NHS Test and Trace
Since 18 September 2020, hair salons in England
have been required by law to keep a temporary record of clients and visitors
for 21 days and assist NHS ‘Test and Trace’ with requests for contact
information if needed. Our appointment booking system already accommodates the
requirements we need to meet, and we are ready to assist the NHS and our clients
As of 24th September 2020, all salons must also display the
official NHS QR poster in the premises for all clients and staff to use with
their NHS COVID-19 app. This is in addition to the client details we already
collect as part of our appointment booking software and how we already assist
NHS Test and Trace.
We will be displaying the QR poster at reception and at each
styling station, so it is easy for clients to “check in” by simply scanning the
QR code on their phone. You will need to download the NHS COVID-19 app, which
is available for both Apple and Android users (it looks as though the app is
still only usable for those with an invitation code in the “trial areas”, but
we suspect it will become available for everyone from tomorrow or over the next
All collected data remains on your phone and complies with
GDPR legislation. Your contact details will only be shared with NHS Test and
Trace if it is requested. Our Privacy Notice is available below.
If you do not have a smartphone or the NHS COVID-19 app, the
information we need to book you an appointment will still be used to assist NHS
Test and Trace if needed, however, it is advised that you use the NHS COVID-19
app to scan the available QR code to help the NHS Test and Trace quickly
and effectively contact everyone who may
have been exposed to the virus during an outbreak and to provide the
appropriate public health advice. This will help to stop the onward spread of
the virus by quickly informing anyone who has been in contact with the virus to
isolate where needed.
Recording customer details: how we use your information
To support NHS Test and Trace (which is part of the
Department for Health and Social Care) in England, we have been mandated by law
to collect and keep a limited record of staff, customers and visitors who come
onto our premises for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and
sharing these with NHS Test and Trace where requested, we can help to identify
people who may have been exposed to the coronavirus.
As a customer/visitor of In To Change Hair Salon you will be
asked to provide some basic information and contact details. The following
information will be collected:
the names of all customers or visitors, or if it is a group
of people, the name of one member of the group
a contact phone number for each customer or visitor, or for
the lead member of a group of people
date of visit and arrival time and departure time
The salon as the data controllers for the collection of your
personal data, will be responsible for compliance with data protection
legislation for the period of time it holds the information. When that
information is requested by the NHS Test and Trace service, the service would
at this point be responsible for compliance with data protection legislation
for that period of time.
The NHS Test and Trace service as part of safeguarding your
personal data, has in place technical, organisational and administrative
security measures to protect your personal information that it receives from
the salon, that it holds from loss, misuse, and unauthorised access,
disclosure, alteration and destruction.
In addition, if you only interact with one member of staff
during your visit, the name of the assigned staff member will be recorded
alongside your information.
NHS Test and Trace have asked us to retain this information
for 21 days from the date of your visit, to enable contact tracing to be
carried out by NHS Test and Trace during that period. We will only share
information with NHS Test and Trace if it is specifically requested by them.
For example, if another customer at the salon reported
symptoms and subsequently tested positive, NHS Test and Trace can request the
log of customer details for a particular time period (for example, this may be
all customers who visited on a particular day or time-band, or over a 2-day
We will require you to pre-book appointments for salon visits
and provide the relevant information at the time of booking.
Under government guidance, the information we collect may
include information which we would not ordinarily collect from you and which we
therefore collect only for the purpose of contact tracing. Information of this
type will not be used for other purposes, and NHS Test and Trace will not
disclose this information to any third party unless required to do so by law
(for example, as a result of receiving a court order). In addition, where the
information is only collected for the purpose of contact tracing, it will be
destroyed by us 21 days after the date of your visit.
However, the government guidance may also cover information
that we would usually collect and hold onto as part of our ordinary dealings
with you (perhaps, for example, your name, email address and phone number).
Where this is the case, this information only will continue to be held after 21
days and we will use it as we usually would, unless and until you tell us not
Your information will always be stored and used in
compliance with the relevant data protection legislation.
The use of your information is covered by the General Data
Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a hair
salon are subject to. The legal obligation to which we’re subject, means that
we’re mandated by law, by a set of new regulations from the government, to
co-operate with the NHS Test and Trace service, in order to help maintain a
safe operating environment and to help fight any local outbreak of corona
We do not transfer personal data outside the UK, the EU or
to anywhere else.
By law, you have a number of rights as a data subject, such
as the right to be informed, the right to access information held about you and
the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data
about you that we hold (although this is not an absolute right).
You have the right to request that we restrict processing of
personal data about you that we hold in certain circumstances.
You have the right to object to processing of personal data
about you on grounds relating to your particular situation (also again this
right is not absolute).
If you are unhappy or wish to complain about how your
information is used, you should contact a member of staff in the first instance
to resolve your issue. Please contact Laura-Jayne Lundy, who is the data
protector officer of In To Change Hair Salon.
If you are still not satisfied, you can complain to the
Information Commissioner’s Office. Their website address is www.ico.org.uk.
We keep our privacy notice under regular review, and we will
make new versions available on our privacy notice page on www.intochangehairsalon.co.uk This privacy notice was last updated on 23
If you have any questions or concerns, please don’t hesitate
to contact the salon during our opening hours by telephone on 0191 477 4693 or