Signage requirements for the use of Facial Recognition Technology (FRT)
Liquor & Gaming NSW has released signage to support venues that adopt the voluntary Code of Practice: Facial Recognition Technology in hotels and clubs (the Code).
The sign is designed to help venues clearly notify patrons when FRT is in use, supporting transparency and informed awareness of the collection and use of facial image data.
Where should signage be displayed?
Signage should always be positioned so patrons can reasonably see it before entering an area where FRT is operating. This supports the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Commonwealth) by helping to ensure patrons are informed about the collection and use of their facial image data.
Note that displaying signage on FRT use on its own may not be sufficient to meet notification requirements under the Australian Privacy Principles. Venues should ensure it is supported by appropriate privacy information and other materials relevant to their use of FRT.
Further guidance on measures is provided in the Code of Practice.
Office of the Australian Information Commissioner’s (OAIC) guidance update
The OIAC recently updated its guidance Facial Recognition Technology: A guide to assessing the privacy risks (July 2026) and supporting OAIC factsheet: Facial recognition technology and privacy
Venues should consider this guidance alongside the Privacy Act 1988, the Australian Privacy Principles and associated guidelines, and the Facial Recognition Code of Practice.
Coming soon
L&GNSW is developing a webinar to help venues understand the Code of Practice obligations and key privacy considerations when using FRT. Further details will be published shortly.
Further guidance on measures is provided in the Code of Practice.
Download the Facial Recognition Technology in use signage.
More information
More information on FRT is available on the Code of Practice: Facial Recognition Technology (FRT) in Hotels & Clubs webpage.
If you have any questions, please email or book a call with the Hospitality Concierge team.