The government introduced its heritage reopening guidance in June 2020. As part of this guidance, museums and other sites across the hospitality sector (such as pubs, restaurants, hairdressers and barbers) are required to collect data to support the government’s track and trace programme. This is likely due to the length of time visitors will spend in these places of business.
Public Health England has published the Customer Logging Toolkit for track and trace. This contains a variety of template materials for businesses to display, as well as guidance on how it works. If a customer tells you they have tested positive for coronavirus, businesses should register their contacts with NHS Test and Trace and leave any follow up work with other customers to the local NHS Test and Trace team. If they assess that the customer was on your premises while potentially infectious, they will contact you to provide support and to obtain the details of anyone who may have been exposed to the virus.
The Government has announced that from 18th September, museums will also be legally required to log details of customers, visitors and staff for NHS Test and Trace.
From Thursday 24th September, museums will be required to display official NHS QR code posters under law ahead of the NHS COVID-19 app being rolled out nationally on 24 September.
The government has also issued new requirements for the Track and Trace system: https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace The obligations have now changed for when museums re-open. Organisations will now have to take contact details for everyone over 16 and not just the lead of the party (or they can use the Track and Trace App). This includes for events as well as general visits. You also now have a legal duty to take all reasonable steps to deny entry to any person that refuses to check in. You can find out more here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/the-visitor-economy#sec-1-5
For the latest information on changes to the Track and Trace system: https://www.gov.uk/guidance/nhs-test-and-trace-workplace-guidance
Services included in the new legal requirements are:
- Hospitality, including pubs, bars, restaurants and cafés;
- Tourism and leisure, including gyms, swimming pools, hotels, museums, cinemas, zoos and theme parks;
- Close contact services;
- Facilities provided by local authorities, including town halls and civic centres (for events), libraries and children’s centres.
- Businesses will be expected to make sure their customers are aware of the rules around QR codes by displaying posters and speaking to customers directly.
- If individuals choose to check-in using the NHS COVID-19 app QR code poster they do not need to log in via any other route.
- Information should be collected by the venue for those people that have not checked-in using the QR poster.
- There is a requirement for hospitality venues, including cafes and restaurants within museums (museum galleries themselves are except), to refuse entry to customers and visitors who do not provide the relevant contact details, or have not checked in with the QR code.
- All the visitors need to check in using the NHS app or with a paper Track and Trace system, with the exception of children. Rules are changes around this requirement so do check the latest government guidance.
- If a visitor refuses to check in (either on paper of digitally) then that person should be refused entry.
You can create your own QR poster here: https://www.gov.uk/create-coronavirus-qr-poster
Questions to ask yourself
- Have you considered how you might record visitor information to assist with Track and Trace?
- Is it possible to implement online ticketing as a way to manage the number of people on your site, as well as to collect this information?
- How much information do you need? Refer to the government guidance for the latest information on this.
- How long do you need to keep it for, and can you use it for only one purpose? What you use it for will need to be made clear to your visitors.
- How can you store this data safely?
- Some museums are struggling with staffing as large numbers have to self-isolate due to a ping from the track and trace app. Have you thought about your contingency plans if you don’t have enough people to open the museum? How will you get the message out to your visitors if that happens?
One small museum has provided a low-tech option:
‘We’ll have paper sheets (like our booking sheets) where the volunteer on duty on the door can take a contact name and either phone number or e-mail address for each person (or household contact if coming as a couple/family group etc) visiting. We will also note the time that they entered the Museum.
We’ll have separate clipboards for morning and afternoon shifts so there is no transmission between volunteers on duty.
Clipboards will be wiped down and cleansed as part of the end of day cleaning procedures so are sanitised for the next day’s users.
Paper records from that day will go in a secure file in the office and be retained for 21 days. They will not be held electronically.
They will only be shared with the NHS for track and trace purposes on request. After 21 days the paper files will be destroyed by being shredded and disposed of through confidential waste.
Accordingly, we reserve the right to refuse admission to the Museum on the following grounds:
- Any visitor who appears to have symptoms of Covid-19;
- Any visitor who does not keep to our social distancing regulations, even when asked;
- Any visitor who does not use hand sanitiser on entering the Museum;
- Any visitor who does not leave a contact name and either telephone number or e-mail when asked to maintain the test, track and trace regulations.
One other thing to add is that we’ll have a GDPR statement about why, how and what we’re doing on collecting this information on the form to answer any visitor enquiries, along with a printed copy for people to consult on display along with our other COVID procedural information in our foyer, and on our website (from next week when we go live with this).’
Stuart Orme, The Cromwell Museum, https://www.cromwellmuseum.org/
Government Heritage Reopening Guidance
NHS test and trace: how it works
Customer logging toolkit
Coronavirus Covid-19 NMDC Good Practice Guidelines on the Reopening of Museums after July 4, 2020 https://www.nationalmuseums.org.uk/media/nmdc_museums_guidelines_v.1.1_25_june_2020.pdf
Information on online ticketing through Art Tickets (a free system offered via Art Fund)
The Audience Agency’s information about online ticketing
GDPR and Track and Trace
Introduction to ticketing for museums and galleries
Customer Logging – A toolkit for businesses
NHS Maintaining Records of Staff, Customers and Visitor Logs FAQs
Maintaining records of staff, customers and visitors to support NHS Test and Trace
Hospitality Fact Sheet
Information on requirements to maintain records
Guidance on maintaining Test and Trace records