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Record keeping for contact tracing - information for business

Information and advice for businesses and workplaces required to collect contact details from patrons.

Victoria moved to further relaxed COVIDSafe settings from 6:00pm on Friday 26 March 2021.

These changes are designed to balance getting Victorians back to doing the things they love while keeping in place measures to protect all that Victorians have worked so hard for. 

Key points

  • Record keeping continues to be an important tool for helping Victoria stay safe and stay open. 
  • All of the following venues and facilities must use the free Victorian Government QR Code Service or Victorian Government Application Programming Interface (API) linked digital record keeping system from March 26 (a 28-day compliance amnesty will be in place to 23 April 2021):
    • Hospitality (including food and drink facilities, such as cafes, restaurants, pubs, bars, clubs and hotels)
    • Indoor physical recreation and community sport (including staffed and unstaffed gyms, play centres, indoor skateparks and indoor trampolining centres)
    • Outdoor physical recreation and community sport facilities
    • Pools, spas, saunas, steam rooms and springs (indoor and outdoor spaces, including water or non-water part)
    • Ceremonies and religious gatherings (including places of worship)
    • Weddings: Record keeping requirements as per the venue where the wedding is held
    • Funerals: Record keeping requirements as per the venue where the funeral is held
    • Community venues and facilities including libraries and toy libraries (not including outdoor skate parks, playgrounds, and other outdoor communal areas)
    • Creative arts facilities
    • Real estate inspections and auctions
    • Seated entertainment venues (indoors and outdoors)
    • Indoor non-seated venues (such as galleries)
    • Outdoor non-seated entertainment venues (such as Zoos, live museums)
    • Arcades, escape rooms, bingo centres
    • Drive in cinemas
    • Amusement parks
    • Gaming (casinos, gaming machine areas, retail betting venues)
    • Adult entertainment (brothels, sex on premises venues, sexually explicit entertainment)
    • Nightclubs
    • Karaoke
    • Hairdressing, beauty and personal care services
    • Accommodation (visitors in shared, communal spaces) 
    • Commercial tourism operators including, but not limited to: 
    • Guided tours of museums, galleries, historic locations
    • Adventure sports (ballooning, abseiling, rock climbing, canoeing, kayaking,) 
    • Marine based tours (kayaking, scuba, fishing, surfing)
    • Commercial passenger vehicles (28-day compliance amnesty period was completed on 26 March 2021).
  • For supermarkets, markets, retail and shopping centres, it is highly recommended. 
  • All other venues and businesses not on this list are encouraged to use the free Victorian Government QR Code Service or the Victorian Government API (Application Programming Interface) to record keep. 
  • For more information on this free service see Victorian Government QR Code Service.
  • Businesses across the state can now access information on dealing with COVID-19 by calling the Business Victoria hotline on 13 22 15.

Which workplaces and premises are required to keep records?

Most customer-facing venues and facilities are required to use the free Victorian Government QR Service or Victorian Government Application Programming Interface linked digital system for electronic record keeping.

    • Hospitality (including food and drink facilities, such as cafes, restaurants, pubs, bars, clubs and hotels).
    • Indoor physical recreation and community sport (including staffed and unstaffed gyms, play centres, indoor skateparks and indoor trampolining centres)
    • Outdoor physical recreation and community sport facilities
    • Pools, spas, saunas, steam rooms and springs (indoor and outdoor spaces, including water or non-water part)
    • Ceremonies and religious gatherings (including places of worship)
    • Weddings: Record keeping requirements as per the venue where the wedding is held.
    • Funerals: Record keeping requirements as per the venue where the funeral is held.
    • Community venues and facilities including libraries and toy libraries (not including outdoor skate parks, playgrounds, and other outdoor communal areas) 
    • Creative arts facilities
    • Real estate inspections and auctions 
    • Seated entertainment venues (indoors and outdoors)
    • Indoor non-seated venues (such as galleries)
    • Outdoor non-seated entertainment venues (such as Zoos, live museums)
    • Arcades, escape rooms, bingo centres
    • Drive in cinemas
    • Amusement parks
    • Gaming (casinos, gaming machine areas, retail betting venues)
    • Adult entertainment (brothels, sex on premises venues, sexually explicit entertainment)
    • Nightclubs
    • Karaoke
    • Hairdressing, beauty and personal care services
    • Accommodation (vistors in shared, communal spaces)
    • Commercial tourism operators including, but not limited to: 
      • Guided tours of museums, galleries, historic locations 
      • Adventure sports (ballooning, abseiling, rock climbing, canoeing, kayaking)
      • Marine based tours (kayaking, scuba, fishing, surfing)
    • Commercial passenger vehicles (requirement  is from 26 March 2021 following the completion of the 28-day trial period)

Customer-facing venues that are recommended to use the free Victorian Government QR Service or Victorian Government Application Programming Interface linked system for record keeping:

    • Supermarkets 
    • Retail stores 
    • Retail shopping centres 
    • Markets or market stalls 

Venues required to use the free Victorian Government QR Code Service or Victorian Government Application Programming Interface (API) linked digital system for electronic record keeping will have a 28-day compliance amnesty, until 23 April, during which no fines will be provided to a venue. This provides venues with time to connect to the free Victorian Government QR Code Service or Victorian Government Application Programming Interface (API) linked system.

A venue must continue to keep records even when they are unable to collect records electronically (e.g. as there is no internet or mobile phone data coverage). This can be done through a non-electronic back-up if it is not possible to connect to a compliant service at that time.

A business must make reasonable efforts to ensure that customers can use a compliant record keeping system even in cases where a customer cannot access the system on their own device for some reason (e.g. they do not have a mobile phone). Note: this should include making a terminal (e.g. an iPad) available for customers to sign in, or staff assisting the customer to sign in. In exceptional circumstances where such an approach is not practicable, an alternative record keeping approach (including a non-electronic approach) can be used as a back-up.

Any customer-facing venues or businesses that are not listed in the above table are also encouraged, but not required, to use electronic record keeping through the free Victorian Government QR Code Service or Victorian Government Application Programming Interface (API) linked system.

Record keeping requirements

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:

  • name
  • phone number.

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.

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 businesses required to keep records, how long do records need to be kept?

Records must be kept for 28 days. This makes it likely that records will be available should contact tracers need to look back into who was potentially exposed to a confirmed case.

Should the records be destroyed after a certain period?

Records should be destroyed as soon as practicable after 28 days from the date of the service provided to the individual. This only applies to services where records are not normally kept, as this is a special type of record-keeping introduced by the Directions. Records that would ordinarily be made for health or other purposes should not be destroyed under these Directions, as they have their own statutory periods for required retention.

What if the person doesn't want to give their details?

Businesses should explain the purpose of keeping records is to help with any future contact tracing that may be necessary in slowing the spread of coronavirus (COVID-19). People may be reassured that they are only to give their name and a contact phone number, and that the records will be destroyed after 28 days, once the potential need for contact tracing has passed.

My business is using QR codes. What should we do if we have an outage or disruption?

If your business is using QR codes and the system you are using experiences an outage or disruption, then you can collect information through a non-electronic back-up if it is not possible to connect to an electronically compliant service at that time. 

A business must make reasonable efforts to ensure that customers can use a compliant record keeping system even in cases where a customer cannot access the system on their own device, for example, if they do not have a mobile phone. A business can support this customer by making a terminal available for customers to sign in, or staff assisting the customer to sign in.  

Reviewed 09 April 2021

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The Business Victoria hotline provides information on restrictions and support to help your workplace plan and respond to coronavirus (COVID-19).

Call Business Victoria on 13 22 15

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