Are QR Codes mandatory for NSW's ECEC services?

The short answer is no. QR codes are not mandatory for NSW's early childhood education and care (ECEC) services.

There appears to be new confusion over recent NSW Government public communications about making QR codes mandatory in all workplaces. Such confusion tends to arise when government messages are made through the media without adequate or any time to explain the reasonable exceptions and exemptions.

In fact, the NSW Government's actual announcement only makes its Service NSW QR codes or digital sign-in sheet mandatory for the following types of businesses from Monday, 12 July 2021 onwards:

• Retail businesses and supermarkets
• Individual shops within shopping centres 
• Shopping centres will also be asked to display QR codes at entry points where practicable
• Gyms
• Offices, including call centres
• Manufacturing and warehousing
• Universities and TAFE
• Schools including teachers and visitors (such as parents and contractors) but excluding students
• Hairdressers
• Hospitality businesses

And at the time of writing this article, there appears to be no change to the current set of NSW Public Health Orders as listed and explained in the Australian Childcare Alliance (ACA) NSW's COVID Member Alert (27 June 2021).

As such, it would appear that NSW's ECEC services continue to be exempt from this requirement.

It should be recognised that such exemptions have been consistently extended to NSW's ECEC services primarily because all ECEC services are already legally required to record all children, parents, visitors, contractors, educators, teachers and support staff's attendances and departures by virtue of:

1. the National Law and National Regulations
2. the Child Care Subsidy obligations
3. industrial relations obligations
4. risk management

And although the overwhelming majority of ECEC services already have electronic sign-in/out mechanisms in place, the minority of services who do not remain legally required to have other compatible systems in place.

Most importantly, introducing another layer of signing in/out by way of the Service NSW QR codes creates unnecessary confusion for our parents, not to mention the additional delays in terms of time to complete multiple registrations for no additional benefit than what ECEC services can already provide to NSW Health on request.

All of ACA NSW's past communiques (as follows) reinforce the continuing exemptions for NSW's ECEC services so that they do not have to introduce QR codes:

• 27 June 2021 - COVID Member Alert - Greater Sydney lockdown (see Q&A#2)
  
• 6 January 2021 - Updated: NSW Public Health Orders for the Northern Beaches
  
• 21 December 2020 - Explained: NSW's latest Public Health Orders (for Northern Beaches and NSW)
• 24 November 2020 - Clarification: QR Codes are NOT mandatory for NSW's ECEC services beginning 23 November 2020

Should ACA NSW members need further information/clarification, please do not hesitate to contact the ACA NSW team on 1300 556 330 or nsw@childcarealliance.org.au.

PUBLISHED: 1 JULY 2021