Contact-Tracing Update

From 1 February 2022, it is no longer necessary for organisations to collect and keep information for contact-tracing purposes: the Government of Jersey no longer requires organisations whose activities have the potential for people to be within 2 metres of each other for longer than 15 minutes, to ask for contact information from patrons, for the purposes of supporting its contact-tracing efforts or to keep such information for 21 days.

Instead, Islanders who test positive will be advised to notify the individuals they have been in contact with and advise them to start 10 days of LFT tests. It will also remain possible to notify close contacts via the Jersey COVID Alert proximity app.

In light of this change, organisations should:

1. Review all information collected for contact-tracing purposes and dispose of information in a secure manner (e.g. shredding paper documents as opposed to disposing of them in public refuse bins, and ensuring permanent deletion of electronic files).
2. Review any privacy policies/processing statements if they had previously been amended to include reference to the collecting and holding of information for contact-tracing purposes.
3. Ensure that information collected for contact-tracing purposes is not repurposed and used for something else (e.g. contact details added to a marketing list).
4. Provide updated training for any staff so that they know they no longer need to collect visitor information for contact-tracing purposes.
5. Remove any posters, flyers or notices from areas frequented by visitors that referred to the need to collect information for contact-tracing (e.g. remove any notices containing QR codes that had been made available to visitors to scan as part of their visit).
6. Disable any contact tracing software they might have installed.

Organisations that have concerns or questions about how to collect and store personal data under the Law, or individuals who have questions about what is happening to their personal information and how to exercise their individual rights under the Law, should contact the Jersey Office of the Information Commissioner (JOIC) team via enquiries@jerseyoic.org or by calling the JOIC office on 01534 716530.

Further data protection guidance is also available at https://www.jerseyoic.org/resource-room/