Contact Tracing Register Template - Alert Level 2

13 May 2020

If anyone who has been at your premises or workplace is a suspected or confirmed case of COVID-19, you must be able to trace that person’s contacts. The key to being able to do this is your Contact Tracing Register.

At Alert Level 2, many retail businesses (including restaurants, cafes and cellar doors) are required have a Contract Tracing Register. This is in addition to the required Contact Tracing Registers for your workers that you would have used at other Alert Levels. More information about when the register is necessary is available in our guidance for Alert Level 2 operations

Below, we have prepared some example templates of Contact Tracing Registers that you may wish to use.  You can adapt these to suit your own business needs.

You should also consider the following:

  • Accuracy: How you’ll ensure the register is being used and maintained correctly.
  • Minimising shared surfaces: How you’ll prevent customers or staff from touching common surfaces, or using common equipment (eg pens and paper), in order to enter details. Where possible, you could have specified staff taking details verbally from people and writing them down. This will also address the privacy security concern noted below.
  • Location: Where the register will be located and who is best placed to enter the information.
  • Zoning: Whether you divide your workspace/premises into zones and limit movement between the zones.

More information is available on WorkSafe’s website here.

Privacy implications

As you will be collecting personal information about individuals, you need to ensure you comply with the Privacy Act. This includes the following:

  • Collection and consent: You need to let people know that you are collecting the information and what you are going to do with it. We have prepared a poster you can use at your entrance, letting people know that you will be running a Contact Tracing Register. As part of the information gathering process, you should let people know that the information may be provided to Government if requested for contact tracing purposes (the poster includes this notice).
  • Security: You need to keep the register secure. If you are using pieces of paper, these need to be stored securely and not accessible by anyone who does not need access. This also means not passing the register around to complete, so everyone can see each other’s details.
  • Access: If a person requests access to the information held about them, you need to respond to that request. More information on dealing with access requests is available here.
  • Deletion: You should delete the information when it is no longer required. At the time of writing, WorkSafe recommends this information be retained for at least two months.
  • Use and disclosure: Generally, you can only use the information for the purpose for which you got it. This means only providing it to the Government if requested for the purposes of contact tracing a confirmed or suspected case of COVID-19.

More information about the requirements of the Privacy Act is available on the Privacy Commissioner’s website here.

This is not a chance to freely add people to your mailing list. If you are collecting contact tracing information, you can generally only use it for contact tracing purposes. If you would like to sign people up to your mailing list, then you must ask them separately.

NZ COVID Tracer app

The Government has produced an app that people can voluntarily use to record their own movements. More information about the app is available here. You can also generate QR Codes for your workplaces or retail spaces that allow individuals to scan their movements into the app for storage on their personal phones.  

However, the app does not replace obligations you may have to keep contact tracing records. (More information is available above about who needs to do this). The app stores data only on each phone individually, and an individual's consent is required to release it upon request. Businesses must hold these records so the Government knows who was in the premises and who to may be a close contact requiring further investigation.

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