Updated NHS Test & Trace Requirement

The Guidance for ‘Maintaining records of staff, customers and visitors to support NHS Test and Trace’ has been updated to include rules for businesses reopening on 12 April, and for entering a venue.


  • 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.
  • Failure to do any of these requirements could result in fixed penalty fines.
  • You must register for an official NHS QR code poster and display one at every entrance to your venue.
  • Sectors that this guidance applies to:
    • hospitality, including pubs, bars, restaurants and cafés
    • 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 here https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace
  • 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.
  • Information to collect:
    • Venues must ask every customer and visitor (over the age of 16) for the following details (unless they have ‘checked in’ using the NHS COVID-19 app):
      • the name of the customer or visitor
      • a contact phone number for each customer or visitor. If a phone number is not available, you should ask for their email address instead, or if neither are available, then postal address
      • date of visit, arrival time and, where possible, departure time
      • the name of the assigned staff member, if a customer or visitor will interact with only one member of staff (for example, a hairdresser). This should be recorded alongside the name of the customer or visitor
  • Everyone in a group must check in.  In line with new regulations, when a group enters a hospitality venue, every individual must check either by scanning the official NHS QR code poster with the NHS COVID-19 app, or by providing their contact details.
  • Recording both arrival and departure times (or estimated departure times) will help reduce the number of customers or staff needing to be contacted by NHS Test and Trace. We recognise, however, that recording departure times will not always be practicable and this is not required by law.
  • All designated venues must also keep a record of all staff working on the premises on a given day, the time of their shift, and their contact details. This covers anyone providing a service or activity including volunteers. Venues must keep these records of staff, but staff can choose to check in using the NHS QR code poster in addition, if they wish.
  • Collecting contact details and maintaining records for NHS Test and Trace is a legal requirement and failure to comply is punishable by a fine:
    • first fixed penalty: £1,000
    • second fixed penalty: £2,000
    • third fixed penalty: £4,000
    • any further penalty notice: £10,000
  • The person responsible for the organisation is liable. This could be the owner, proprietor or manager with overall responsibility of the organisation, business or service.
  • NHS Test and Trace or Public Health Officers will ask for these records only where it is necessary. For example, when two or more people who later tested positive for COVID-19 visited your premises on the same day.
  • If you are asked to provide these records you must share them with NHS Test and Trace straight away. You are legally required to share this information as soon as possible – you must not delay.
  • If you are contacted by NHS Test and Trace, contact tracers will:
    • call you from 0300 013 5000
    • send you an email containing a template spreadsheet and a secure link to upload your logbook to the secure Egress system
  • Local contact tracers may contact you from a different phone number or ask you to call them back. If you are unsure if the telephone number is genuine, check with your local council.
  • Contact tracers will never:
    • ask you to dial a premium rate number to speak to them (for example, those starting 09 or 087)
    • ask you to make any form of payment or purchase a product or any kind
    • ask for any details about your bank account
    • ask for your social media identities or login details, or those of your contacts
    • ask you for any passwords or PINs, or ask you to set up any passwords or PINs over the phone
    • disclose any of your personal or medical information to your contacts
    • ask about protected characteristics that are irrelevant to the needs of NHS Test and Trace
    • provide medical advice on the treatment of any potential coronavirus symptoms
    • ask you to download any software to your PC or ask you to hand over control of your PC, smartphone or tablet to anyone else
    • ask you to access any website that does not belong to the government or NHS

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