The Government has requested that Churches in England assist the NHS Test and Trace service by keeping an accurate temporary record of visitors to church premises for 21 days.
This request by the Government for the Church to collect personal information about visitors to our premises in England, and to share this with the NHS Test and Trace service (in the event of possible infection), raises immediate concerns about data protection. The ICO has in the last day or so produced much anticipated guidance on the data protection implications. Hot on the heels of the ICO’s guidance TMCP has produced a new Focus Note to help Managing Trustees understand what steps they need to take to comply with this request and how to ensure compliance with data protection legislation.
Managing Trustees who will be welcoming visitors into their buildings from 4th July 2020 are asked to urgently review the following guidance and resources:
- "Test and Trace", Data Protection and What you need to do Focus Note – with a Test and Trace Five Step Plan for Managing Trustees to follow to keep the information in their record safe and compliant with data protection legislation.
- Template Methodist Church Test and Trace Record developed by TMCP and Property Support.
Please refer to Section D of the "Test and Trace", Data Protection and What you need to do Focus Note for details about how to use the Test and Trace Record and Section C for how to keep the information safe.
The new "Test and Trace", Data Protection and What you need to do Focus Note and template Methodist Church Test and Trace Record can be accessed from the Data Protection and COVID-19 pages on TMCP’s website respectively and should soon be available from the Methodist Church website.
It is likely that the Test and Trace Record and suggested procedures will need to be developed over time to take account of additional Government information and guidance on exactly what is needed to make the NHS Test and Trace system work. In the meantime, please let us have your comments and suggestions so that we can also take these on board in developing a record and process that is as helpful as possible for Managing Trustees and takes account of the responsibilities under data protection legislation. Please contact TMCP Data Protection.
Please contact TMCP Data Protection if you have any queries in relation to the data protection implications of the Test and Trace Record, TMCP and Property Support for guidance on using the Test and Trace Record and Property Support for guidance on opening our church buildings generally.