08/05/2026
NSW Releases New Facial Recognition Technology Code for Hotels & Clubs
Is your venue prepared to meet evolving expectations around Facial Recognition Technology use?
Liquor & Gaming NSW and the NSW Government have recently released the Voluntary Code of Practice: Facial Recognition Technology (FRT) for Hotels & Clubs. The Code outlines best practice, privacy, and security requirements for using FRT to identify self-excluded patrons in clubs and hotels.
The requirements in the Code are intended to apply to venues that already use FRT voluntarily, or those considering installing FRT for exclusion purposes.
While the Code is voluntary, it sets out clear expectations for the ethical and responsible use of FRT including:
• privacy risk identification
• hardware installation and maintenance
• signage display
• secure storage of patron's data
• data access and use
• system performance
• venue staff responses
Clubs are expected to document their FRT usage, demonstrating ethical and compliant operations specific to their venue. Without proper evidence, your venue risks non-compliance with privacy obligations and misses the opportunity to show stakeholders, patrons, and regulators that FRT is being used responsibly.
How can Barringtons support you?
Barringtons can assist your venue in implementing the Code of Practice and ensuring your venue can demonstrate ethical, documented FRT usage. Our services also include:
• Facial Recognition Risk Assessments: to identify operational and privacy risks in your venue utilising FRT.
• Data Privacy Impact Assessments: to ensure your FRT usage aligns with privacy legislation.
• Policy & Consent Frameworks: develop practical policies and consent procedures for staff and patrons.
• Technology Evaluation Pack: validate your system against the Code’s technical specifications and best-practice guidelines.
Our team can help you implement, document, and validate FRT usage in your venue or answer any questions you may have. Contact us at https://landing.barringtongroup.com.au/corporate-risk or [email protected]
