Contact tracing requirements for the hospitality industry

Important changes to contact tracing requirements


Published: 22 December 2020.
Updated: 23 March 2021.

Businesses can register to use the Check In Qld app to meet contract tracing requirements , and all Queenslanders can download and use the free and secure Check In Qld app to provide their details when they visit a venue using the app.

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, at a minimum, the name, phone number, email address, and the date and time of attendance of guests, patrons and staff.

Businesses are required to keep contact details for all patrons for a minimum of 30 days and a maximum of 56 days. Businesses must also take reasonable steps to ensure that the contact information collected from patrons is accurate, securely stored and not used for any other purpose.

New electronic record keeping requirements

Due to the high-risk nature, 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.

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

A risk assessment of other industries is being undertaken to determine whether these expanded electronic record keeping requirements will be rolled out across other industries.

What does electronic mean for businesses?

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

These could vary from:

  • Check In Qld app
  • QR codes
  • Online fillable forms
  • Online booking systems
  • Digital spreadsheet, e.g. Excel spreadsheet.

If your business already has an online booking system that captures patron information, you are not required to implement another system.

Find out ore about collecting customer information for contact tracing.

Why is this necessary?

This restriction is ensuring all businesses in the hospitality industry move away from paper-based record keeping so that information can be provided in a timely manner upon request.

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

Do we need to comply and what are the penalties?

Yes, all businesses in hospitality industry (such as pubs, clubs, restaurants and cafés) need to comply with this requirement and establish processes to ensure patrons contact information is collected electronically.

If requested by public health officer, the electronic data set will need to be provided within a stated time. Public health officers will be conducting random audits to ensure businesses are complying with this requirement.

Another method of collection of contact information (e.g. paper-based form) may be used when:

  • a person cannot provide the required information electronically, or
    For example, a person may be unable to use an electronic sign in system due to age, disability or language barriers
  • it is not possible to collect the information electronically due to unexpected circumstances
    For example, a temporary issue with an internet service or breakdown in the electronic system.

In these instances the information must be transferred into an electronic system within 24 hours of collection and kept electronically for a period of no less than 30 days and no more than 56 days (unless otherwise specified).

Businesses collecting personal data via electronic means (via an app or electronic point of sale) must ensure systems are privacy compliant.

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
  • 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:
24 March 2021