Contact Tracing For Small Businesses: Are You Prepared?

Six feet (or less) apart, for fifteen minutes. That’s the definition of “close contact” used by contact tracers to determine if someone has been exposed to the novel coronavirus. Contact tracing is a critical part of the public health response to coronavirus, and it’s just as important for reopening the economy. As a business owner, contact tracing can help you protect your workers and customers from COVID-19, and even prevent your business from getting shut down in the event that an employee tests positive.

What Is Contact Tracing?

“Contact tracing” sounds high-tech and cutting edge, but it’s nothing new, and it’s basic enough that it can be accomplished with just a pen, paper, and a telephone. Historically, the practice of contact tracing has been critical in controlling numerous epidemics and pandemics, including smallpox and tuberculosis. By definition, contact tracing is the practice of identifying individuals who have an infectious disease, and alerting other individuals with whom the infected person has come in close contact with so that they can self-quarantine. By identifying cases of infection and alerting contacts who may have been exposed, the spread of disease can be limited. Contact tracing can also provide epidemiologists with important information about how a disease spreads.

COVID-19 contact tracing is generally conducted by public health departments, which, in the United States, follow the CDC’s COVID-19 contact tracing guidelines. However, businesses also have an important role to play in contact tracing.

When & Why You Need To Care About Contact Tracing

The second wave of COVID-19 is upon us (or at least the second wave of business closures related to COVID-19) and certain types of businesses are especially vulnerable to COVID-19 outbreaks. In particular, businesses that involve close contact with others or indoor spaces with limited ventilation can be especially conducive to the spread of this disease. This could include bars, restaurants, salons, spas, office buildings, and others. Though implementing social distancing practices at your business can help prevent the spread of coronavirus, your responsibilities as a business owner do not stop there. In the event that an employee or customer gets sick, having a contact tracing system in place can help you comply with local health authorities and limit the impact on your business.

During COVID-19, contact tracing is a tool for businesses to do the following:

• Limit outbreaks at your business
• Keep your workers safe
• Keep your customers safe
• Stay compliant with the law
• Protect your business against potential liability
• Prevent your business from being shut down

Though the bulk of contact tracing work is done by health authorities, business owners can play their part as well, particularly by tracking employees’ activities, and by keeping a customer log of who has visited your business, if feasible. It will be easier for businesses in certain industries to keep customer logs — appointment-based businesses such as mechanics or hair stylists will automatically have a log of all their customers — but maintaining a customer log could prove more difficult for a bar, restaurant, or retail store.

Contact Tracing Requirements & Guidelines For Businesses

Currently, there are no nationwide contact tracing requirements or official guidelines for businesses in the US. However, it’s important to check your local city, county, and state laws, which may have their own COVID-19-related policies for businesses. Here are also a few other things to keep in mind.

Customer Logs

Depending on your area, there could be a requirement for your business to keep a customer log, though this is not currently a widespread requirement by any means. One city where this is required is in New Orleans, where businesses of all types are now required to keep a daily customer log for contact tracing purposes. Washington state briefly instated the same guidelines, but Governor Jay Inslee quickly lifted them after receiving public backlash. Most states and cities currently do not have any contact tracing requirements or guidelines for businesses, but this may change as the pandemic drags on.

OSHA & CDC Guidelines

Generally, businesses should follow CDC guidelines to stay OSHA-compliant. This means that if the CDC issues business guidelines related to COVID-19 contact tracing, you will need to adhere to them, along with any other CDC policies regarding COVID-19 (such as those involving social distancing) — as well as to any local health ordinances related to businesses and coronavirus. If any employee tests positive for coronavirus, you do have an obligation to report the infection to the rest of your staff and to OSHA. In the (hopefully rare) event that an employee sues your business because they catch coronavirus at work, you will want to show you are OSHA-compliant and did everything you could to keep workers safe.

Communicating With Local Health Authorities

Though most businesses have no legal obligation to create a worksite contact tracing plan, having a plan in place (or at least keeping good records) will still help your business in the event of coronavirus transmission related to your business. If any employee or patron of your business tests positive, you will likely be contacted by your local health department’s contact tracing team to assist in their contact tracing investigation. Having your own plan in place can help health authorities with their investigation, as well as potentially preventing a full-on outbreak that could result in your business being shut down.

Considerations When Making A Contact Tracing Policy

There are several aspects businesses need to think about when creating a contact tracing policy. Try to incorporate some or all of these considerations into the creation of your business’s contact tracing plan.

Customer Tracking

If you have a customer-facing business such as a store, restaurant, or salon, you will likely want to incorporate customer tracking into your contact tracing plan. As mentioned, keeping a daily customer log is one way to do this, though these logs may not be practical or appropriate for every business. Here are a few other ways to track who visits your business:

• Require reservations for in-person dining
• Require appointments to shop at your store
• Use a cloud POS system with customer profiles that link customers to transactions

If you don’t want to require customers to leave their personal information or make appointments/reservations, you might consider having a completely voluntary customer log where customers can leave you their information only if they would like to be notified in the event that they were exposed.

Employee Tracking

Employee tracking is another important aspect of contact tracing, particularly if you have more than a few employees. In addition to keeping track of their schedules to see who is coming in when, larger businesses with a lot of employees might even have employees sign in and out every time they visit a different location within the business, such as the warehouse or kitchen.

HR software or a POS system with an employee timeclock and scheduling functionality will help you keep good records of employees’ schedules. Most cloud POS software also has employee profiles/logins, which can also be useful to see who accessed the cash register, and when.

Contact Tracing Apps

COVID-19 contact tracing apps are being developed to use digital technologies such as Bluetooth, GPS, and QR codes to track individuals’ movements within the community, including visits to businesses. As of yet, there isn’t any leading contact tracing app for business use that’s been widely adopted in the US, though there are various employee management programs businesses can use to track employees’ whereabouts within a business using Bluetooth or geolocation. These apps, which include ReturnSafe, PwC Check-In, and others, are generally intended for larger businesses such as manufacturing and enterprise-level businesses.

As far as contact tracing apps to track customers, the United States again comes up short. By contrast, in New Zealand, the national government has released a mobile contact tracing app consumers use to scan QR codes at businesses they visit, creating a digital diary of their activities. In the event of an outbreak at a business, contact tracers will automatically contact any customer who may have been exposed. Singapore’s government has also rolled out a mobile contact tracing app that works by exchanging Bluetooth signals between phones of other app users that you come in close contact with. Participation in either of these programs is voluntary, but encouraged.

It’s not clear if or when such a widely implemented digital contact tracing solution might be available in the US, but Google and Apple are currently working on a COVID-19 contact tracing mobile app for public health use (though 17 states have already said they won’t use it), and the CDC says, regarding digital contact tracing, that they are currently, “Generating preliminary tool recommendations for piloting tracing in areas with limited introduction of COVID-19.”

Privacy Concerns

Businesses must notify local health officials and staff if one or more of their employees tests positive for COVID-19. However, business owners still need to maintain the employee’s confidentiality in accordance with the Americans with Disabilities Act (ADA).

Customers and clients may also have confidentiality concerns about giving you their personal information. If you do collect this information for contact tracing, you’ll need to make sure to get customers’ consent, and only use the information for the purpose for which it was given —to contact the customer in the event that someone at your business tests positive. Don’t sneak that information onto a mailing list.

There are some legitimate privacy concerns with contact tracing technology as well, as this technology may track individuals’ movements and other activities. If you use a contact tracing app for employees, the software needs to have strong security systems in place and be compliant with privacy laws and other relevant laws.

Contact Tracing Templates

You may be able to find contact tracing templates for business online or as part of a business software package. For example, business software provider Zoho has a contact tracing form for business owners to track employees who are in danger of being exposed to the virus, offered via their Zoho Survey product. You might also consider working with an HR specialist to create your own contact tracing template to use at your business.

Additionally, the CDC has a contact tracing workflow that businesses might find beneficial when crafting their own policy.

Keep Your Employees & Customers Safe With Contact Tracing

The importance of contact tracing in battling coronavirus cannot be understated. Both from a public health standpoint and from a business standpoint, contact tracing can help mitigate the damage caused by this pandemic. Businesses can do their part to protect employees, customers, and themselves by putting in place their own contact tracing plan. Even if your policy just involves keeping good records and having a basic game-plan of what to do and who to contact if an employee tests positive, you’ll be ahead of many other businesses. By taking proactive measures, you may be able to prevent a single positive test from turning into an outbreak at your business.

Here are some more resources on COVID-19 and small businesses; check out our COVID-19 hub for even more coronavirus small business content:

• Is Your Business Ready For A Second Wave Of COVID-19?
• How To Safely Reopen Your Brick-and-Mortar Business As Pandemic Measures Are Lifted
• The Business Owner’s Retail Guide To Surviving The Coronavirus
• Social Distancing For Small Business: How You Can Adapt & Survive The Coronavirus
• Coronavirus Survival Guide For Restaurants
• Salon Survival Guide: Coronavirus Edition