GDPR v Coronavirus: Staying safe physically and electronically
As lockdown is relaxed this weekend and pubs are once again opening their doors, owners and managers not only need to get the contact details of their customers for tracing purposes, but they also need to data protection rules.
As you may recall, just over two years ago, new rules came into force governing to keep personal data safe- GDPR and privacy was a hot topic in May 2018. Fast forward two years and a pandemic later, and now pub and restaurant owners in particular are going to have to take from customers their contact details before they can be served. Whilst this is crucial if we are going to have any hope of stopping the virus, the information to be collected is personal data and that data will still have to be dealt with under data protection rules.
If in doubt, the ICO guidelines are helpful, but as an outline, good practice would suggest thinking about the following:
Only take the data that you need to take and nothing more.
If taking a written note of the information, make sure to keep it safe- this could be anything from being kept in a locked drawer to a locked safe or filing cabinet. Make sure that only certain people are key-holders. If the information is taken electronically, then be careful to protect the electronic information using password protection.
Make sure the data is destroyed after the necessary time- whatever the guidance time period is from the Government that that should be the length of time the information is kept and no longer. Regular management of destruction of the personal data therefore needs to be by in place, whilst a secure form of destruction, such as shredding for paper copies, is recommended.
It is also important that you do you not use the personal data for any purpose other than if required to provide it for track and trace purposes. There is a currently legitimate reason for handling the data for the safety of your customers, but it does not go beyond that reason.
You should notify your customers of what you are doing. You can do this verbally, or consider putting up signs in public areas advising that you are taking and storing personal data and why you are doing it.
If you would like to know more about Residential or Business Tenancies and Coronavirus (COVID19) please contact Joanne Davies by email: email@example.com or phone: 01543 420059