Contents

Introduction

Defintions

A. Preparing yourself and your premises
1. Check your insurance
2. Assess the risks of reopening
3. Prepare for social distancing
4. Appointment timings
5. Treatment time
6. Temperature checks
7. Deep clean and prepare for ongoing deep cleaning and hygiene
8. Handwashing facilities
9. Communications and signage
10. Removing risk items from common areas
11. Contactless payment facilities
12. Seeing clients in their own homes
13. Update policies and agreements
14. Face coverings, face masks and Personal Protective Equipment (PPE)
B. Checking COVID-19 risk factors before seeing clients
1. Check if clients are in COVID-19 high risk categories
2. Check if clients are in COVID-19 moderate risk categories
3. Screening for COVID-19 symptoms and when not to treat
4. When you should not treat clients
C. Preparing to work with clients
1. Communication with clients in advance of treatment or care
2. Client consultations in advance of treatment or care
D. Working with clients
1. Client arrival: Social distancing and hygiene
2. During treatment/session
3. After treatment/session
E. Payment arrangements
F. Steps to take between clients
G. Steps to take at the end of the day
H. Testing and contact tracing
1. England
2. Northern Ireland
3. Scotland
4. Wales

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Introduction

This advice applies to all IAEBP Members, and whether they are able to work with their clients while maintaining social distancing (face to face therapy).

Current advice is that you may remain open during the lockdown in England from 5 November to 2 December, however, you cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.

If your practice is based in your own home you can continue to work as long as it is COVID secure.

IAEBP Members can continue to provide the therapies they are registered for, on a one-to-one basis to clients, for an identified mental or physical health condition or injury that is causing them pain, or having an adverse impact on their quality of life. You must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by recording their health condition and giving a clear rationale in your client’s care record for the treatment that you are providing. (Updated 10 November 2020)

You can find advice on following government guidelines on working safely below.

This advice will help you to follow government guidance on returning to work and working safely during the coronavirus pandemic.
You must follow guidance from the government of the country you practise in:

• England: See Working safely during the coronavirus (COVID-19) and Staying alert and safe (social distancing).
• Northern Ireland: See Advice for businesses and workers and Coronavirus: Working safely in different business settings
• Scotland: See Coronavirus (COVID-19) Information for individuals and businesses in Scotland.
• Wales: See Coronavirus (COVID-19) Staying safe at work.

There is additional guidance for close contact services cited below but this does not apply to our normal therapeutic work, performed at a distance.
• England and Northern Ireland: See Working safely during the coronavirus (COVID-19): Close contact services.
• Scotland: See Coronavirus (COVID-19): retail sector guidance including close contact services and Checklist for salons and close contact services.
• Wales: See Beauty, holistic and wellbeing services: coronavirus workplace guidance. It includes a restart risk assessment and a reopening checklist.

You are advised to check the relevant government guidance on a regular basis as it will be updated.

Who can return to work
Face to face therapies and close contact services have resumed in in England, Northern Ireland, Scotland and Wales subject to the following:

Local restrictions on returning to work
Returning to work is subject to local lockdowns or restrictions put in place in areas where there are local COVID-19 outbreaks. You are advised to consult local restrictions guidance to see if any restrictions are in place in your area:
• England (updated 10 November 2020)

Based on the advice we have received, we are able to say that IAEBP Members in England meet the definition of “other…health services, including services relating to mental health” contained in Section 47, Part 3 of the Schedule to The Health Protection (Coronavirus, Restrictions) (England) (No. 4) Regulations 2020 and can therefore continue to practise during the period of national restrictions in England introduced on November 5th, but you must be able to evidence that your therapeutic intervention is supporting your client with their condition. You can do this by recording their health condition and giving a clear rationale in your client’s care record for the treatment that you are providing. (Updated 10 November 2020)

Legal advice has taken into account that in Section 25E of the Health and Social Care Act 2012 practitioners on Accredited Registers are defined as engaged in work that includes the provision of healthcare.

Mobile working

You cannot provide treatment to a client in their own home unless you have received a direct referral from a statutory regulated health professional.

If your practice is based in your home

If your practice is based in your own home you can continue to work from there as long as it is COVID-secure. You can find advice on following government guidelines on working safely below.

• Scotland (Updated 1 November 2020)
A new system of local protection levels has been introduced from 2 November 2020. You can check the protection level for your area and find out what you can and cannot do under each level here.

• Northern Ireland (updated 19 October)
The First Minister outlined the Northern Ireland Executive’s decisions to the Assembly on 14 October 2020. The restrictions, which will come into force on Friday 16 October for an initial period of 4 weeks, include: “Closure of close contact services apart from those meeting essential health needs which will be defined in the regulations to ensure continuation of essential health interventions and therapeutics. This will not include complementary treatments.”

Hypnotherapy and psychotherapy are not included in the list of prohibited activities. Updated guidance can be found here.

• Wales (updated 9 November 2020)
The short, sharp “circuit-breaker” or “fire-break” ended on Monday 9 November 2020. You should now follow the local restrictions which are in force in some parts of the country.  For more advice check here.

Definitions

Face to face therapies
Face to face therapies are ones where you are able to maintain a physical distance from your clients. Examples of face to face therapies are hypnotherapy and nutritional therapy.

‘Hands-on’ therapies (also known as close contact services)
‘Hands on’ therapies are those that involve close physical contact with clients for extended periods of time, for example, massage therapy, reflexology and sports therapy. Government guidance calls services such as ‘hands-on’ therapies “close contact services” and we will use that term throughout this guidance when talking about ‘hands-on’ therapies.

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A. Preparing yourself and your premises

1. Check your insurance
1.1. Before any steps are made to return to face to face and close contact work, check with your insurance company that you will be covered under your professional indemnity insurance.
1.2. Most insurance companies have provided cover during remote working but may have quite different requirements for face to face and close contact work, due to the increased risks involved. Note that Towergate have approved face to face working for IAEBP members.

2. Assess the risks of reopening
2.1. Before reopening it will be important to carry out a risk assessment of both the premises and treatment areas, as well as your way of working:
• England: The UK Government has prepared guidance on how to work safely during the coronavirus outbreak, Working safely during the coronavirus outbreak; a short guide. You can also find an online checklist Reopen your business safely during coronavirus (COVID-19).
• Wales: See Keep Wales Safe at Work guidance.
• Northern Ireland: See the section on “Working Safely” in Coronavirus updates: Support for your business
• Scotland: See Returning to work safely guidance
2.2. Key actions to take when assessing risks:
• Identify what work activity or situations might cause transmission of the virus.
• Think about who could be at risk.
• Decide how likely it is that someone could be exposed.
• Act to remove the activity or situation, or if this is not possible, control the risk.
2.3. See Health and Safety Executive (HSE) guidance on carrying out a risk assessment, Managing risks and risk assessment at work.
2.4. The HSE has identified the need to manage Legionella risks if the building to which you will be returning has been empty or unoccupied during the Covid-19 outbreak. See Legionella risks during the coronavirus outbreak.

3. Prepare for social distancing
3.1. The UK Government and the devolved nations have made clear that social distancing will continue for the foreseeable future.
3.2. When planning to reopen your clinic or premises, check how you can maintain the required social distancing between yourself or staff and clients, between clients and between staff.
3.3. Physical areas to consider are:
• the entrance to your premises
• waiting areas
• treatment rooms
• toilet facilities.
3.4. The UK Government suggests you consider how to:
• physically arrange work areas to keep people 2 metres apart (or where this is not possible having additional protective measures in place to manage the transmission risk)
• mark areas using floor paint or tape to help people keep a 2 metre distance
• provide signage to remind people to keep a 2 metre distance
• use screens to introduce a physical barrier, for example at reception desks or payment areas
• prepare to ensure your clinic or treatment area is well ventilated – do not use air conditioning systems or convector heaters that recirculate air.

4. Appointment timings
4.1. Plan your treatment schedule to allow 30 minutes between clients, so that clients can leave without meeting other clients and to allow time for disinfecting and cleaning between sessions (see section D below). Do not allow appointments to over run if they will not allow for the 30 minute gap been appointments.

5. Treatment time
5.1. For close contact services treatment times should be kept to a minimum. They should not exceed an hour.
5.2. For face to face therapies and close contact services provided for clients who fall into high and medium risk categories, consider the shortest time that the treatment can be effectively delivered in.

6. Temperature checks
6.1. You may wish to check each client’s temperature before treatment using a no-touch thermometer.
6.2. If so, ensure you have a supply of no-touch thermometers available.

7. Deep clean and prepare for ongoing deep cleaning and hygiene
7.1. Before re-opening you will need to check, if necessary, that the water supply does not carry any Legionella risks (see section A.2.4), then carry out a deep clean of your premises. This means a full clean including disinfecting all hard surfaces such as doorbells, door handles, banisters, taps, reception desks, computer keyboard and mouse, telephones, toilet and hand washing facilities.
7.2. You will also need to plan how to clean and disinfect your premises and treatment area between clients (see section F and section G below).
7.3. Ensure you have an adequate supply of cleaning products in stock.
7.4. Ensure you have an adequate supply of couch roll for use on non-wipeable chairs and couches in waiting and treatment areas for use for each client.
7.5. Towels, couch covers, blankets, pillowcases and any other soft item should only be used once per client. This may represent a change in practice if you have previously used couch roll on top of a soft cover. Ensure you have a sufficient supply of washable items for each client or use disposable couch roll and covers. At no time should a client be allowed to bring their own sheets, towels, blankets or pillows.
7.6. Ensure you have a covered laundry bin to collect any used washable items following each client’s treatment. Ideally this should be a foot pedal bin.
7.7. Ensure you have disposable gloves to handle used items and waste at the end of each day.
7.8. Ensure you have laundry facilities to be able to wash any items at 60 degrees.
7.9. Check with the local authority in your area about waste disposal requirements of e.g. couch rolls, disinfectant wipes and other used items.
7.10. For close contact services where clients remove their clothing, ensure you have a lidded container where clients can place their clothing and belongings during treatment, where appropriate. Ideally use a foot pedal bin.

8. Handwashing facilities
8.1. Ensure both yourself and clients have access to hand washing or hand sanitising facilities.
8.2. Ensure you have an adequate supply of hand washing or hand sanitising products in stock.
8.3. If you use hand sanitising gel or wipes, they should have an alcohol content of 70 per cent.
8.4. Hands should be washed for a minimum of 20 seconds. Guidance on the correct way to wash hands can be found on the NHS website.

9. Communications and signage
9.1. Prepare signage for your clinic and treatment areas to remind clients to wash or to sanitise their hands and to keep a 2 metre distance from others.

10. Removing risk items from common areas
10.1. To reduce the risk of transmission from touch, remove from waiting rooms and treatment areas all non-essential items such as:
• magazines
• samples
• water dispensers (ask clients to bring their own water)
• pens
• any other items which clients may touch.

11. Contactless payment facilities
11.1. Put facilities in place to ensure clients can pay by contactless or online payment.
11.2. Card machines should be sanitised between clients.
11.3. If clients can only pay by cash, have single-use envelopes available where clients can place their cash following treatment. Use one envelope per client. Do not touch these until the end of the day. Wash hands thoroughly after handling the envelopes and cash. Dispose of the envelopes safely.

12. Update policies and agreements
12.1. Check your cancellation policies and update if necessary, to allow for greater flexibility and sensitivity if you or your clients have to cancel an appointment at short notice due to COVID-19 infection. A cancellation charge for a client cancelling because they, or a member of their household, have COVID-19 symptoms would be inappropriate.
12.2. Seek advice from your insurance company about any disclaimers you may need to use for yourself and your clients regarding risks of COVID-19 infection.

13. Face coverings, face masks and Personal Protective Equipment (PPE)
13.1. Personal Protective Equipment (PPE) includes items such as disposable gloves, disposable masks and items of clothing such as disposable gowns and aprons.
13.2. If you work face to face, then Government advice is that social distancing and hygiene are the ways to manage the risk of infection from COVID-19.
13.3. If you work face to face, you may choose to take the additional precautionary measure of wearing a face mask or face covering and asking your client to wear a face covering as well, particularly if the client’s is in a high or medium risk category. Face coverings are not classified as PPE – see Face coverings: when to wear one and how to make your own.
13.4. If you are asking clients to wear a face covering, contact them before their appointment to ascertain if they are are exempt from wearing a face covering

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B. Checking COVID-19 risk factors before seeing clients

Some people are at higher risk of severe illness from COVID-19. They have been categorised as ‘clinically extremely vulnerable’. For more information, see guidance from the NHS Who’s at higher risk from Coronavirus.

Below we set out what you need to do before you see clients. This includes:
• Identifying any clients who are at increased risk of infection.
• Screening for COVID-19 symptoms.
• Clarifying when not to treat.
You may wish to use a checklist based on the areas outlined below.

1. Check if clients are in COVID-19 high risk categories

1.1. Check if any clients are in the high risk (clinically extremely vulnerable) category which means they will have been contacted by the NHS and have been shielding. Clients in this category have been identified as being at extremely high clinical risk of infection and must avoid face to face contact with anyone outside their household for at least 12 weeks following any period of lockdown.

They include those who:

• have had an organ transplant
• are having chemotherapy or antibody treatment for cancer, including immunotherapy
• are having an intense course of radiotherapy (radical radiotherapy) for lung cancer
• are having targeted cancer treatments that can affect the immune system
• have blood or bone marrow cancer (such as leukaemia, lymphoma or myeloma)
• have had a bone marrow or stem cell transplant in the past six months or are still taking immunosuppressant medicine
• have been told by a doctor that they have a severe lung condition such as cystic fibrosis, severe asthma, or severe Chronic Obstructive Pulmonary Disease (COPD)
• have a condition that means they have a very high risk of getting infections such as Severe Combined Immunodeficiency (SCID) or sickle cell
• are taking medicine that makes them much more likely to get infections (such as high doses of steroids)
• have a serious heart condition and are pregnant.
1.2. Always seek advice from your professional indemnity insurance company about the risks associated with treating clients in the high risk category before proceeding.
1.3. You cannot see clients in the high risk category until the government in the country you practise in pauses shielding.

• England: Shielding has been paused from 1 August
• Northern Ireland: Shielding has been paused from 31 July
• Scotland: Shielding has been paused from 1 August
• Wales: Shielding paused from 16 August.

Where shielding has been paused it will be kept under close review by the relevant government and may change. Local outbreaks of COVID-19 may also lead to a change of measures so it is important to keep up to date with current guidance.
1.4. Even if shielding is paused, clients in this category will still be at risk of severe illness if they contract coronavirus. You must very carefully assess whether the potential benefits of treatment outweigh the risks, particularly if close contact services are being provided. As part of this assessment:
• Consider delivering the treatment remotely if that is possible.
• Clients should be encouraged to seek the advice of their GP, midwife or hospital consultant on whether they should proceed with the treatment. [UPDATED 24 August 2020}
• If the client tells you that their GP, midwife or hospital consultant has not identified any reason why they should not proceed with treatment, document this in the client’s notes and ask the client to sign and date this.[UPDATED 24 August 2020}
1.5. If you decide to proceed, take extra care with social distancing and hygiene measures.
1.6. Keep treatment times to a minimum. Consider the shortest possible time in which you can deliver the treatment effectively. Do not exceed an hour and do not book two appointments for different types of treatments back to back.
1.7. Remember that your safety and the safety of the client are paramount. Trust in your professional judgement and do not feel pressured to see a client if you feel this will put them or yourself at risk.

2. Check if clients are in COVID-19 moderate risk categories

2.1. Check if any clients are in the ‘moderate risk’ groups which include those who are:
• 70 or older
• Pregnant. Pregnant women from 28 weeks are at higher risk of becoming seriously unwell if infected with COVID-19 and are advised to take particular care with social distancing. See RCOG guidance Coronavirus infection and pregnancy.
• have a lung condition that’s not severe (such as asthma, COPD, emphysema or bronchitis)
• have heart disease (such as heart failure)
• have diabetes
• have chronic kidney disease
• have liver disease (such as hepatitis)
• have a condition affecting the brain or nerves (such as Parkinson’s disease, motor neurone disease, multiple sclerosis or cerebral palsy)
• have a condition that means they have a high risk of getting infections
• are taking medicine that can affect the immune system (such as low doses of steroids)
• are very obese (a BMI of 40 or above).
2.2. People in the moderate risk group are advised to stay at home and social distance but they are not required to shield. For more information, see guidance from the NHS Who’s at higher risk from Coronavirus.
2.3. Always seek advice from your professional indemnity insurance company about the risks associated with treating clients in the moderate risk category before proceeding.
2.4. If a client is in the moderate risk group:
• For face to face therapies:

o As part of your risk assessment, use your professional judgement to decide if the potential benefits of treatment outweigh the risk. [UPDATED 24 August 2020]
o If you do proceed with treatment, take extra care with social distancing and hygiene measures.

2.5. Keep treatment times to a minimum. Do not exceed an hour and do not book two appointments for different types of treatments back to back for the same client.

3. Screening for COVID-19 symptoms and when not to treat

3.1. At the time of writing the NHS guidance for symptoms to look out for are as follows:

• High temperature
• Persistent cough
• Loss or change to your sense of smell or taste.

This guidance may be updated so check the advice on symptoms on the NHS website on a regular basis.

3.2. You: Check daily if you are experiencing any COVID-19 symptoms. This could include taking your temperature each day.
If you become aware of any COVID-19 symptoms you should immediately cancel any booked appointments and follow government guidance about self-isolation.

3.3. Your household and support bubble: Check daily if anyone in your household or support bubble is experiencing any COVID-19 symptoms, which could include temperature checks.
If anyone in your household or support bubble experiences COVID-19 symptoms you must cancel all appointments and put yourself in quarantine for 14 days, as per government advice.

3.4. Your clients: Check with clients 24 hours in advance of any appointment if they or anyone in their household or support bubble is experiencing any COVID-19 symptoms.
If a client or anyone in their household or support bubble is experiencing symptoms they must not attend the session, They must follow government guidance and self-isolate for a minimum of 10 days if it is them, or 14 days if it is a member of their household.

3.5. Check NHS advice about COVID-19 symptoms and what to do.

4. When you should not treat clients

4.1. To summarise, do not treat clients if:

• you or any member of your household or support bubble have any COVID-19 symptoms
• a client has COVID-19 symptoms
• a client is self-isolating or in quarantine
• a member of a client’s household or support bubble or anyone the client has been in contact with in the last 14 days has COVID-19 symptoms
• a client is in the high risk group and is shielding.

Think carefully and carry out a risk assessment for clients in the high and moderate risk groups. For close contact services ask them to obtain the advice of their GP, midwife or hospital consultant.

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C. Preparing to work with clients

1. Communication with clients in advance of treatment or care
1.1. In advance of re-opening, communicate with clients to explain the new working arrangements.
1.2. Request that clients attend on their own to reduce the risk of additional contacts between people.
1.3. Ask clients to wait outside your premises until the appointment time.
1.4. Ask client to bring their own pen if relevant.
1.5. Ask client to bring their own water to drink. Do not provide plastic cups.
1.6. Request clients pay using a contactless card or via payment online. Only accept cash payment as a last resort.

2. Client consultations in advance of treatment or care
2.1. Aim to carry out all pre-treatment consultations online or by telephone wherever possible to reduce the length of face to face contact.

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D. Working with clients

1. Client arrival: Social distancing and hygiene
1.1. Open the door yourself wherever possible.
1.2. DO NOT shake hands or hug the client.
1.3. Ask clients to wash or sanitise hands on entry to premises.
1.4. Maintain a minimum of 2 metres at all times (for face to face treatments).
1.5. Show the client the social distancing arrangements.
1.6. Ensure couch roll is placed on any non-wipeable seats and couches used by client.
1.7. Only use your own pen.
1.8. If a client needs to write, they must use their own pen or you can supply a pen which you should sanitise after use. [UPDATED: 10 September 2020]
1.9. Take client’s temperatures using a no touch thermometer. Record temperatures in client notes.
1.10. If a client shows signs of a fever or high temperature, do not treat the client. They must return home and may need to self-isolate. Suggest they call 111 for advice.
1.11. If a client has COVID-19, you may then need to self-isolate. Again, call 111 for advice.
1.12. If a client says they have had and recovered from COVID-19 it is advisable to gain a letter from their GP or hospital consultant to say it is ok for them to receive treatment. If the client says they have this permission, document it in your notes and request that the client signs and dates this.

2. During treatment/session
2.1. Keep your premises well-ventilated, with windows open in your treatment room wherever possible, or use an extractor fan. Do not use air conditioning or a convector heater that recirculates air.
2.2. Remain a minimum of 2 metres from the client for face to face therapies.
2.3. Consider asking your client to wear warm clothing, or retain their coat, if the weather is cold outside and ventilation is making your consulting room cool.

3. After treatment/session
3.1. Amend your aftercare advice sheets to include information on what clients should do if they feel unwell with any COVID-19 symptoms and any hygiene protocols you have introduced into your practice. These should be to be emailed to your client.

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E. Payment arrangements

1.1. Ask client to pay by contactless method using contactless cash machine or online payment.
1.2. If client can only pay by cash, show the client the envelope for cash payments. Use one envelope per client. Do not touch these until the end of the day. Dispose of the envelopes safely. Wash your hands thoroughly afterwards.

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F. Steps to take between clients

1.1. Wash hands thoroughly in hot water and soap for a minimum of 20 seconds. Guidance on the correct way to wash hands can be found on the NHS website – How to wash your hands.
1.2. For close contact services, hand hygiene should extend to include washing of exposed forearms.
1.2. Sterilise the container where clients have placed their clothing between clients, including any handles and any areas touched by the client.
1.3. Dispose safely in a bin with a lid all couch roll, disinfectant wipes and any other items used by or for the client. You may wish to use disposable gloves to do this. Wash your hands thoroughly for a minimum of 20 seconds afterwards.
1.4. Disinfect any surface(s) touched by a client – this might include couch, chairs, door handles, consultation table, toilet area, handwashing area.
1.5. Open doors and windows to ventilate the treatment and waiting areas.
1.6. Replace couch roll on chairs and treatment couches in readiness for the next client.
1.7. Keep doors to areas not used by client closed.
1.8. Change and dispose of Type II mask, disposable visor and PPE if being worn. Clean and disinfect reusable visor if being worn.

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G. Steps to take at the end of the day

1.1. Place all waste in sealable plastic bags and follow local waste disposal advice.
1.2. If a uniform is worn, place in a sealable plastic bag for laundering before leaving. Dispose of the bag afterwards.
1.3. Wash all uniforms, towels, coverings on a 60°C washing machine cycle.
1.4. Open doors and windows to ventilate the areas used by clients.

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H. Testing and contact tracing

You are advised to keep up to date with the government guidance on testing and contact tracing in the country you practise in.

1. England
1.1. See UK Government advice NHS Test and Trace: how it works and Maintaining records of staff, customers and visitors to support NHS Test and Trace.
1.2. You may be required to pass on client details to the NHS Test and Trace service.
1.3. Inform clients that you may need to pass on their details if required. You can either explain this to each client or have a notice up in your practice to say that you may be required to pass on contact details. Client consent is not required for their details to be used in this way
1.4. Although compliance with the NHS Test and Trace service is voluntary, please encourage customers and visitors to share their details in order to support NHS Test and Trace and advise them that this information will only be used where necessary to help stop the spread of COVID-19.
1.5. If a client informs you that they do not want their details shared for the purposes of NHS Test and Trace, they can choose to opt out, and if they do so you should not share their information used for booking purposes with NHS Test and Trace.
1.6. The NHS COVID-19 Test and Trace app launched on 24 September 2020. The app has a feature that allows users who have the app to ‘check in’ to your premises by scanning an NHS QR code if they wish to.  As a face to face therapist, you are not obliged to have your own QR code but if you wish to apply for one anyway, go here. In case of difficulty call the NHS QR Code support line on 0800 540 4900.
NOTE: The Government have now confirmed this requirement DOES apply to mobile therapists: See NHS COVID-19 app FAQS here. [UPDATED: 30 September2020]

2. Northern Ireland
2.1. See NIDirect guidance – Coronavirus (COVID-19): testing and contact tracing.

3. Scotland
3.1. See the Scottish Government’s guidance Coronavirus (COVID-19): Test and Protect.

4. Wales
4.1. See the Welsh Government’s guidance –Test Trace Protect.