Salons and barbershops must, by law, keep a temporary record of clients’ contact details to help with the NHS ‘Test and Trace’ service. 

A number of wider questions have also come up about what to do if a client or team member tests positive for the virus or has symptoms. The following FAQs apply to England and explain: 

These FAQs apply to England. Read the government guidance for England. 

NHBF Members can listen to our webinar on this topic which explains how salons and barbershops are affected across the four nations. The webinar details how the different schemes work and also covers related employment law.

The guidance for Wales states that you should ask clients for each client’s contact details on the day of their appointment to help with the government’s ‘Test, Trace, Protect’ service. Find more details about this on the Welsh Government’s website.

Salons and barbershops in Scotland are being asked to gather ‘minimal contact details’ from clients to support the Scotland’s ‘Test and Protect’ service. This requirement is explained in more detail on the Scottish Government’s website

Northern Ireland operates a contact tracing programme. Salons and barbershops should assist this service by keeping a temporary record of clients and visitors in a way that is manageable for your business.

 

What client information do I need to record? 

The law says you must keep a temporary record of your clients and visitors for 21 days and assist NHS ‘Test and Trace’ with requests for contact information if needed.  Find out more about this legal requirement on the government website. 

When collecting and storing data you will need to comply with strict data protection regulations. Find out more.  

You will need to make a note of each client’s:

  • Name.
  • Phone number.
  • Time of arrival.
  • Time they left, where possible.
  • Who served them.

You’ll also need to record the dates and times that your team members are at work. 

The government has confirmed: 

  • You do not have to check the accuracy of the information that clients give or ask to see their ID.
  • You do not have to collect contact details from people who are only your site for a short time, for example, delivery people.
  • Records can be kept digitally or on paper.
  • You do not have to delete the information immediately after 21 days – this can be done when you normally delete unwanted data.

How does Test and Trace work? 

The government is encouraging everyone in England and Wales to download the recently launched COVID-19 app. Find out more on the government website

In England, individuals are required by law to self-isolate if they test positive or are contacted by NHS Test and Trace. Those breaking the rules will be fined up to a maximum of £10,000 for repeat offenders.

In addition, it is now an offence for an employer to knowingly permit a worker (including an agency worker) to attend any place other than where the individual is self-isolating. This includes individuals who are required to self-isolate because they live with someone who has tested positive.

This means that if you know your employee has tested positive (or lives with someone who has tested positive), it is now your responsibility to stop the worker from working (unless they can work from home). Any employer who fails to do so will face a fine, starting at £1,000.

There is also an obligation on the worker to tell their employer that they are self-isolating.

Anyone who tests positive for coronavirus must share information promptly about their recent contacts through the NHS Test and Trace service so that others who may need to self-isolate can be alerted. 

Individuals will be alerted by the NHS Test and Trace service if they have been in close contact with someone who has tested positive for coronavirus. The alert will usually come by text, email or phone call. Those who have been in close contact will be told to: 

  • Begin self-isolation for 14 days from the last contact with the person who has tested positive.
  • If they develop symptoms of coronavirus they must book a test and other members of their household must self-isolate immediately at home for 14 days. 

If your staff or clients are contacted, the NHS Test and Trace service and/or your local health protection team can provide further advice about what you should do next to protect your team and clients. You can find your local health protection team by entering your post code on this page of the government's website

Find more detailed information on the NHS website

Do I have to put a QR poster up in my salon or barbershop?

You must register for an official NHS QR code and display the official NHS QR poster from 24 September 2020.

The NHS COVID-19 app has a feature that allows users to quickly and easily ‘check in’ to your venue by scanning the code. The information stays on the user’s phone. In England, you do not have to ask people who choose to ‘check in’ using the official NHS QR code to provide their contact details. If there is an outbreak associated with a venue, a message will be sent to the relevant app users with the necessary public health advice. Find out more about this on the government website.

Is it compulsory for team members to download the Test and Trace app? 

No. Employees cannot be forced to download the app. You can recommend that they do so. 

If you have company phones, it’s best practice to download the app onto them. (However, bear in mind that the government has not produced any further updates on this and the guidance may change in the near future.) 

How do I deal with an outbreak (more than one case) in my salon or barbershop? 

The government guidelines that currently apply to England and Northern Ireland say: 

As part of your risk assessment, you should ensure you have an up-to-date plan in case there is an outbreak of coronavirus in your salon or barbershop. 

This plan should name the person who would be responsible for contacting your local health protection team where necessary. 

You may be informed of a confirmed case of COVID-19 by NHS Test & Trace, an employee, customer or your local Public Health England Health Protection Team (PHE HPT). When you are informed of more than one confirmed case, contact your local health protection team.

You can find your local health protection team by entering your post code on this page of the government's website

Download an Action Card from the government's website. This provides a step-by-step guide for salons and barbershops on how to manage an outbreak. Find out more about outbreak management and how the Action Cards can help.

Find out how the government plans to manage local outbreaks in England.

It is likely that the Test and Trace team will ask to see your risk assessment and the control measures that you have put in place to reduce the spread of the infection. It is therefore imperative to follow the government guidance on PPE (personal protective equipment), cleaning procedures and client management. These control measures must be clearly stated within your risk assessment and all members of staff must be trained and know how to follow them.  

What should I do if an individual member of staff develops symptoms of coronavirus after being in my salon/barbershop? 

If a worker develops symptoms, they should  request a free test as soon as their symptoms start. If symptoms start while they are at work they should be sent home.

Once they have ordered the test, they’ll be asked by the NHS Test and Trace service to provide details of anyone who they have been in close recent contact with. 

Anyone who has been in close contact with the affected team member does not need to take a test or self-isolate unless the NHS Test and Trace service asks them to do so – but they must avoid high-risk individuals and take extra care to ensure social distancing and good hygiene. 

If the person with symptoms tests positive for COVID-19, the NHS Test and Trace service will notify their close contacts and instruct them to self-isolate. 

If the person with symptoms needs clinical advice, they should go online to NHS 111 or call 111 if they don’t have Internet access. In an emergency, call 999 if they are seriously ill or injured or their life is at risk. They should not visit their GP, pharmacy, urgent care centre or a hospital. 

You can notify other employees that there has been a suspected case in your salon or barbershop, but do not identify the member of staff affected as this could breach strict data protection laws (GDPR). It may be difficult to conceal the identity of the team member who is affected if they are the only one off work. In this case, try to get the affected team member’s permission to pass on the information to the rest of the team. 

Make sure you are following stringent cleaning and hygiene routines and carry out additional cleaning after someone with symptoms has been in your salon or barbershop. 

What should I do if an individual member of staff tests positive for coronavirus after being in my salon/barbershop? 

If a staff member tests positive for COVID-19, the NHS Test and Trace service will notify their close contacts and instruct them to self-isolate. 

Make sure you are following stringent cleaning and hygiene routines and carry out additional cleaning after someone with coronavirus has been in your salon or barbershop. 

What should I do if an individual client develops symptoms after being in my salon/barbershop? 

Anyone who has been in close contact with the affected client does not need to self-isolate – but they must avoid high-risk individuals and take extra care to ensure social distancing and good hygiene. 

If the client tests positive for COVID-19, the NHS Test and Trace service will notify their close contacts and instruct them to self-isolate. 

If the person with symptoms needs clinical advice, they should go online to NHS 111 or call 111 if they don’t have Internet access. In an emergency, call 999 if they are seriously ill or injured or their life is at risk. They should not visit their GP, pharmacy, urgent care centre or a hospital. 

Make sure you are following stringent cleaning and hygiene routines and carry out additional cleaning after someone with symptoms has been in your salon or barbershop. 

If a client shows symptoms while in your salon, avoid standing within two metres of them. Ask them to leave and encourage them to go home and contact NHS 111. Clean any surfaces they have been in contact with.

What should I do if an individual client tests positive for coronavirus after being in my salon/barbershop? 

If the client tests positive for COVID-19, the NHS Test and Trace service will notify their close contacts and instruct them to self-isolate. 

Make sure you are following stringent cleaning and hygiene routines and carry out additional cleaning after someone with coronavirus has been in your salon or barbershop. 

Test and Trace has contacted me. What should I do? 

NHS Test and Trace will contact you if they need to see your client contact details. 

NHS Test and Trace will carry out an assessment and work with you to understand what actions need to be taken on a case-by-case basis. 

Depending on the circumstances and the length of time that has elapsed, this could include arranging for people to be tested, asking them to take extra care with social distancing and/or – in some circumstances – asking them to self-isolate. 

NHS Test and Trace will give you the necessary public health support and guidance. Your staff will be included in any risk assessment and NHS Test and Trace will advise them what they should do.

Are staff entitled to sick pay if they test positive or have to self-isolate? 

Your employee will be entitled to Statutory Sick Pay from day one of their illness or self-isolation plus any other contractual sick pay they may be entitled to. This also applies if an individual needs to shield. Find out more about Statutory Sick Pay rules on the government website. You can also check to see if you can claim back Statutory Sick Pay paid to employees due to coronavirus.

What if my employee’s child is sent home from school due to a coronavirus outbreak? 

If your employee’s child is sent home from school because of a coronavirus outbreak, your employee will have the right to a reasonable amount of emergency leave to deal with the situation. This is unpaid unless the employment contract states that emergency leave will be paid. 

A ‘reasonable amount of time’ must be judged on a case-by-case basis. Two days is often considered the norm, but a longer length of time may be considered reasonable during the current coronavirus outbreak. Your employee could also consider taking annual leave or you could agree a flexible working arrangement with them. NHBF Members can contact our legal helpline for expert advice with this. 

Parents of the child will not be considered as self-isolating unless the NHS has told them to self-isolate or they have symptoms or test positive.

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