Customer record keeping

Collecting patron and staff details

Under 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 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 will be mandatory for certain types of businesses to use electronic check-in methods to collect patron details.

Why contact details need to be collected

When a new COVID-19 case is detected, contact tracing teams from NSW Health need to find all close contacts of the new case as quickly as possible to help stop or slow the spread of COVID-19.

Contact tracing teams rely on businesses and organisations keeping complete and accurate records of all patrons and staff. If tracing teams are not able to obtain reliable information, people are unknowingly placed at risk and the virus can continue to spread throughout the community.

Electronic check-in methods (such as QR codes) are better than paper records. Hand-written details can be difficult to read and need to be turned into an electronic format for contact tracing purposes. Electronic methods are also contactless and reduce physical contact between people.

Obligations for businesses collecting patron and staff details

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 upon request from NSW Health, 7 days a week.

From Monday 23 November, some businesses and organisation will be required to collect details electronically (e.g. using QR code) and allocate a staff member to oversee that patrons are providing the required information. Patrons who will not provide valid contact information must be denied entry.

For patrons who do not have access to a smartphone, businesses and organisations are encouraged to record their contact details and time of entry in digital form using a non-QR electronic device, such as a computer. A record template is available. (PDF, 167.7 KB) This record can be in the form of a spreadsheet or any other form of digital entry that can track customer check-ins and protects the privacy of your clientele.

In exceptional circumstances where an electronic method is not available, for example due to technical limitations or outages, paper records must be collected and be digitised as soon as possible e.g. by taking a readable digital photo.

Businesses and organisations should ensure that they protect the privacy and security of patron contact details:

• collect personal details in a way that keeps them private from other patrons
• ensure the information recorded is stored confidentially and securely
• ensure the information is only used for the purpose of COVID-19 contact tracing when requested by authorised officers, or that consent is obtained from the customer if the information will be used for another reason (e.g. customer loyalty schemes or marketing).

How to collect contact details

To support accurate collection of contact details, businesses and organisations should:

• collect patron details at visible and accessible entry points.
• clearly display what is required of patrons on entry to premise. 
• provide appropriate cleaning and/or access to sanitiser between customer use for any shared items .

Records are not required for customers or visitors collecting takeaway items or dropping off goods.

Selecting an electronic system to collect contact details

Details must be collected electronically for most businesses, e.g. using a QR code or on a digital file. 

Businesses and organisations should consider using an electronic system that can quickly and accurately produce a complete digital record of patron and staff contact details. It is also important that an electronic system can provide a safe, secure and easy experience for patrons.
 
Look for a system that:

• is contactless where possible
• is iOS and Android compatible
• has a check-in function so that you can keep track of when patrons arrive at your business or organisation 
• has a check-out function (when this technology becomes available) so that you can see in real time how many patrons are checked in, to support monitoring and compliance
• has a limited number of steps for patrons to go through (e.g. automatically fills details where available) and retains information so that return patrons do not have to re-enter data
• confirms or validates individual contact details to ensure patron information is accurate
• protects individual patron information, and ensures information is secure and held onshore in Australia
• has a privacy policy that forbids use of patron information for any purpose other than contact tracing by NSW Health, or obtains patron consent before using their information for other reasons (e.g. loyalty schemes and marketing).

A free QR code check-in option is available for businesses and organisations that register as COVID Safe.

Last updated: 20 November 2020