COVID-19 Record Keeping of Patrons

Due to the impact of COVID-19, many businesses are required (or strongly advised) to record their customer’s or staff’s details in the event of another viral outbreak. Contact tracing is a critical step in managing any potential outbreaks of COVID-19 within Australia.

It’s important that you store your customer’s/staff details correctly and use their private information for the purpose its intended for – to notify State Health Authorities should you be instructed to do so.

Requirements for keeping a record of your customer/staff/visitor’s information varies from state to state.

If a Direction or Order applies to your business, the collection of this personal information will be necessary for your organisation’s functions of activities. This means the collection of contact information is permitted under the Privacy Act 1988.

If there isn’t a Direction or Order that applies to your business, you are not required to ask for customer and visitor names and contact details for contact tracing purposes. However, you can still collect contact information if you would normally do so for your functions and activities, like booking appointments. (SOURCE: OAIC.GOV.AU)

NSW

Under NSW public health orders some businesses and organisations are required to keep a record of all staff, patrons and contractors visiting their premises.

Businesses that need to collect patron and staff details must address this requirement in their COVID-19 Safety Plan. Failing to collect complete and accurate patron details is a breach of public health orders and may result in penalties.

From Monday 23 November 2020, it became mandatory for certain types of businesses to use electronic check-in methods to collect patron details.

Details you must collect:

Businesses and organisations that are required to collect patron records must record the following details for every person including staff, patrons and contractors entering the premises:

+ Full name

+ Phone number (and email address where possible)

+ Date and time of entry (and time of exit where possible).

Records must be kept for a minimum period of 28 days and provided as soon as possible, but within 4 hours, upon request from NSW Health, 7 days a week.

From Monday 23 November, some businesses and organisation became required to collect details electronically (e.g. using a QR code). Processes must be in place to ensure that patrons provide the required contact information and deny entry to patrons who will not provide valid  details.

If there are unexpected circumstances which prevent the use of electronic methods to collect contact details (such as an internet outage or technical limitations), any paper records must be entered into an electronic format such as a spreadsheet within 12 hours.

Patrons without smartphones, businesses are encouraged to record their details via electronic means (eg a computer).

For more information, head to: https://www.nsw.gov.au/covid-19/covid-safe/customer-record-keeping/collecting-patron-and-staff-details-obligations-for

VIC

To support contact tracing, some businesses, workplaces and premises must request that each person who attends the premise for more than 15 minutes (including staff) provide their:

  • first name

  • phone number

Businesses are strongly encouraged to use QR codes to support contact tracing. For more information on this free service see Victorian Government QR Code Service.

For a copy of the Visitor and patron contacts log – Coronavirus (COVID-19) contact tracing register, head to this page here:

https://www.coronavirus.vic.gov.au/signs-posters-and-templates

Businesses must keep a record of those details, and the date and time at which the person attended the facility.

Where the patrons spend most of their time in a single space (i.e. a dining room, or a cinema), a record of the space used should also be kept. There is no need to keep multiple records if patrons move through multiple spaces. Records can be kept electronically or in hard copy and should be kept for 28 days.

Pens used to record details should be wiped with an alcohol wipe between users. Customers should be encouraged to use their own pen, if they have one, to minimise the sharing of pens.

The record keeping requirement applies to all persons attending a facility or venue for longer than 15 minutes, which may include staff, customers, maintenance and delivery workers.

Please note additional record keeping requirements may apply to meet your OHS obligations in certain industries. For more see the WorkSafe Victoria website.

For more information, head to: https://www.coronavirus.vic.gov.au/record-keeping-contact-tracing-information-business

REST OF AUSTRALIA

For further information on Australia wide guidance for businesses collecting personal information for contact tracing, head to the Office of the Australian Information Commissioner’s website:

https://www.oaic.gov.au/privacy/guidance-and-advice/guidance-for-businesses-collecting-personal-information-for-contact-tracing/

REMEMBER:

In the event of an outbreak, State Health authorities rely on businesses and organisations keeping complete and accurate records of all patrons and staff. It’s vital for tracing teams to obtain reliable information to keep our communities safe.

It’s easier to use electronic means for recording patrons information. Handwritten details may be difficult to read and need to be converted to electronic format for tracing purposes. Electronic methods also reduce physical contact between people ensuring record keeping is contactless.