Our site is publicly accessible. We are not an entity covered by the Privacy Act 1988 (Cth). Even so, we handle footage responsibly and in line with Victorian surveillance laws and the safeguards below.
1) What we collect
We operate security cameras and related monitoring systems in public-facing areas of the site. Cameras may capture images of people, vehicles and property, and associated metadata (e.g., timestamps, location).
We do not place cameras in toilets, washrooms, change rooms or lactation rooms.
Microphones are disabled on our security cameras. If any device incidentally captures sound, we do not use or publish it and will disable/strip audio wherever reasonably practicable.
2) Why we collect it (primary purposes)
Site safety & security (e.g., deterring, detecting and investigating vandalism, theft, hazards or misconduct).
Operations & maintenance (e.g., equipment troubleshooting, cleaning standards and fault diagnosis).
Training & service quality.
Incident management (e.g., handling complaints, insurance and legal claims).
Victorian law restricts observing or recording private activities and recording private conversations without consent. Our cameras are directed to non-private, public-facing areas. An activity carried on outside a building or where people ought reasonably expect to be seen is not a “private activity” under the Surveillance Devices Act 1999 (Vic).
3) Social media clips and other uses (secondary purposes)
We may share short video excerpts or stills from our CCTV for purposes connected with operating the car wash (e.g., safety education, service updates, equipment demos, incident warnings, community engagement). Clips may be edited for de-identification, cropping/framing, time/speed changes, stabilisation/quality adjustments, and annotations.
Safeguards: we use the minimum footage necessary, try to avoid publishing material that unreasonably identifies bystanders (especially children/vulnerable persons), and do not materially misrepresent what occurred. We do not post footage to ridicule or “name and shame”.
4) Legal basis & our compliance stance
Surveillance law (Vic). We comply with the Surveillance Devices Act 1999 (Vic), including not observing/recording private activities, not using listening devices to record private conversations without consent, and not publishing such recordings.
Workplace privacy. No cameras in toilets, washrooms, change rooms or lactation rooms.
Privacy Act (federal). Our small business is not covered by the Privacy Act 1988 (Cth). We nonetheless follow good practice (clear notices, limited use, secure storage, respectful handling).
5) Where footage is stored and who we share it with
Storage. Footage is stored in our CCTV system and/or a trusted cloud service with access controls.
Internal access. Access is limited to authorised personnel on a need-to-know basis.
Disclosures. We disclose footage only where reasonably necessary for the purposes above or required by law, including to:
Law enforcement/regulators (upon lawful request).
Insurers/brokers and professional advisers for claims and legal advice.
Service providers who support our CCTV/IT systems, under confidentiality obligations.
Limited disclosures to our family or close friends to assist with a specific operational need (e.g., locating lost property or resolving an equipment/safety issue), using only the minimum necessary excerpt, with an expectation of confidentiality and no onward sharing.
Social media platforms for the posts described in section 3 (platforms may process/store content overseas).
If you appear in a posted clip and have questions or want removal/further de-identification, contact us and/or use the platform’s reporting tools.
6) Security
We apply safeguards appropriate to the sensitivity of footage, including role-based access controls, device and account security, activity logging/audit trails, and secure deletion/overwriting. Service providers are subject to confidentiality obligations.
7) How long we keep footage
Routine footage is retained for up to 30 days and then automatically overwritten. Footage relevant to an incident, request, insurance claim or legal matter may be kept longer, but only for as long as reasonably necessary for that purpose.
8) Your options
Use in social posts: If you do not wish your appearance to be used on our social media, please contact us. We will consider removal or further de-identification where reasonable. We generally rely on footage recorded in public areas and aim to de-identify bystanders if necessary.
Access/copies. Although not bound by the federal Privacy Act, we will consider reasonable requests for copies of footage in which you appear where feasible and lawful and where doing so would not unreasonably affect others (we may require date/time/location to identify footage, and may redact third parties).
Complaints. If you believe a law has been breached, you may seek independent advice or contact Victoria Police.
9) Changes
We may update this policy to reflect operational or legal changes. The latest version will be available on our website and on-site upon request.