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

 

[Roche1n]

I had a similar issue with camera use, and what helped me was checking how consent and notice were handled—especially on private property or vehicles. I’ve got Vivint security cameras at home, and even those needed clear signage under local laws. Whether it’s a bus or a private coach, the people being recorded usually need to be told about it, unless it's for lawful surveillance with proper signage.

 

[coachcapt]

There are TWO different systems with different regs for Qld (passenger) transport camera monitoring, that I have established:

DASHCAMS

- specifically to monitor driving environment (eg. traffic behaviour, bus driver behaviour, incident recording)
- they're NOT legally allowed to monitor passengers (because they can be easily accessed and manipulated, breaching the Privacy Act issues).
- relatively cheap and simple to setup and operate.
- you can see the dashcom examples I have collected on my school bus, which I use to demonstrate compliance or training matters here:

• https://youtu.be/N7x7MUJM2yE?si=wLR-_CBequyonWrW
  
• https://youtu.be/LPoF-ZGWCIw?si=9nQ28AzUP04vn9z4
  

CCTV

- specifically designed to monitor passengers for behaviour and vandalism, etc.
- closed system with sealed and restricted access to recordings - usually a hard-drive requiring physical link to download.
- 2 TMR Bulletins attached explaining the legal requirements for this system.
- relatively expensive to setup, but valuable for compliance and evidence.