Coming Out Of Lockdown - Data Protection Issues For Charities And Community Groups

• Published date: 13 July 2020
• Subject Matter: Privacy, Data Protection, Privacy Protection
• Law Firm: Veale Wasbrough Vizards
• Author: Penny Bygrave

In line with government guidance for the retail and hospitality sectors, and the re-opening of public places, all public facing organisations are being asked to collect personal data about visitors.

This is for the purpose of assisting NHS Test and Trace with data if it is needed for contact tracing and the investigation of local outbreaks.

Government guidance provides that: "The opening up of public places following the COVID-19 outbreak is being supported by the NHS Test and Trace service. ... you should assist this service by keeping an accurate temporary record of visitors for 21 days".

If you are providing public-facing services, this guidance applies to you. If you are collecting personal data you must comply with data protection laws, even if you are a not-for-profit or community group.

Data protection law permits you to collect personal data for legitimate purposes (in this case the legitimate purpose is supporting NHS track and trace), provided you do so in accordance with the data protection principles. This means:

• only collect what you need (name contact details and date and time of their visit)
• only use it for the...