Privacy Commissioner warns against paper-based contact tracing registers
Privacy Commissioner John Edwards is concerned that people are gaining access to personal information from paper-based
contact tracing registers and using it in ways that breach peoples’ privacy.
The Government’s introduction of mandatory record keeping requires businesses to display a QR Code and have an
alternative record keeping system, enabling them to collect contact tracing records in a privacy-protective way.
Ensuring businesses’ record keeping systems protect peoples’ privacy is a legal requirement under Privacy Act 2020.
Mr Edwards says although most organisations and businesses know they need to provide a manual alternative to the QR
Code, many are using paper registers that leave peoples’ contact details visible to members of the public.
“Using an open sheet or register left in a public-facing position where personal information is visible to others is a
leading cause of COVID-19-related privacy breaches. It’s important that businesses provide other methods of collecting
and storing contact tracing records, but in ways which also protect the privacy of those whose details are being
collected.”
The Office of the Privacy Commissioner has published guidance on mandatory record keeping for contact tracing.Privacy-protective ways of collecting and storing information for contact tracingSet up a ballot box with individual paper slips or cards for people to fill in the name, date, phone number and time.Have an employee manually record visitor details – this ensures that staff maintain control over the records and do not
leave contact information visible to others.Consider an electronic system, like a tablet sign-in app, work timesheet or an existing booking system.Use a special purpose work cell phone to receive texts from customers or visitors. Simply post the cell phone number
around the entrance to your service or organisation and let customers text you their name. The phone will automatically
record the phone number, date and time.
Other resources, including ballot box templates, are available on Unite Against COVID-19: https://covid19.govt.nz/posters/