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Updated guidance on Job Retention Scheme.

We are all living and working through Lockdown 2, with the Christmas period approaching we are all thinking about how Lockdown will be released and what will replace it, our team will review and advise you all once we have been updated by Government as to the most relevant guidance and rules your business needs to follow.

The most significant update in terms of the extension of the Job Retention scheme was well received by many businesses and our advice on how to ensure that our clients can fully benefit continues, today we need to advise you all of some technical updates or clarifications to the scheme that you need to be aware of.

The guidance on collecting and recording details of staff, visitors, customers and contractors that visit your business premises, has also been updated, we encourage you all to read and implement the relevant guidance as the fines for not collecting data and making it available to NHS test and trace are significant.

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.

For the extended Job Retention Scheme, also known as furlough, HMRC have introduced tight deadlines for submitting claims for each calendar month. The claim has to be submitted within two weeks of the end of the previous calendar month (see below) unless there is a “reasonable excuse for failing to make a claim in time”. Yesterday, 19 November 2020, the government amended its guidance to give examples of what it meant by a ‘reasonable excuse’, which have been summarised below.

These are the deadlines:

  • Claim for furlough days in  November 2020 must be submitted by 14 December 2020
  • Claim for furlough days in  December 2020 must be submitted by 14 January 2021
  • Claim for furlough days in January 2021 must be submitted by 15 February 2021
  • Claim for furlough days in February 2021 must be submitted by 15 March 2021
  • Claim for furlough days in  March 2021 must be submitted by 14 April 2021 

The HMRC guidance states that the following examples ‘may’ amount to a reasonable excuse for missing the deadline:

  • your partner or another close relative died shortly before the claim deadline
  • you had an unexpected stay in hospital that prevented you from dealing with your claim
  • you had a serious or life-threatening illness, including Coronavirus related illnesses, which prevented you from making your claim (and no one else could claim for you)
  • a period of self-isolation prevented you from making your claim (and no one else could make the claim for you)
  • your computer or software failed just before or while you were preparing your online claim service issues with HMRC online services prevented you from making your claim
  • a fire, flood or theft prevented you them from making your claim
  • postal delays that you could not have predicted prevented you from making your claim
  • delays related to a disability you have prevented you from making your claim
  • a HMRC error prevented you from making your claim

Maintaining records of staff, customers and visitors to support NHS Test and Trace

Added cinemas, concert venues and theatres to the list of venues that must have a system in place to request and record contact details of their customers, visitors and staff to help break the chains of transmission of coronavirus. Added clarification that indoor sports and leisure centres includes gyms.

To manage this risk, establishments in the following sectors, whether indoor or outdoor venues or mobile settings, must request contact details from staff, customers and visitors, and display the official NHS QR code poster:

  • hospitality, including pubs, bars, restaurants and cafés
  • tourism and leisure, including hotels, museums, cinemas and amusement arcades
  • close contact services, including hairdressers, barbershops and tailors
  • community centres, libraries and village halls

A full list of organisations within scope in these sectors can be found in annex A.

Follow the link for the full detailed guidance update.


Please call us should you need further assistance in relation to these updates or discuss in detail with your lead consultant on your next, MS Teams online meeting or Telephone call.

Remember that you are never alone with Park City as your business partner and we are stronger together.

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