QLD Bus/Coach - Private Dashcam v. Operator's CCTV

[coachcapt]

I have a strange interpretive challenge. I privately use a personal dashcam to confirm my compliance and evidence for incidents (front and rear-right traffic only):



I have been queried by Transport and Main Roads that it is a CCTV system, and as such needs to comly with ALL the requirements of the
(Information Bulletin PT 404/10.14) A recommended code of practice for the use of Closed Circuit Television (CCTV) by operators of passenger transport services and infrastructure.
I have also examined the related Information Bulletins:

Information Bulletin PT 405/09.12 Recommended specifications for Closed Circuit Television (CCTV) fitted in Queensland buses;
Information Bulletin PT 406/10.14 Recommended guideline for the installation and use of Closed Circuit Television (CCTV) in Queensland buses.

I have even looked at the perspective from personalised transport (eg. Uber, Taxis, Limos, etc):
Guidelines for the installation and use of personalised transport security cameras (Updated January 2023).

From what I have gathered, if the Dashcam is solely purposed to monitor traffic and bus operation (with NO recording of the interior, passengers or driver) it does not fit the definition of a CCTV system based on the purpose or mode of operation.
There are no internal privacy issues at risk.

Can anyone please advise regarding this interpretation, and pitfalls or compliance?

 

[Rod]

I'd be writing back and saying dash cameras (front and rear) are not CCTV.

The definition for CCTV is likely in AS 4806.1—2006, however I do not have access to that standard to confirm the definition.

Seems like typical bureaucratic overreach.

What is at risk here?

 

[coachcapt]

I'd be writing back and saying dash cameras (front and rear) are not CCTV.

The definition for CCTV is likely in AS 4806.1—2006, however I do not have access to that standard to confirm the definition.

Seems like typical bureaucratic overreach.

What is at risk here?

 

[coachcapt]

Thanks Rod.

It's mostly posturing with threats of non-compliance towards my employers by not placing signs as per Code of Pratice for CCTV ...

Appropriate signage must exist to inform the public that a CCTV system is operating. This signage should be easily visible to all passengers.

If it is not a CCTV as defined by the legislation (monitoring the interior for the purpose of passenger & driver safety and police investigations/evidence of incidents), the signs are superfluous (and erroneous).

I appreciate everyone's perspective, in case I missed something.

Cheers