COVID-19 Coronavirus: Extension of Contact registers - Frequently Asked Questions (FAQs)

Guidance
Your extension of contact registers questions answered.

Last updated: 12 February 2021 at 5:19pm

What changes are being made for businesses required to maintain a contact register?

From Tuesday 2 February, recording of contact information is also required at the following venues:

  • retail venues and the retail components of other businesses
  • motor vehicles or boats which are capable of carrying 12 or more passengers and used on a commercial basis for a party, tour or function (such as party buses, wine and food tours and sightseeing tours)
  • takeaway food or drink services, excluding drive-through
  • food courts
  • a place where an event is held (including events requiring a  COVID Event Plan (500+ patrons)), and outdoor functions and gatherings that are weddings, corporate functions, festivals, carnivals, fetes, markets and funeral/memorial services.   

Please see below for a full description about what each of these includes. These businesses were not previously required to maintain a contact register.

How do I know if I am a retailer? What’s the definition of retail?

Retail venues include any part of a place of business to which the public has access for the purpose of obtaining retail goods or services, whether for personal, household or business use, excluding drive through. It includes the retail components of businesses that are not solely retail trade, but have customer-facing retail components.

This includes but is not limited to:

  • department stores;
  • pharmacies;
  • supermarkets, grocers, bakeries, butcher's shops, fishmongers, convenience stores, delicatessens;
  • "cash 'n' carry" premises;
  • hardware stores, furniture stores, electrical stores, recreational goods stores, clothing and footwear stores, newsagents;
  • motor vehicle repairers;
  • bank branches (ATMs excluded)
  • post offices
  • Customer service branches of insurers e.g. Medibank Private, HBF etc.
  • manufacturers' customer facing showrooms
  • Part of a place used to engage in retail sales of produce from agriculture and food production direct to the public.

Do I have to check in at the shopping centre entrance and then at the different stores I visit as well?

You are not required to record contact information on entering a shopping centre.

You are required to record contact information at each store and at any food court and gatherings held in common areas within shopping centres (e.g. concerts, Santa photos) that you visit within a shopping centre.

I’m a small retailer and do not have any staff. How do I ensure patrons are checking in to my shop if I am assisting other customers? Will I be fined if I am unable to make sure they have checked in?

If you do not have additional staff, ensure your contact register is displayed in a prominent position at your premises where people can easily complete the register (by either scanning the QR code or filling in a paper-based register). You should display the QR code in multiple locations to make it easy for people to check-in, for example at the entrance/s to the premises and at the service counter.

It is now also mandatory for people to check into venues required to keep a contact register, so they may also face penalties for failing to check-in and remaining at the venue.

We all have a community responsibility to keep one another safe. Displaying the contact register in prominent positions within your premises is a good reminder to customers to provide their contact details and of their role in ensuring WA can carry out effective contact tracing should it be required in the event of an outbreak.

A reasonable and common sense approach will be taken to enforcement, based on best endeavours. Prominently displaying your contact register is also an easy way to demonstrate you are maintaining one and will assist with you meeting your obligations.

Am I considered retail if I own and operate a takeaway Lotterywest kiosk in the middle of a shopping centre?

Yes.

If I visit a multi-premises venue (such as a shopping centre or Crown Casino) do I need to check-in at each individual business or venue within the complex?

Yes. You are required to check-in at each individual business or venue that you enter that is required to request contact information even if that venue may be part of a larger complex.

What’s the requirement for events and outdoor functions/gatherings?

The requirement for a mandatory contact register has extended to:

  • events required to have a COVID Event Plan (500+ patrons)
  • outdoor functions and gatherings that are weddings, corporate functions, festivals, carnivals, fetes, markets and funeral/memorial services.  

It is up to the organiser how they keep their contact register. The register must include attendees’ names, phone numbers, date and time they entered the place of the event or function/gathering.

Refer to COVID Event Guidelines for further information and COVID Event Plans – FAQs.

What’s considered an outdoor function or gathering? Does this extend to small family picnics in the park etc.?

Outdoor functions and gatherings in public places for which recording of contact information is required are weddings, corporate events, festivals/carnivals, community fetes and markets (including food or pop up markets), funerals and memorial services. This has been introduced as there was previously limited ability to contact trace attendees at these functions, where there can be mixing of a large number of individuals from different households, and they are held in large public open spaces.

Although you may not be required to keep a register for other family functions, make sure you all still follow physical distancing guidelines. It is also a good idea to have the contact details of everyone that attends in the event that contact tracing is required.

Do I have to keep a contact register for my wedding?

The venues where your wedding and reception are being held may be required to record contact information, including any venue that is an outdoor area in a public place.

Where you are holding your wedding in an outdoor public place which is not a ‘venue’, it is your responsibility to maintain a contact register. You can choose to use an electronic check in method such as SafeWA Code (details of how you can obtain one can be found at [insert link], or maintain a detailed guest list, with contact details and details of any contractors (caterers, photographers etc).

Do I have to keep a contact register for a funeral?

Yes. Contact registration is required for any place that is an outdoor area in a public place when used for a funeral or memorial service or a gathering after a funeral or memorial service, or any place that is a funeral parlour or other indoor area when used for a funeral service.    

What is considered takeaway? Does this include outdoor takeaway food trucks?

Businesses that involve the sale of takeaway food and beverages are required to keep a mandatory contact register, regardless of the time people spend at the premises, except to the extent that the takeaway is sold in a drive through. This includes:

  • stand-alone takeaway stores e.g. fish and chip shops, café and espresso bars, pizza bars, kebab shops, fast food
  • takeaway food and beverage vendors in indoor markets.

It does not include businesses selling takeaway in a food court, or outdoor food and beverage trucks/carts e.g. coffee/food truck, ice-cream van.

If an outdoor food truck or vendor is part of an event or certain outdoor functions, like food markets, the event or function organisers would be required to keep a contact register. Similarly, for businesses selling takeaway in a food court, the operator of the food court is required to have a contact register.

I run a takeaway outlet within a shopping centre food court. Does each outlet need to have their own contact register?

No, a food court is required to have its own contact register which should be provided by the shopping centre/food court management. Individual takeaway vendors do not need to have their own register, but it is recommended that you display the food court QR code at your counter/s.

The dining area in the food court should also display multiple QR codes and/or paper based registers to enable people to check in.

You should contact management of your shopping centre/food court for further advice on this.

Do takeaway delivery drivers through ride share services need to check-in each time they enter a takeaway food store or restaurant?

Yes. The requirement to check-in applies to everyone entering the venue (subject to limited exceptions, such as if you are younger than 16 years old). There is no special exemption for delivery drivers.

What’s the requirement for drive-through bottle shops that have both retail and takeaway components?

The premises must maintain a contact register.

Anyone that physically enters the bottle shop premises (e.g. customer, staff, delivery driver, and contractor) is required to register their attendance.

Anyone who goes through the drive-through service to purchase their items and does not physically leave their car is not required to register their attendance.

Which commercial vehicles and vessels are required to have a contact register?

Commercial vehicles or vessels are required to keep a contact register if:

  • there is capacity to carry 12 or more people (including driver/skipper/staff), and
  • is used on a commercial basis for a party, tour or function.

This includes:

  • party/function vehicles/vessels
  • wine and food tour vehicles/vessels
  • hop on/hop off tour vehicles(e.g. Perth City Tour Bus)/vessels
  • vehicles and vessels used for sightseeing tours
  • vehicles and vessels used for activity-based tours.

I operate a tour bus/vessel. My ticketing/booking system captures all the information required for the contact register. Do I still need SafeWA or another type of contact register?

You are required to record contact information (name, phone number and date and time of entry) from all people entering the vehicle or vessel, including staff.  You must also maintain these records for at least 28 days and be able to produce details for contact tracing purposes within 3 hours.

I own a tour business with a fleet of vehicles/vessels. Do I have one QR code/contact register for all the vehicles in the fleet?

Contact registration is required for each commercial vehicle or vessel which is capable of carrying 12 or more passengers (including the driver) and is used for a party, tour or function.

Guidance on how each vehicle/vessel can be set up as a venue can be found at https://www.wa.gov.au/organisation/covid-communications/covid-19-coronavirus-safewa-guide-businesses (Step 3).

I own a boat that can carry 12+ people. Do I need to have a contact register if I am taking friends out fishing?

No, you don’t have to maintain a contact register for the private use of your own vehicle or boat that is not used on a commercial basis for parties, tours or functions.

I operate a hop on/hop off vehicle/boat tour. How can I make sure people are providing their details? Will I get fined if they don’t?

You should take reasonable steps to request each person entering the vehicle or boat to provide the person's contact information.

Ensure your contact register or QR code is displayed in prominent positions on the vehicle/boat where your passengers can easily view and scan the code/complete their details, including at the entrance/s.

You should consider displaying the contact register in multiple locations to make it easy for your passenger to check-in, for example at the entrance/s and behind or next to each seat.

We all have a community responsibility to keep one another safe. Displaying the contact register/QR code in prominent positions is a good reminder to passengers to provide their contact details and of their role in ensuring WA can carry out effective contact tracing should it be required in the event of an outbreak.

It is also mandatory for people entering venues to check into venues required to keep a contact register (or not stay at the venue), so they may also face penalties for failing to check-in.

I am hiring a bus for myself and 25 friends to travel to various wineries. Do I need to keep a contact register?

As you are hiring a bus with the capacity to carry more than 12 or more people for a party, tour or function, contact registration requirements apply and the bus operator should have a contact register. This could be through the SafeWA app, a paper-based or digital register on the bus which you and your friends are required to complete.

You should also register your attendance at wineries and other venues you may visit through their contact register.

I’m going on a sightseeing tour and bought tickets providing all my details. Do I still need to give my details for the contact register?

Yes, you are required to provide your contact information.  This may include, for example, any tour bus and venues visited on the tour.  Your details provided to a tour company when purchasing tickets may not be sufficient for contact tracing purposes at each place or venue that you enter on the tour.

Does the 12+ person capacity include driver/skipper and any staff?

The contact register requirements apply to a vehicle capable of carrying 12 or more people including driver/skipper and staff

A reasonable and common sense approach will be taken to enforcement, based on best endeavours. Prominently displaying your contact register is also an easy way to demonstrate you are maintaining one and will assist with you meeting your obligations.

Do I need to register my details when I take public transport?

It is not mandatory for you to check-in when taking public transport. However, if you use a SmartRider, you should ensure your contact details are registered online and current for contact tracing purposes.

You can register or update your details for your SmartRider through the Transperth websiteRegistering your SmartRider card.

Why are there QR codes on CAT buses and not on other buses?

Contact tracing on most public transport can be done via registered SmartRiders. You are encouraged to register your SmartRider and make sure your details are up to date to assist with this.

CAT buses have a SafeWA Code because you can’t use a SmartRider on these buses. SmartRider is not in use on these services.

Is it mandatory for me to tag on and off in Free Travel Zones?  If I tag on and tag off using my SmartRider in the Free Travel Zone, will I get charged?

Tagging on and off using a SmartRider in these zones will assist with contact tracing in the event of an outbreak. There will otherwise be no record of you having been on that bus.

You will not be charged for the trip if you remember to tag correctly.

Do I have to check-in when travelling in a taxi or ride-share vehicle?

No, because the number of people at any given time on these types of transport is limited, and contact tracing can be done via booking systems and credit card payments.

Why are these businesses only being included now?

A review of outbreaks in other jurisdictions has found at least half of positive COVID-19 cases visited retail outlets. Previously, retail contacts had been reviewed as casual contacts, but events in other jurisdictions have demonstrated transmission can occur in a short period of time.

Takeaway venues have also been linked to several outbreaks. The new requirement for takeaway venues to maintain a contact register reflects that operationally, many of these venues involve wait times that exceed 15 minutes during busy periods. Lessons learnt from other jurisdictions indicate in the event of an outbreak, a high proportion of case locations are likely to involve hospitality venues, including takeaway.

Additionally, there are new, more infectious strains of COVID-19 occurring across the world, and cases of the highly infectious UK strain have already entered Australia through hotel quarantine. Although there is currently no community transmission in WA, these changes are necessary to further strengthen our contact tracing capabilities. Contact tracing is one of the most effective measures in controlling the spread of COVID-19 and ensures potential chains of transmission are interrupted.

If there is an outbreak, we want to be able to contact trace as quickly as possible, to avoid further transmission and minimise disruption to business.

Why do large events need to keep a contact register now? Aren’t they already required to keep one as part of their COVID Event Plan?

Registration is standard for outdoor events in many jurisdictions. Prior to the expansion of contact registers in WA, the COVID Event Plans required event organisers to implement a ticketing or contact register system at certain types of events, including concerts, and music and other festivals.

However, lessons learnt from other jurisdictions indicate in the event of an outbreak, relying on ticketing and credit card information provides incomplete contact records for events, and delays in capturing contact tracing data.

Why do I have to offer the option of using SafeWA if I already have my own QR code to register patrons?

The use of alternative QR codes to collect contact information may cause delays in contact tracing and undermine user confidence regarding data usage.

Information obtained through the SafeWA app goes directly to WA Health, and is securely stored for at least 28 days, unless it is needed for contact tracing. This means contact information is not accessible for any other purpose.

Learnings from other jurisdictions have also found third party data is not timely for contact tracing. 

Who do I contact to report non-compliance?

It is a legal requirement for particular businesses and venues to keep a contact register. If you visit one of the businesses or venues required to maintain a contact register, but aren’t keeping one, you should contact 13 COVID (13 26843).

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.

What can businesses be fined for?

Penalties may be issued for the following:

  • not being able to produce contact records (penalty for business or occupier)
  • using contact details for purposes other than contact tracing, unless otherwise permitted by law (penalty for business or occupier)
  • There is no requirement for businesses/ occupiers to verify information provided by people.

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.

What can patrons be fined for?

It is mandatory for people entering and remaining at a venue to check-in to a venue that is required to keep a contact register. Penalties may be issued for failing to do so.

Penalties may also apply for providing false information in connection with the provision of contact details.

Failing to comply with these new requirements could result in penalties of up to $50,000 for an individual and $250,000 for a body corporate, or 12 months' imprisonment.

Who is authorised to inspect my premises and check that I am maintaining a contact register?

Under the Emergency Management Act 2005, authorised officers include:

  • WA Police officers
  • Environmental Health Officers (EHO’s), and
  • Department of Fire and Emergency Services (DFES) officers.

In addition to WA Police officers, EHO’s and DFES officers have been authorised for the purposes of enforcing these requirements - refer to Authorisation under s 61EMA for EHOs and DFES for further detail.

Page reviewed 25 February 2021