Coronavirus Test and Protect guidance on collection of customer and visitor contact details

Support provided by Scottish Government

What does this involve?

The Scottish Government has issued guidance on how to collect customer and visitor contact details to assist with NHS Scotland’s Test and Protect coronavirus (COVID-19) contact tracing system.

This data should be gathered by businesses and other establishments in Scotland where the nature of the premises means there may be an increased risk of transmission of COVID-19 due to a higher degree of interaction between unknown individuals. This measure will form part of the national effort to suppress COVID-19, and support Scotland to return to a more normal way of life.

The Scottish Government has updated the guidance in advance of reopenings during April 2021 to request the collection of the name and contact details for every visitor to premises.

This will help create consistency across the range of settings where this is requested or mandated in Scotland, and also help ensure that relevant data is captured to assist the Test and Protect contact tracing service.

The guidance sets out key actions and information around the collection of customer and visitor data as restrictions relating to the COVID-19 pandemic are eased.

Topics include:

  • an introduction to how the Test and Trace system works
  • which businesses and establishments should collect contact details
  • how to determine if your organisation needs to register with the Information Commissioner’s Office (ICO)
  • collecting and handling data in a way that’s compliant with data protection laws
  • how to collect, store and dispose of data securely
  • how the data will be used
  • useful tools and resources

The main guidance is in the form of an 11-page PDF file (194.8 kB).

Additional resources include a sample privacy notice and information posters which you can download and print.

What does this cost?

This is a free service.

Who is this for?

This guidance applies to any establishment or operator in sectors that provide an on-site service or work in other people’s homes to deliver a service. This includes, but is not limited to:

  • Hospitality, including restaurants, cafes, and pubs, as well as hotels and other accommodation providers
  • Tourism and leisure, including theme parks, museums and cinemas
  • Close contact services, including hairdressers, barbers, beauticians, tattooists, sports and massage therapists, dress fitters, tailors and fashion designers
  • Facilities provided by local authorities, such as libraries, leisure centres and registration offices
  • Cremation authorities, burial authorities, places of worship or funeral director service rooms offering funeral services
  • Places of worship which are reopening for congregational services and communal prayer or contemplation

It does not apply where services are taken off-site immediately - for example, a library operating a click-and-collect service, or a food outlet which only provides takeaways. If premises offer a mix of on-site and collection services, contact information only needs to be collected for customers who remain on-site.

There is separate guidance on collecting contact details in hospitality settings, where it is mandatory and not simply advised that you collect visitor contact details. 

Important information

The Protect Scotland app from NHS Scotland’s Test and Protect is a free, mobile phone app designed to reduce the spread of coronavirus and avoid further lockdowns.

The app will alert you if you have been in close contact with another app user who tests positive for coronavirus. And if you test positive, it can help in determining contacts that you may have otherwise missed while keeping your information private and anonymous.

Next steps

Visit the Scottish Government website to download the full guidance and related resources.


Support provided by Scottish Government

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