Our customers include a number of the UK’s leading pub and restaurant management companies and we have been discussing with them how they can most effectively support the UK’s Government’s data retention requirements for Covid-19 track and trace - Government Track and Trace Data Retention Guidance.

The Government stipulates that you should “keep a temporary record of your customers and visitors for 21 days, in a way that is manageable for your organisation”. This may be a simple requirement for single venue pubs and restaurants, but how do you ensure this data is appropriately stored, protected and deleted when you have 100’s of establishments across the country (and beyond)? Given this type of personal data is covered by the General Data Privacy Regulation (GDPR) and the implications of mismanaging this data is significant.

I thought it would be useful to share some of the considerations and measures being taken to ensure the data is effectively managed.

There are already many instances of misuse of the track and trace data either through employee ignorance of the privacy regulations, or outright wilful abuse. Whether its companies using the data for marketing purposes, or serving staff personally contacting female customers through their contact details, there needs to be better control of this data.


It is important to remember that you not only have to gain consent to store data, but also state the specific purpose it will be used. The tweet above illustrates a pretty minor infringement, but we need the ICO to demonstrate a less passive and ineffectual approach to building awareness and policing businesses’ obligations under GDPR.

The ideal approach to meeting this Government requirement is for the data to be stored and managed centrally. This will enable appropriate encryption, access control and automated deletion processes. Whilst there is nothing that says the data can’t be held in a local paper-based bookings calendar (as traditionally has been the case for smaller businesses), deleting and restricting access to the data is difficult in these circumstances. Indeed, a corporate Data Protection Officer (DPO) would find it difficult to ensure compliance with GDPR.

The Government’s requirement for companies to store this data should be seen as an opportunity rather than an overhead. Leveraging strong data privacy practices as a company differentiator and demonstrating transparency with your customers on how their data is treated will be a great selling point at a time when the trading environment is extremely challenging.

Our customers, just by the very nature that they use eSpyder to manage their GDPR compliance are among the very best companies in the UK for effectively managing personal data and minimising the cost of managing and reporting on compliance. Incorporating this temporary data retention requirement into their on-going operations is easier than for a majority of companies. That said now is the ideal time to get your Data Privacy operations fit for the most challenging trading environment in living memory.

Agility is going to be the key to survival and this albeit minor requirement, highlights how effectively managing the customer data you hold will be a critical success factor. Managing personal data can be time-consuming, costly and frankly, not a core business activity. Reducing those costs and resource commitments whilst enhancing your company’s reputation with customers will greatly benefit the company’s business growth and profitability.
I would love to hear your thoughts or discuss your company’s situation. Please feel free to start reach out to me at Chat .

The General Data Protection Regulation (GDPR) came into force in May 2018 and in the subsequent 2 years, UK companies have not only had to ensure they are compliant with GDPR, but also prepare for Brexit and more recently adapt their businesses to working under Covid-19 restrictions.


It’s fair to say that many organisations of all sizes were not ready to manage their obligations under GDPR by the May 24th 2018 deadline and whilst most companies reviewed their data processing policies and business processes, there was still a huge challenge in terms of identifying where personally identifiable information (PII) resided in their systems. Which limited the effectiveness of the compliance measures they were trying to establish. Further-more a majority of companies still struggle to track and protect PII on an on-going basis.

One major barrier to gaining visibility to sensitive data is that there are a myriad of IT and business systems with their own individual data stores. Also, many users transfer data to their local machines from secure corporate data stores, often with the best intentions of working efficiently offline or from remote locations such as their homes.

Another major challenge is that the Data Owners and Data Protection Officer (DPO) are typically business executives rather than IT and whilst they are the people who need to ask questions of what Data is being held and where, for example in response to a data Subject Access Request (DSAR), they are wholly reliant on IT staff to provide the results. This is costly and time-consuming for both the business stakeholders and the IT department. It also significantly hampers business agility, which has been crucial for companies in the current Covid-19 crisis where businesses had to develop new business practices to continue trading.

Understanding with confidence where the companies’ sensitive data is stored and who can access it, is the foundation and starting point for an effective Data Protection capability. When adopting a maturity model as below, you cannot progress beyond level 1 without completing the initial discovery and then implementing an ongoing tracking and search capability.

 

Once a company knows where their data resides and can ensure it is appropriately controlled and protected, they will gain significant business benefits beyond just GDPR compliance.

  • It greatly reduces costs associated with managing data protection and management.
  • It saves time and limits the resource required to gain visibility and control over data.
  • It increases business agility through both the time-savings and the reduction of risk in implementing new business models and services.
  • Improves customer service and brand reputation through rapid responsiveness to DSARs and demonstrable care and respect for customer’s data and privacy.