As more employees start to return to the workplace we thought the following track and trace guidance may be useful:

This link gives you guidance on Test & Trace in the workplace:

https://www.gov.uk/guidance/nhs-test-and-trace-workplace-guidance

  • There is guidance at this link that you may want to share with your employees
  • You should check back to this advice regularly as guidelines change as more information becomes known
  • There are specific guidelines at this link on who is defined as a “close contact” dependent on the closeness and duration of contact with another person with symptoms – it may include people who were in close contact two days before an employee developed symptoms
  • If an employee has symptoms and is awaiting test results close contacts do not always need to isolate but instead should be vigilant in practicing distancing and hygiene – if you wish to have a company policy that they go home you should inform staff of this
  • If an employee tests positive their close contacts will need to self-isolate but do not need to get a test unless they develop symptoms themselves
  • Employees who need to self-isolate should submit an isolation note
  • Employees in self-isolation are entitled to SSP if they meet the eligibility criteria and you may be able to reclaim the SSP
  • If you have more than one case in a workplace you should notify your local health protection team https://www.gov.uk/health-protection-team

This link gives you detailed information about the records you should keep, how long for & who you should share the information with:

https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace

  • Note that not all workplaces are required to keep records but if you choose to do so you should ensure you have informed employees of this
  • Note that if you take the temperature of employees, customers or visitors it is not recommended that you keep this data
  • You should consider what your policy will be if someone refuses to give the information you require
  • If you do take temperatures on arrival at premises you should also decide what your policy will be for anyone that refuses to have their temperature taken
  • The Gov website is recommending that you only hold data relating to any Covid infection control measures for 21 days

There is further information on the ICO website about protecting customer & visitor data:

https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/contact-tracing-protecting-customer-and-visitor-details/

  • You must comply with GDPR requirements for all Test and Trace / Covid related data you collect
  • There are several legal bases on which you can process data – consent is one of these but it is explicitly not required in most settings for all Test and Trace / Covid related data and is not applicable for collecting employee data relating to Covid
  • If there is a positive case in the workplace employers should not identify the individual to their colleagues but simply inform them if there is a need to self-isolate (although NHS Test & Trace should also do this)

This link gives a general overview of Test & Trace in all settings not just the workplace: https://www.gov.uk/guidance/nhs-test-and-trace-how-it-works

A reminder of the link to the HSE Covid guidance: https://www.hse.gov.uk/coronavirus/working-safely/index.htm

The link to get advice on getting a Covid Test https://www.nhs.uk/conditions/coronavirus-covid-19/testing-and-tracing/get-a-test-to-check-if-you-have-coronavirus/

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