Important changes to record keeping for contact tracing

Important changes to contact tracing requirements

Note:

From 1am AEST Wednesday 23 December there are changes to the Restrictions on Businesses, Activities and Undertakings Direction and requirements for recording contact information. Businesses should check regularly to ensure they are meeting current requirements.

Current record keeping requirements

Since the pandemic began, businesses have been required to keep contact information for a minimum of 30 days.  This has been required so that our contact tracers can move quickly and contact trace anyone who might have come into contact with someone with COVID-19.

This requirement is set out in the Restrictions on Businesses, Activities and Undertakings Direction.  

Contact information means information that is:

  1. the name, phone number, email address, and the date and time period of guests, patrons and staff; and
  2. provided to a public health officer within a stated time, if requested by a public health officer; and
  3. securely stored, not used for any other purpose; and
  4. deleted after not less than 30 days and not more than 56 days.

Businesses must take reasonable steps to ensure that the contact information collected is accurate.

New electronic record keeping requirements

As of 1:00am Wednesday 23 December, all businesses in the hospitality industry (such as pubs, clubs, restaurants and cafés) in Queensland must comply with new electronic contact information collection requirements per the Restrictions on Businesses, Activities and Undertakings Direction. The Direction will be updated to reflect this requirement. This is due to the high risk nature of the hospitality industry.

Over the coming weeks, it will be determined whether these expanded electronic record keeping requirements will be rolled out across other industries. This will be decided based on a risk assessment of other businesses and venues.

What will this mean for businesses?

  • Businesses must now move away from paper-based record keeping methods; and
  • Businesses need to have an electronic form or other digital method to capture contact information.

Who does this apply to?

This new restriction will apply to all Queensland businesses in the hospitality industry (such as pubs, clubs, restaurants and cafés).

If these businesses already have an electronic or digital means to do this, we are not asking them to implement another system.

What does electronic mean?

There are a variety of electronic methods businesses can use to adhere to restrictions.

These could vary from:

  • QR codes
  • Online fillable forms
  • Online booking systems
  • Digital spreadsheet

If a business already has an online booking system that captures patron information, there is no need for a secondary form of digital record keeping. This restriction is ensuring that all businesses in the hospitality industry are moving away from paper-based record keeping, and that the digital information can be provided in a timely manner upon request.

It is imperative that contact tracers can use legible and accurate information to contact people.

Do we need to comply and what are the penalties?

Yes, as of 1:00am Wednesday 23 December, all businesses in hospitality industry (such as pubs, clubs, restaurants and cafés) will need to comply with this requirement and will need to establish processes to ensure patrons contact information is collected electronically. In the coming weeks, it will be determined whether other industries will need to comply with this new requirement.

If requested by a Public Health Officer, the electronic data set will need to be provided in a timely manner. Public Health Officers will be conducting random audits to ensure businesses are complying.

Businesses are required to keep contact details for all patrons for a minimum of 30 days and a maximum of 56 days.

Businesses that are unable to comply with the requirement to collect contact information electronically, whether because a patron is unable to provide their information electronically (for example, because they do not have a smart phone) or because of unforeseen circumstances (such as an internet outage) will be required to:

  • collect contact information using another method (for example, paper-based forms); and
  • transfer the information to an electronic system within 24 hours.

A person who owns, controls or operates a restricted business activity or undertaking may be fined/penalised if they fail to keep electronic contact information about all guests, patrons and staff.  Failure to comply will impose:

  • operating with an occupant density limit of one person per 4 square metres;
  • for food and drink venues (including cafes, restaurants, pubs and clubs), operating for seated patrons only;
  • maximum penalty – 100 penalty units or 6 months imprisonment.

Find out more about the changes to collecting contact information requirements.

Last updated:
23 December 2020