Be extra vigilant about opening web links and attachments in emails or other messages
  • Use strong passwords for digital devices.

More details of these security tips from the ICO can be found here.

4. 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.

5. 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.

The ICO says “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”.

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