Following the launch of the NHS Test and Trace app on 24 September 2020 and Managing Trustee comments on the application of our Test and Trace guidance in practice, we have updated the “Test and Trace Data Protection and What you need to do Focus Note”, updated the FAQs included in our previous “Test and Trace – A Further Update article” and included these in the Focus Note so that the guidance is all in one place.

Please refer to the updated Test and Trace, Data Protection and What you need to do Focus Note.

Requirements to display a QR Code and have a system in place to keep a temporary Test and Trace record

Although not yet a legal requirement for places of worship, it is strongly encouraged by the Government, by NHS Test and Trace and by the Methodist Church for Managing Trustees to ensure that they have a system in place to keep a temporary Test and Trace record, share the information with NHS Test and Trace and display a QR Code poster.

As recommended in our previous “Test and Trace” – A Further Update article, it is strongly recommended that Managing Trustees review the systems they have in place to record who has been in the building and when, and ensure that the existing records enable them to provide contact details to NHS Test and Trace if requested. If you do not yet have a system in place or are aware of chapels in your Circuit who do not have a system in place please ask them to contact TMCP Data Protection or Property Support so that we can assist them.

Local Churches in Wales and Scotland


Please note that Local Churches in Wales and Scotland are expected to follow TMCP’s Test and Trace data protection guidance where applicable, adapted to the particular requirements in Wales and Scotland. Please note that the NHS QR Code guidance does not apply in Scotland (although it is applicable to Methodist buildings in Wales) which has its own “Test and Protect” programme and "Check-in Scotland" QR code system. For Local Churches in Wales, please refer to the Welsh Government’s guidance on “Test, Trace and Protect”.

Updated “Test and Trace” Focus Note

Please refer to the updated guidance in our Focus Note, "Test and Trace, Data Protection and What You Need to Do" which is intended to help Managing Trustees put a system in place that both enables Managing Trustees to collect the information they need to help NHS Test and Trace (if called upon to do so) and comply with their data protection responsibilities. The Focus Note has been updated to confirm that Managing Trustees can enlist the help of their third party user groups/licensees to assist in putting in place a system that works in buildings where there are a large number of third party users, and where due to COVID restrictions or otherwise, insufficient resources are available to enable Managing Trustees to run the system themselves. (Please see Section F of the Focus Note, Q.1 in particular.)

Where Managing Trustees have obtained guidance direct from NHS Test and Trace that states, contrary to Government guidance elsewhere, it is acceptable for third party users of church premises to each have their own QR Code rather than there being one for the whole venue, then Managing Trustees can consider the updated guidance and either continue with one QR Code as per our existing guidance and best practice or request that their third party users apply for and display their own QR Codes and keep their own records. Please refer to Sections C and F of the updated "Test and Trace, Data Protection and What You Need to Do" Focus Note

Share your experiences with us

We have been contacted by many Managing Trustees who have put in place their own systems based on the guidance provided by TMCP, including nominating a steward to keep the record while the building is open and asking visitors to complete details taken from the record on individual cards which are then posted into a ballot box. Speak to your Circuit to see how other chapels in your Circuit are collecting and storing this information and ensure that your system is in accordance with the “Data Protection Five Step Plan” set out in Section C of TMCP’s Test and Trace Focus Note. These systems make a lot of sense from a “COVID safe” perspective; no shared pens/forms and reduce the risk of personal information being seen by others.

Please continue to let us have your comments and suggestions so that we can 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 also contact TMCP Data Protection if you are contacted by NHS Test and Trace so that we can ensure the guidance reflects what you are asked to do in practice.


Please contact TMCP Data Protection if you have any queries in relation to the data protection implications of the Test and Trace Record, TMCP Legal for guidance on using the Test and Trace Record and Property Support for guidance on risk assessments and opening our church buildings generally.