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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.

Key points

  • From 11:59pm 6 December 2020 businesses may apply the two square metre rule if they use electronic record keeping to record the details of anyone who spends more than 15 minutes at their business. Otherwise, the four square metre rule applies for manual means of record keeping. Retailers should keep electronic records where practical to do so.
  • Businesses are strongly encouraged to use QR codes to support contact tracing. For more information on this free service see Victorian Government QR Code Service.
  • A Visitor and patron contacts log - Coronavirus (COVID-19) contact tracing register is available for businesses using manual processes such as pen and paper.
  • Businesses across the state can now access information on dealing with coronavirus (COVID-19) by calling the Business Victoria hotline on 13 22 15.

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:

  • first name
  • phone number.

Businesses are strongly encouraged to use QR codes to support contact tracing. For more information on this free service see Victorian Government QR Code Service.

For a copy of the Visitor and patron contacts log - Coronavirus (COVID-19) contact tracing register, see Signs, posters and templates for your workplace.

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.

Pens used to record details should be wiped with an alcohol wipe between users. Customers should be encouraged to use their own pen, if they have one, to minimise the sharing of pens.

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.

Which workplaces and premises need to keep records?

The following workplaces, premises and facilities must request and keep a record of the first name and contact phone number of the people who have attended:

  • a physical recreation facility including those exclusively used by a single professional sporting team
  • a community facility
  • a venue that is hosting a wedding or a funeral
  • a library or other community facility
  • an arena or stadium being used exclusively for training by a single professional sporting team or providing a venue for a professional sporting event 
  • a place of worship that is hosting a wedding, funeral or ceremony
  • a hairdresser, beauty service and a barber shop  
  • a swimming pool including those used by a single professional sporting team
  • a residential property at which there is an auction or an inspection
  • an outdoor personal training facility
  • a restaurant, pub, bar or café
  • an auction house
  • a gallery, museum, national institution or historic site
  • all other facilities that are work premises (with some exceptions). For further information, see the Workplace Directions on the DHHS website.

It is important to remember other restrictions (beside record keeping) are also likely to apply to these facilities.

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

Records should 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 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 first 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.

Does my business need to use a QR code?

Businesses are strongly encouraged to use QR codes for record keeping that will support contact tracing if required.

Businesses, except retailers, that are applying the two square metre rule must use electronic recording keeping. If records are kept manually, the four square metre rule applies.

Retailers should keep electronic records, if practicable.

QR codes are a barcode that a patron scans using their smart phone camera. The QR code takes the patron to a website where they enter their details.

The Victorian Government QR Code Service is free for all Victorian businesses and venues. For more information on this service see Victorian Government QR Code Service.

Businesses are strongly encouraged to use QR codes, however businesses may use manual processes such as pen and paper.

If QR codes are used for record keeping purposes, food and drink venues that are less than 200 square metres in size (that is, the total of all indoor space that is accessible to the public) can apply the two square metre rule up to a maximum of 50 patrons .

If a QR code is not used for record keeping in these food and drink venues, the four square metre rule will apply, up to a maximum of 50 patrons.

Other venues (including food and drink venues that are 200 square metres or more in size) can also choose to use QR codes to collect the necessary records of staff and patrons.

For patrons who do not have smart phones, staff can enter their details using the QR code or contact details can be manually recorded.

For more information on density limits, see Four, two and eight square metre rules.

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 manually record details using pen and paper.

Reviewed 06 December 2020

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Coronavirus (COVID-19) business support and the Industry Coordination Centre

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

Contact Business Victoria

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