Facial Recognition Technology (FRT) will become mandatory in NSW in 2028, alongside the introduction of the NSW State Exclusion Register.
The changes will require venues to use FRT to help identify people who have self-excluded and ensure those exclusions are effectively enforced.
Whilst 2028 may seem some way off, venues using or considering FRT now should be preparing for the changes and ensuring their systems, processes and privacy practices are aligned with the requirements already outlined in the Voluntary Code of Practice: Facial Recognition Technology (FRT) for Hotels & Clubs.
What’s changing?
The introduction of mandatory FRT alongside the State Exclusion Register will mean venues need to consider more than just having the technology in place.
Venues will need to ensure they have appropriate processes in place for ethical and responsible use, 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
The existing Voluntary Code provides a framework for responsible FRT implementation, covering privacy, security, technology and operational requirements. Preparing against these expectations now can help venues move towards the mandatory requirements with greater confidence. For more information on the 2028 changes, please click here.
How can Barringtons support you?
Barringtons can work with your venue to understand what the upcoming requirements mean for your operations, identify any gaps and provide practical guidance to help you prepare for the future changes. 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.
Don’t wait until questions arise. Let us help you implement, document, and validate FRT usage in your venue. Contact us today!

