As many businesses reopen to the public following the COVID-19 lockdown, the Information Commissioner's Office (ICO) has provided guidance to help them comply with data protection regulations when collecting customers' and visitors' information for contact tracing purposes. Noting that many organisations will not have collected such information before, the ICO outlines five steps to ensure that this is done in a way that does not fall foul of the law:

  • Ask only for what's needed – You should only ask customers for the information set out in government guidance, for example their name and contact details and the time they arrived. People should only be asked to prove their details using identity verification if this is standard practice for your business.
  • Be transparent with customers – You should be clear, open and honest about what the information you collect will be used for. If you already collect customers' details (e.g. for bookings), you should be clear that this information may also be used to support contact tracing.
  • Carefully store the data – For digital records, this means ensuring they are stored securely. Paper records should be locked away when not in use.
  • Don't use it for other purposes – If you collect customer details for contact tracing purposes, you cannot use them for anything else (e.g. direct marketing or data analytics).
  • Erase it in line with government guidance – Personal data should be deleted when it is no longer needed. In this case, information collected for contact tracing reasons should not be kept longer than the government guidelines specify. Ensure you dispose of both physical and digital data securely.

More detailed guidance can be found on the ICO's website at

Contact Roy Colaba  or a member of our commercial team for advice on any data protection law matter.

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