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Contact register requirements WA

Jonathan Shaw

Contact registers and you

With rising infection rates internationally and second and third wave outbreaks occurring in many parts of the world, it is important that Western Australia continues to have appropriate systems in place to keep the community safe for the long term.

From 5 December 2020, particular businesses will be required to maintain contact registers for WA Health Department COVID-19 contact tracing, if required.

Contact registration is encouraged but not mandatory for other businesses and gatherings. Providing contact details helps make contact tracing more efficient, if it becomes necessary. This helps stop the spread of COVID-19 infection.

In the event of COVID-19 being detected in the WA community, contact registers help to protect the community by providing information to the WA Health contact tracing team, which enables them to quickly identify and assist anyone that may have been exposed to COVID-19.

Contact tracing is one of the most effective measures in controlling the spread of COVID-19 if an outbreak occurred. Contact tracing involves identifying individuals who may have been exposed to an infectious case of COVID-19 and having these people avoid contact with others until we can be sure they are not going to develop the disease.

If someone becomes infected while in quarantine, they can be promptly diagnosed and treated appropriately. In addition, because they are in quarantine the number of persons they might infect is greatly reduced. This key contact tracing work ensures potential chains of transmission are interrupted.

Which businesses are required to maintain a contact register?

From 5 December 2020, the following businesses will be required to maintain contact registers for the purposes of WA Health Department COVID-19 contact tracing, should it be required:

  • food and licensed venues (restaurants, cafés, bars, pubs, taverns, nightclubs)
  • gyms, indoor sporting centres, wellness centres, health clubs and fitness centres
  • indoor play centres
  • saunas and bathhouses
  • swimming pool, both indoors and outdoors
  • places of worship, and funeral parlours
  • beauty and personal care services (hairdressers, barbers, nail salons, tattoo parlours, spa and massage parlours)
  • galleries and museums
  • cinemas, theatres and other entertainment venues (casino, gaming or gambling venues)
  • auction houses and real estate inspections
  • community facilities, libraries and halls
  • zoos and amusement parks
  • function centres
  • hotels, motels, campgrounds or other accommodation facilities that ordinarily have check-in arrangements
  • boarding schools or residential colleges (not including residents)
  • adult entertainment premises (strip clubs, brothels and sex on premises venues)

Contact registration is encouraged, but not mandatory for other businesses and gatherings.

Refer to the Closure and Restriction (Limit the Spread) Direction (No.9) for a more detailed list of particular businesses and venues.

How do I register contacts — which modes of registration are acceptable?

The requirement to register contacts for particular businesses is mandatory. However, provided they collect the necessary details, the business owner can decide the method best suited to their business operations and patrons.

The WA Government has developed a free app, SafeWA, which provides businesses with a method to keep a digital contact register system, endorsed by the Department of Health.

The use of the free SafeWA contact register app is encouraged, because it is easy to use, hygienic, protects patrons’ privacy and is efficient for contact tracing.

However, businesses must have an alternative (manual) method of registering patron details, such as a paper-based register or electronic version such as Fitbrix.

This will ensure access to their premises is inclusive and allows patrons that may not have access or choose not to use the SafeWA app to have an alternative registration method. The WA Government has developed a suggested format for businesses to use for paper-based registers.

Businesses may choose to use other electronic sign-in methods of registration. If they use an electronic system different to the SafeWA contact register app, they will need to ensure the method they choose complies with the legal requirements. This includes storing the information collected for 28 days and making it available to WA Health if required.

What information do I need to record in a contact register?

The contact register must record the name, contact telephone number, location, date and arrival time of patrons.

Do I need to record the details of everyone that visits my premises?

Businesses are required to request the contact details of each person that appears to be aged 16 years and over who enters a place listed above, including patrons, staff, volunteers and contractors.

Records are not required to be collected for:

  • people collecting takeaway (food or drink to be consumed off the premises)
  • children under 16 years
  • people entering for medical or emergency purposes
  • people who reside at a boarding schools and residential college
  • where a place is used for an event for which there is an approved COVID Event Plan that does not require it.

Unaccompanied children under 16 are encouraged but not required to register. Adults accompanying children under 16 are encouraged to register for them.

Who is responsible for maintaining the contact register?

The occupier or other person apparently in charge of a place is required to maintain a contact register.

For example, the occupier or other person in charge of a restaurant will be required to maintain a register of anyone entering the premises.

If a local hall is hired for a function, the occupier or other person in charge is responsible for maintaining the register for the period of the function.

How does the SafeWA app contact register work?

  1. Businesses are issued with a unique, free QR code when they download the SafeWA app through the Apple or Google Play App Store and register their venue(s).
  2. The business can print hard copies of the QR code on posters that are placed in the premises and/or use an electronic device (such as a tablet) to display the QR code.
  3. When a patron arrives at the businesses’ premises, they use the SafeWA app to scan the QR code.
  4. The smartphone reads the code and one of two things will happen:
  • the patron will be asked to download the SafeWA app if they haven’t already (in the app they will be required to input their name and contact phone number)
  • if the patron already has the app, they will be checked-in and see a confirmation on their device
  1. Through the check-in process, the patron’s name and telephone number as well as the date and time they attended the venue, are collected and stored in the WA Health database.
  2. A staff member at the premises may choose to check the successful sign-in on the patron’s phone

How does the Fitbrix app contact register work?

  1. Businesses download Fitbrix app from the Apple or Google Play App Store and register their venue(s).
  2. The business sets the capacity of there venue and location of the premises and patrons can secure a place before they arrive
  3. When a patron arrives at the businesses’ premises, the business owner checks them in via the app.
  4. The smartphone records the patrons details securely in the background and one of two things will happen:
  • the patron will be asked to download Fitbrix and register their details (in the app they will be required to input their name and contact phone number)
  • if the patron already has the app, they will be checked-in and see a confirmation on their device
  1. Through the check-in process, the patron’s name and telephone number as well as the date and time they attended the venue, are collected and stored in a secure database.
  2. A staff member at the premises may choose to check the successful sign-in on the patron’s phone.

What system requirements does my business need to support the QR code system?

To register for your venue QR code you need access to the internet, a smartphone or tablet, then a printer to print and display the QR code poster at your venue.

You can also display the QR code electronically, e.g. on a tablet device for your patrons to scan.

SafeWA is accessible only if you have a compatible smartphone. SafeWA is compatible with Apple iPhone model 5S (and later) with iOS 9.3 (and higher), plus most Google Android mobile devices running Android 5.0 (and higher).

What system requirements does my business need to support the Fitbrix system?

To register with Fitbrix you need access to the internet, a smartphone or tablet,

Fitbrix is accessible only if you have a compatible smartphone. Fitbrix is compatible with all Apple iPhone models running iOS, plus all Google Android mobile devices.

What’s the difference between the SafeWA App and Fitbrix, and which is mandatory?

Contact registration is mandatory for particular businesses. The way(s) patron contact details are collected is the decision of each business. As individuals are required to provide their details, it is important to have accessible means available to them so that they can provide their details easily.

The WA Government has developed a free digital contact register app called SafeWA, as an efficient and safe way to record patron and visitor contact details where they can check-in, using the app.

The SafeWA contact register app utilises QR code technology to register a patron’s attendance at particular businesses and venues.

The SafeWA contact register app is one of the methods businesses can use as an easy, secure and hygienic method of meeting the requirements of the direction.

Businesses that use the SafeWA app are also required to have an alternative (manual) method of registering patron’s details, such as a paper-based register. This will ensure access to their premises is inclusive and allows patrons who do not use the SafeWA app to have an alternative registration method. The WA Government has developed a suggested format for businesses to use for paper-based registers.

The Fitbrix contact register utilises secure user verification to register a patron's attendance at particular businesses and venues. Patron does not require the app at first visit and a team member can add patrons details to the system through the business app if patron is unable to use other means. This ensures accessibility for elderly and disabled patrons and a paper based register is not required.

What is a QR code and how do I get it?

A QR code is just like a barcode, with information that can be read by a smartphone/tablet camera. The WA Government will provide businesses with free QR codes to display in their premises when a business chooses to use the SafeWA contact register app.

To obtain the QR code, businesses need to download the free SafeWA app from the Apple App Store or Google Play and register their business/venue(s). They will then receive a welcome pack which includes supporting information and a unique QR code for each venue.

Patrons and visitors will also be able to download the SafeWA app from the Apple App Store or the Google Play Store. Through the app, they can use their smartphone to scan the QR code on arrival to check in and register their contact details.

QR codes are convenient for businesses and patrons. They provide a hygienic, contactless way of signing in to a venue, allowing for seamless check in.

What if i dont like the QR code system?

If your business chooses not to use a QR code system, Fitbrix provides a private and secure system that registers contacts without the need of a QR code.

Businesses that use Fitbrix can add patrons details during service interactions to provide a friendly customer experience without the need of a paper register.

Why do I need to also offer an alternative to a QR code contact register for patrons to provide their contact details?

Not all patrons will have access to a smartphone or they may choose not to provide their details via the QR code. An alternative format for patrons to provide their contact details must be kept onsite. This could include a paper-based register and/or an electronic sign-in form. A template for a written contact register form is available on the Contact registers stakeholder toolkit page.

Alternatively you can choose an app that does not require patrons to have access to a smartphone such as Fitbrix

How do I protect the privacy of and ensure contact details aren’t accessible by others?

If your business keeps paper or electronic records, you are required to protect (using reasonable steps) patrons’ contact details from misuse or loss, and unauthorised access, modification or disclosure.  The WA Government has developed a suggested format for paper-based contact registration that involves placing completed paper slips into an enclosed container. Businesses may also choose to use other paper-based systems that keep registration details out of the view of other patrons.

Contact registers of people visiting the premises must record:

  • name
  • phone number
  • location
  • date
  • arrival time.

Where do I find my SafeWA QR code/s?

If you have registered your business through the SafeWA app, you will be emailed an information pack with your unique QR code/s and poster. Your QR code is also displayed when you log in to your SafeWA app.

Do I need to record contact details of my staff?

Yes, you are required to record the contact details of your staff, and any volunteers or contractors.

How long do I have to keep contact register records?

Contact register records must be kept for 28 days, or such longer period as required by the State Emergency Coordinator or a person authorised by the State Emergency Coordinator.

How should a business store contact information?

If your business uses the SafeWA contact register app, the data collected goes directly to WA Health. This means the data does not have to be stored by your business and it is readily available for WA Health to access if it becomes necessary for contact tracing.

If your business uses paper-based or electronic sign-in forms (or other methods) for contact registration, it is the responsibility of the occupier or other person apparently in charge of the place  to ensure that patron contact details are stored in a secure and confidential location.

This should be done in a manner that facilitates efficient retrieval if requested by an Authorised Officer and cannot be viewed or tampered with by other patrons.

Businesses will need to make sure that they comply with any legal obligations they have in relation to the collection, storage and use of patron’s contact details.

If I choose to use the SafeWA contact register app, will the WA Government subsidise the cost of using this software?

There is no cost to businesses or the public for using the SafeWA contact register app.

What happens if patrons visiting my premises don’t have a smartphone that supports using the QR code system?

It is a mandatory requirement of your business to request all patrons and visitors to your premises (including staff, volunteers and contractors) to provide their contact details. If your business uses the SafeWA app, you are required to provide an alternative method for patrons to provide their contact details in case they cannot or choose not to use the SafeWA app. This could be a paper-based register or an electronic sign-in form. A template for a written contact register form is available on the Contact registers stakeholder toolkit page.

Alternatives to QR code systems include Fitbrix which does not require patrons to have access to a smartphone.

What happens if my business does not maintain a contact register? What are the penalties?

It is a legal requirement for particular businesses to request all patrons who enter your premises (including staff, volunteers and contractors) to provide their contact details. When that information is provided directly to your business (not via the SafeWA app), you are required to keep a record of those contact details. . Not having a contact register may put the Western Australian community at risk, as it will slow the process for contact tracing if a COVID-19 affected patron visits your premises.

Businesses that put the community at risk in this way risk penalties under the Emergency Management Act 2005, including a fine of up to $50,000 for an individual and $250,000 for a body corporate, or 12 months imprisonment. Infringement notices can also be issued.

Penalties also apply to businesses for:

  • not being able to provide a record of the contact information  as soon as practicable, but no later than three hours, after the request is mad by a responsible officer e

or

  • not being able to produce a record of the contact information for inspection by an authorised officer on request for the purpose of checking compliance with the contact register requirements

or

  • using or disclosing contact information for purposes other than contact tracing, unless  permitted by law or if a person expressly provided their contact details for other purposes.

Individual patrons can also face penalties for:

  • providing false information in connection with the provision of their contact details

Or

  • entering a place after being requested to provide contact details and refusing to provide these details.

Am I responsible for ensuring contact information provided by patrons is accurate?

There is no requirement for businesses/occupiers to verify the accuracy of contact details provided.

Can I refuse entry to patrons who refuse to provide contact details?

Businesses are encouraged to exercise any existing legal rights to control who enters their premises by refusing entry to patrons who refuse to provide their contact details.

Individuals can face penalties for entering a premises after refusing to provide their contact details.

Does my business have to record details of minors who attend my premises?

If children under 16 years attend your business unaccompanied by an adult, they are not required to provide their contact details.

Adult patrons are encouraged to register accompanied minors under 16 years of age.

What happens with the data? Is the business responsible or the WA Government?

Contact register information collected through the SafeWA contact register app is stored securely for at least 28 days and accessed, only if needed, by WA Health contact tracers. This means the data is not stored by the business.

Businesses using a paper-based, electronic form or other method to keep a contact register are responsible for maintaining these records for a period of at least 28 days, or longer as required under the direction. Businesses are required to take reasonable steps to protect the contact information it holds from misuse and loss, and unauthorised access, modification or disclosure. This means contact information should not be sold, disclosed or used for marketing or research purposes, unless permitted by law or if a person expressly provided their contact details for other purposes.

Contact register information must be provided to a responsible officer as soon as practicable, but no later than three hours, or to an authorised officer for inspection (for compliance checking) upon request. Businesses can be penalised for using contact details for purposes other than contact tracing, unless permitted by law or if a person expressly provided their contact details for other purposes.

How will compliance be checked?

Authorised officers may inspect premises to monitor compliance with contact register requirements. A business must produce a record of the contact information for inspection by an authorised officer on request for the purpose of checking compliance with the contact register requirements.

At venues like nightclubs where your ID is scanned, is a secondary contact register required?

Yes, a contact register is still required because an ID does not contain sufficient contact details to facilitate effective contact tracing if required.

All venues must record the date, name, telephone number and arrival time for every patron entering the premises.

How do patrons check in to a campground if there are no staff onsite?

If a campground does not have an existing check-in process for visitors (e.g. no monitoring when visitors arrive/depart, no keys to collect) they are not required to maintain a contact register.

Are indoor food markets and/or outdoor farmers markets required to maintain a contact register? In some cases they have a designated dining area for the food vendors. Are they exempt like food courts?

Most indoor and outdoor food markets are considered under the same classification as a food court (food is served in a takeaway style) so they are not required to keep a contact register.

Do people staying in accommodation facilities need to register their attendance each time they re-enter over the course of their stay?

Accommodation facilities that already have check-in arrangements in place (such as hotels) are required to keep a contact register of all guests. A guest is required to provide their contact details when they first arrive at and enter the facility, however they are not required to provide their contact details each time they leave and re-enter during their stay.

If patrons have the COVID Safe App, does my business still need a contact register and/or contact register app?

Yes. The contact register is a separate data repository and the SafeWA contact register app uses different technology than that used by the Australian Government’s COVID Safe App.

How is the data stored on SafeWA?

Data is encrypted at the point of capture and stored securely for at least 28 days.

How is the data stored on Fitbrix?

Data is encrypted at the point of capture and stored securely for at least 28 days.

Where do I put the QR code at my business?

Your QR code should be displayed in a prominent position at your premises where your patrons can easily view and scan the code, preferably at the entrance/s.

You may display the QR code in multiple locations to make it easy for your patrons to check-in, for example at the entrance/s to the premises and at the service counter.

How many of my staff members can access the SafeWA business account at the same time?

There is no limit to the number of users who can access the SafeWA business account to check patrons in if required.

How many people can I register for my business as administrators of the SafeWA app?

Each business can register a primary contact and a secondary contact. This enables WA Heath to contact the relevant business if contact tracing is required.

How many people can I register for my business as administrators of the Fitbrix app?

Each business can register an entire team of employees. This enables everyone on the team to be able to check patron's in while contact tracing is required.

Does the SafeWA app have a confirmation screen that staff at a venue can check to ensure patrons have scanned the QR code on entry? If so, are staff obliged to check this has been done?

If patrons use the SafeWA app to check-in at a venue, a confirmation screen will appear on their device once they have successfully checked-in.

Businesses are required to request the contact details of each person that enters their premises, but are not required to verify or confirm the accuracy of the information provided. Where possible, staff are encouraged to ensure patrons have checked-in either through the SafeWA app or the venue’s contact register. However, there is no obligation to do so.

Does the Fitbrix app have a confirmation screen that staff at a venue can check to ensure patrons have registered on entry? If so, are staff obliged to check this has been done?

If patrons use the Fitbrix app to check-in at a venue, a confirmation screen will appear on their device once they have successfully checked-in.

Businesses are required to request the contact details of each person that enters their premises, businesses are not required to verify or confirm the accuracy of the information provided. With Fitbrix, Business owners and staff are able to visually confirm patrons have checked in via the app as they check-in which ensures business does not put community at risk.

How many additional people can an individual register on their app? Is there a maximum limit?

There is no maximum limit for individual registrations.

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