This updated guidance is aimed at VCS organisations that are starting to re-open following the COVID-19 lockdown. It was prepared by Tower Hamlets Council and published on 13th May 2021.
On 22nd February this year, the Government published COVID-19 Response – Spring 2021. This new documentation lays out the principles for easing the lockdown, the four tests that will apply, and the roadmap for reopening. We are now at Step 3 of the Roadmap:
Step 3 – 17th May 2021:
From 17th May a range of further settings, including indoor settings, will be permitted to open. Unless a specific exemption exists, rules around social contact still apply. Contact should be limited to a group of 6 people or 2 households indoors or in a group of no more than 30 people outdoors.
Government guidance states that “At this step, both outdoor and indoor gatherings or events, organised by a business, charity, public body or similar organisation, can be organised, subject to specific conditions: that they comply with COVID-Secure guidance including taking reasonable steps to limit the risk of transmission, complete a related risk assessment; and ensure that those attending do not mix beyond what is permitted by the social contact limits (unless another exemption exists, such as for organised sport or exercise, supervised activities for children or a significant life event).”
- The ‘rule of six’ will be abolished for outdoor gatherings, replaced with a limit of 30 people
- Indoor events can run with up to 1000 people or 50% capacity
- Hospitality venues will be able to open under ‘rule of 6’ guidance
- Indoor entertainment, including theatre, concerts, film screenings and sports matches can take place, subject to social distancing
- The requirement for groups to stay seated in social or entertainment spaces (e.g. table service principles, to limit mixing of groups) will remain
- Up to 30 people will be able to attend weddings, receptions, funerals, and wakes
Please check the official Guidance on reopening businesses and venues and Guidance for the safe use of multipurpose community facilities for more detailed information.
Step 4 – 21st June
Progression to Step 4 will be subject to a review of social distancing measures, and will happen no earlier than 21st June.
- All legal limits on social contact will be removed
- Remaining settings (including nightclubs and large events) can reopen
Managers of community facilities will have discretion over when to open for any activity permitted by legislation. You may decide to remain closed if you are not able to safely follow the relevant guidance and make your space COVID secure.
Many community facilities are also workplaces, so managers should also be aware of their responsibilities as employers and check the ‘Working Safely During Coronavirus’ guidance. No one is obliged to work in an unsafe workplace.
Organisations also have a duty of care to volunteers are afforded the same level of protection as employees and the self-employed. See government information on volunteering during coronavirus.
Whether your organisation manages its own premises or hires out space in a community building, the decisions and responsibilities around safe re-opening should be taken by your team and board based on your own particular circumstances, facilities, concerns and clients.
This guidance covers:
- Risk Assessment 3
- Deciding When and How to Reopen. 4
- Returning to Work. 5
- Cleaning and Hygiene. 6
- Social Distancing. 7
- Face Coverings. 9
- 7. Test and Trace. 10
- If Someone Tests Positive for COVID-19. 13
1. Risk Assessment
As you consider re-opening or adapting your services, you will need to conduct a risk assessment for your work setting in line with government guidance. The Health and Safety Executive has advice on how to do this including a .
- Make sure the right people are involved in the risk assessment process, e.g. trustees, senior team, staff, volunteers, services and building users.
- The risk assessment should help you to compare the risks of staying closed vs. opening. Be aware that 1 in 3 people who have coronavirus have no symptoms and will be spreading it without realising it. If you decide to re-open your building and/or start running activities in person you should therefore consider which activities are essential and which need to stay suspended.
- Check the Coronavirus restrictions: What you can and cannot do guidance carefully and take them into account in your risk assessment and decision making.
- Your risk assessment should consider the risk of people (whether members of the public, service users, or members of your team) mixing or being unable to maintain social distancing when they come to your venue.
- Check if any changes you make will impact on your insurance cover. You may need to contact your insurers to discuss this.
- A fire risk assessment should be undertaken if you decide to operate indoors and your building or space is repurposed, for example when there is any change in the way you use the space or to exit arrangements.
- Where possible, share your risk assessments with any other tenants in your building. Make sure the risk assessment is communicated to all of your own team and to other building users.
- It is important to note that the COVID-19 secure requirements are part of UK law, and that fines of up to £10,000 can be issued for repeated breaches.
2. Deciding When and How to Reopen
Your risk assessment will help you to decide whether you are ready to re-open your building, how your services might need to change, and what you will need to do in order to re-open safely.
- Where possible, consult with your client group and community to find out what people are likely to need from any re-opened services and how confident they are about coming back to your building.
- Community facilities following COVID-19 Secure guidancemay be exempt from mixing rules if they are hosting people ‘for work, or the provisions of voluntary or charitable services’. We advise organisations to think carefully about whether they would designate themselves as a service, and wherever possible to follow the above measures to protect the population.
- Consider how ongoing concern about coronavirus and the restrictions on group sizes and mixing might affect the quality of your services. If the quality and effectiveness of your activities are likely to be reduced, it might be more appropriate to delay reopening and focus on other delivery methods.
- Consider whether reopening would disadvantage any of the service users – for example, where switching a service from online to in person might leave out those unable to attend. How can any disadvantages be reduced?
- Consider any additional costs associated with COVID-19 safety measures. How will these costs be covered? Keep in touch with funders and commissioners about how delivery may need to change and whether resources can be reprofiled.
- Before re-opening, secure and set up the equipment you need to support social distancing throughout the building, e.g. screens or dividers to reduce contact, signs and stickers.
- In planning for re-opening, consider whether you can pool resources with other organisations. Can you offer space to other projects who are providing support to the community?
3. Returning to Work
One key consideration in reopening will be the safety of your staff and volunteers. Your team will need support to help them to feel safe. Make sure that you are consulting with them and involving them in the redesign of your services.
- Check the government pages on Working Safely During Coronavirus for detailed guidance. The information is updated regularly so check back if there are new announcements, e.g. if new requirements around testing are introduced
- Current advice is for everyone to work from home where possible, so consider which staff need to come back in and which can work remotely. Make sure you communicate with your team and provide opportunities for feedback.
- Identify and speak to members of your team may be unable to return to work due to being classed as clinically extremely vulnerable/clinically vulnerable. What reasonable adjustments can you make to help them work safely from home? Read the HSE guidance on protecting vulnerable workers.
- Be mindful of staff and volunteers who live with people from vulnerable groups, have caring commitments have other concerns and who may be anxious about returning to work. Keep equality and diversity issues in mind – what is reasonable for some people might not work for others.
- In light of emerging evidence that COVID-19 mortality is disproportionately higher in people from Black, Asian and Minority Ethnic (BAME) backgrounds, you may decide to complete a risk assessment with BAME staff to identify those at higher risk. Guy’s and St Thomas’ has published some guidance on how to approach this.
- Consider adapted working hours to reduce the number of people in the building at any one time and partnering for staff so that the same groups are consistently working together.
- Develop contingency plans to cover staff or reduce/cancel services if team members become ill, need to self-isolate, or if further lockdown measures are re-introduced.
- Make sure you support the mental wellbeing of all staff through the changes you will need to make.
- Consider the role that staff members play in the community in sharing messages about Covid-19 and encouraging preventative measures. Will they need additional training to support them in this role?
4. Cleaning and Hygiene
The HSE has clear guidance on cleaning and risk reduction; read through it to help you plan out what cleaning needs to be done both before you open and you’re your services are up and running again.
- Your building may need to be deep cleaned prior to opening. Consider whether this can be done by staff/volunteers or whether you need to bring in professional cleaners.
- Encourage all users of your building to follow the guidance on hand washing and hygiene by washing their hands frequently and thoroughly.
- Where handwashing is not possible, visitors should use alcohol-based hand sanitiser (minimum 60% alcohol content).
- Provide hand sanitiser around the workplace, particularly at entrances/exits.
- Enhance cleaning for busy areas, and frequently clean and disinfect objects and surfaces that are touched regularly.
- Can you ask staff and tenants to help, e.g. cleaning individual work stations before and after use, keeping communal areas clean after each use?
- Consider leaving internal doors (not fire doors) open throughout the building to improve ventilation and reduce contact with door handles.
- When meeting people you do not live with, it is important to do so outdoors where possible, or to make sure that any indoor venue has good ventilation (for example by opening windows so that fresh air can enter).
5. Social Distancing
A large part of reducing the risk of COVID-19 will be around the behaviour and vigilance of your team. This HSE guidance on ‘Talking with your workers about preventing coronavirus’ is a great starting point as you begin to reopen.
- Follow and promote the ‘HANDS, FACE, SPACE, FRESH AIR’ rules:
- You should maintain 2m social distancing where possible. If it is not possible for people to be 2m apart, you should do everything practical to minimise the transmission risk and length of contact.
- Put up signs and issue information to help promote social distancing. The CPNI has a set of downloadable workplace posters and guidance on how to use them.
- Avoid sharing workstations. If workstations do need to be shared ensure they are thoroughly cleaned after each use.
- Use back-to-back or side-to-side working whenever possible and consider using screens or barriers to separate people from each other.
- Use floor tape or paint to mark areas to help people keep to a 2m distance.
- Consider where the high traffic areas in the building are likely to be, and whether any areas may need to remain closed. Can you implement a one-way system to reduce contact?
- Introduce a bookings system, if appropriate, so waiting times are minimised.
- Keep activity time as short as possible, with fast transitions into and out of activity spaces.
- Try to reduce the number of people each person has contact with by restructuring your activities and staggering start and finish times.
- Reduce the overall number of people in the building and try to make sure the same groups, always 6 people or less, work together consistently as a work bubble where possible.
- Where practical, meet people outdoors. This is safer than meeting indoors because fresh air provides better ventilation.
- All users of your building, staff and volunteers should avoid social interaction with anyone outside the group (of up to 6) you are with, even if you see other people you know.
- See the Government guidance on COVID-19 for more information, including updated guidance following new announcements.
6. Face Coverings
Face coverings are currently mandatory for visitors to most public buildings, including community centres, youth centres, social clubs and entertainment venues.
- Some exemptions apply; check the detailed government guidance on face coverings for more information on who should wear face coverings, enforcement, and safe usage.
- Face coverings are not required by law for employees as employers already have a legal obligation to provide a safe working environment.
- Employers should assess the use of face coverings on a case by case basis depending on your risk assessment of the workplace environment, any other appropriate mitigations you have put in place, and whether reasonable exemptions apply. For example, there will be times when screens or visors are in use, or when a staff member is not in close proximity to people they do not normally meet, and so it will not be necessary for staff to wear a face covering.
- Where you are requiring staff to wear a mask in the workplace, ensure staff have received guidance and/or training in how to use this safely and effectively.
- For recommendations and requirements in specific settings please check the Government’s workplace guidance.
- Amend any online information and update social media to highlight any new restrictions to potential visitors and to let people know what to expect when they first arrive at your building.
- Do you work with any groups who will need additional help and support to understand and comply with social distancing? How will you support compliance?
- What will be your policies and procedures for dealing with anyone who refuses to comply with social distancing measures? Discuss and agree these in advance of re-opening or running an activity and make sure your team know what to do.
7. Test and Trace
Guidance on maintaining records of staff, customers and visitors to support NHS Test and Trace is available on the government website.
NHS QR Codes and App Venues in hospitality, the tourism and leisure industry, close contact services, community centres and village halls must:
- Ask every customer or visitor (over the age of 16) to provide their name and contact details
- Keep a record of all personnel working on their premises and shift times on a given day and their contact details
- Keep these records of customers, visitors and staff for 21 days and provide data to NHS Test and Trace if requested
- Display an official NHS QR code poster so that customers and visitors can ‘check in’ using the NHS COVID-19 app as an alternative to providing their contact details
- Adhere to General Data Protection Regulations (GDPR)
- The full list of settings that need to display a QR code is available here. The general principle is that events, venues and facilities that are open to the public should use a code; regular office settings do not need to do so.
- Customised QR codes must be created via the official government website. Your QR code should be displayed clearly at the access points to your venue. Visitors can use the NHS Covid-19 app on their smartphones to ‘check in’ to your premises (this data stays on their phone and is not shared).
- NOTE: The rules on what you need to do when a group enters your venue have changed. You must now ask every customer and visitor to scan the NHS QR code using their NHS COVID-19 app, or provide their name and contact details, not just a lead member of the group.
- If you are currently using your own QR code to collect contact details you must change to the official NHS code.
- Further help on QR codes and posters is available on the NHS website.
- 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.
Collecting Information
- If visitors are not using the NHS app to check in to your venue or event, you should collect the following information from them:
- The name of the customer or visitor
- A contact phone number for each customer or visitor. If a phone number is not available, you should ask for their email address instead, or if neither are available, then postal address
- Date of visit, arrival time and, where possible, departure time a visitor is likely to interact with only one member of staff (e.g. for advice appointments) the name of the staff member should be recorded alongside the name of the visitor
- All designated venues must also keep a record of all staff working on the premises on a given day, the time of their shift, and their contact details. This covers anyone providing a service or activity including volunteers. Venues must keep these records of staff, but staff can choose to check in using the NHS QR code poster in addition, if they wish.
- No additional data should be collected for Test and Trace
- You should collect the information in a way that is manageable for your establishment. If not collected in advance, information should be collected at the point that visitors enter the premises or at the point of service.
How records should be maintained
- You should hold records for 21 days. This reflects the incubation period for COVID-19, which can be up to 14 day, plus an additional 7 days to allow time for testing and tracing.
- After 21 days, visitor information collected for Test and Trace purposes should be securely disposed of or deleted.
- Records that are made and kept for other business purposes do not need to be disposed of after 21 days. The requirement to dispose of the data relates to a record that is created solely for the purpose of NHS Test and Trace. All collected data, however, must comply with the General Data Protection Regulations and should not be kept for longer than is necessary.
Promoting Test and Trace
- Visitors may have concerns about how their data will be used, so you may want to provide online information explaining the key points:
- Information will be kept for 21 days and will only be used if there are confirmed cases of Covid-19 involving people who have visited
- Where there is a confirmed case of Covid-19, NHS contact tracers will contact facilities where visitors have been to provide as much information as possible
- You can check the detailed guidance about information sharing and download a template privacy notice from on the government’s coronavirus pages.
- Further information about Test and Trace for Tower Hamlets residents is available on the Tower Hamlets website.
- Leaflets and posters on Test and Trace, including some in community languages, are available from Public Health England.
Failure to comply
Collecting contact details and maintaining records for NHS Test and Trace is a legal requirement and failure to comply is punishable by a fine:
- first fixed penalty: £1,000
- second fixed penalty: £2,000
- third fixed penalty: £4,000
- any further penalty notice: £10,000
The person responsible for the organisation is liable. This could be the owner, proprietor or manager with overall responsibility of the organisation, business or service.
8. If Someone Tests Positive for COVID-19
- If you are notified that someone has tested positive for Covid-19 who visited your setting during the infectious period*, contact the London Coronavirus Response Cell (LCRC) if you have not already heard from them:
Email: LCRC@phe.gov.uk or call 0300 303 0450
Please also let Tower Hamlets Council know by emailing: PHCov19@towerhamlets.gov.uk.
LCRC will help you to undertake a risk assessment and tell you what to do next.
As a minimum, once a case is reported you should undertake a deep clean.
*People are infectious 48 hours before, and 10 days after, the onset of symptoms (or the date of their test if they do not have symptoms).
NOTE: A single case at a setting is classified as a situation, which puts LCRC on alert for any future cases that might be linked to the same place. When there are two or more linked cases within a setting, this is classified as an outbreak. If anyone who has been to your workplace reports a positive test, the risk assessment that LCRC will undertake will help them identify any potential close contacts who have also been there. Close contacts will then be contacted to request that they self-isolate and take a test if they develop symptoms. If any close contact returns a positive test, this would then be classified as an outbreak and trigger additional action. |
- Nominate a key member of staff to represent your organisation when dealing with a situation or outbreak. They will be the main contact person for the LCRC and/or Tower Hamlets Council.
- If necessary, an outbreak incident management team may be convened, with one of your senior staff invited to attend to help enable joint decision making.
- Have your visitor log ready: LCRC will want to use it for contact tracing. You will need to work with LCRC to identify who has been in close contact with the positive case.
A ‘close contact’ is a person who has been close to someone who has tested positive for Covid-19 while they are infectious.
Close contact includes:
- Household contacts
- Sexual partners
- A person who has had face-to-face contact (within one metre), with someone who has tested positive for Covid-19, including: being coughed on, having a face-to-face conversation within one metre, having skin-to-skin physical contact, or contact within one metre for one minute or longer without face-to-face contact
- A person who has been within 2 metres of someone who has tested positive for COVID-19 for more than 15 minutes
- A person who has travelled in a small vehicle with someone who has tested positive for COVID-19 or in a large vehicle or plane near someone who has tested positive for COVID-19
- Think about communication with your employees and the community, as advised by LCRC and/or Tower Hamlets Council.
- Check that all staff on the premises are symptom-free and have not been told by NHS Test and Trace/LCRC to self-isolate.
- If anyone in your team does have symptoms, or has been told to self-isolate, send them home and ask them to follow self-isolation advice/guidance for contacts. Consider what support you can offer them to help with self-isolation.
- For large outbreaks, LCRC and Tower Hamlets Council may discuss mass testing of your employees with you.
This document should be considered alongside other specific guidance, including:
For further support and guidance on anything relating to safe re-opening, please contact THCVS at info@thcvs.org.uk and see their COVID-19 resources and support pages.
If you have specific queries about infection control or PPE you can also contact the Public Health inbox – PHCov19@towerhamlets.gov.uk.
Document updated 13th May 2021.
If you have any feedback or suggestions for changes please contact Gemma.Cossins@towerhamlets.gov.uk