Our car wash 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).
Selected camera feeds may also be used for public live video broadcasts on social media.
We are testing an Automatic Number Plate Recognition (ALPR) system that reads vehicle registration plates and records associated images and detection information. Further details are provided in Section 5.
We do not place cameras in toilets.
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: Deterring, detecting and investigating vandalism, theft, hazards or misconduct.
- Operations & maintenance: Equipment troubleshooting, cleaning standards and fault diagnosis.
- Training & service quality.
- Incident management: 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".
Live video broadcasts are addressed separately in Section 4. ALPR is addressed in Section 5.
4) Live broadcasting
Purpose
From time to time, we may broadcast live video from selected cameras at Cruisers Car Wash to publicly accessible social media channels.
These broadcasts are intended for entertainment, community engagement, promotion of our facilities and providing viewers with an insight into everyday car washing activities.
What may be broadcast
Broadcasts may include footage from our manual washing bays, automatic washing bays, dog wash facilities and other public-facing areas of the premises.
Customers, staff, visitors, vehicles, vehicle registration plates and other identifying features may appear in the broadcasts.
Our broadcasts are video-only. We do not intentionally capture or broadcast audio.
The broadcast video is slightly blurred to help reduce identification of people, pets and vehicle number plates. However, people, vehicles and other details may still be identifiable.
Notification and customer choice
Signs at the entrance and in relevant washing areas advise customers that public broadcasting may occur.
Where an entrance notice indicates that broadcasyting is in progress, customers who do not wish to appear in a broadcast may choose not to enter the areas being broadcast.
Broadcasting may occur at scheduled or unscheduled times. Not all cameras or areas will necessarily be included in every broadcast.
Privacy safeguards
Our broadcasts are intended to show ordinary car washing activities, rather than deliberately identify individual customers.
We take reasonable steps to:
- Direct cameras towards public-facing washing and operational areas.
- Avoid broadcasting areas where individuals have a reasonable expectation of privacy.
- Avoid deliberately identifying, targeting or publicly tracking individual customers.
- Avoid using broadcasts to ridicule, embarrass or publicly shame customers.
- Interrupt, redirect or discontinue a broadcast where circumstances reasonably warrant it.
Because broadcasts occur in real time, people and vehicles may be identifiable, and it may not be practical to review or de-identify all footage before it is broadcast.
Public access and third-party recordings
Broadcasts are publicly accessible and may be viewed by people in Australia and overseas.
Social media platforms may process, store or retain broadcast footage according to their own terms and privacy policies.
Viewers may also capture screenshots, record broadcasts or redistribute footage without our knowledge or permission.
We cannot guarantee the removal of footage independently recorded, retained or distributed by third parties.
Recordings and highlights
We may retain selected recordings, screenshots or highlights from broadcasts for promotional, educational, operational or community engagement purposes.
Material retained or published for these purposes may remain available beyond our normal CCTV retention period.
5) Automatic License Plate Recognition (ALPR)
Current status and purposes
We are currently testing an in-house Automatic Number Plate Recognition (ALPR) system in selected public-facing areas of the car wash. The system is being evaluated for accuracy and reliability and may be used for site security, incident investigation and operational monitoring.
Local processing and storage
Our ALPR system operates entirely on equipment located at Cruisers Car Wash. Vehicle registration recognition, image processing and database storage are performed locally. ALPR images, registration numbers and detection records are not transmitted to external service providers for processing or storage during normal system operation.
Information collected
The system may detect and record:
- Vehicle registration numbers recognised by the cameras.
- Images of number plates and associated vehicle images.
- The date, time and camera location of each detection.
- Previous detection records associated with the same registration number.
ALPR uses automated image recognition and may occasionally misread a registration number. A registration number does not, by itself, establish the identity of the vehicle's driver or owner.
Use of information and alerts
ALPR records can be searched to review vehicle detections and assist with legitimate operational or security matters. The system can also be configured to issue alerts when particular registration numbers are detected. An alert is not, by itself, evidence of wrongdoing.
We do not link ALPR records to customer loyalty accounts, payment transactions or other customer databases, and do not use external registration databases to identify vehicle owners.
Access and sharing
ALPR records are protected by a secure login, with access restricted to the business owner. The ALPR database is not publicly accessible.
All ALPR processing and storage occurs on-site, and information is not routinely shared with external parties. Limited information may be transmitted to third-party services for operational notifications, or disclosed where reasonably necessary for incident investigations or as required by law, consistent with Section 7.
Retention during testing
We are still determining the appropriate retention period for ALPR images and detection records. We are considering a routine retention period of up to 90 days, with longer retention only where reasonably necessary for an incident, insurance claim or legal matter. Until a retention period and automatic deletion process have been finalised and implemented, records may be retained for longer during testing. This policy will be updated when those arrangements are confirmed.
Questions and accuracy concerns
If you have a question about an ALPR record or believe a registration number has been recorded incorrectly, please contact us using the contact details provided on our website.
6) Legal basis & our compliance stance
Surveillance law (Vic). We comply with the Surveillance Devices Act 1999 (Vic), including restrictions on observing or recording private activities, using listening devices to record private conversations without consent, and communicating or publishing protected 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).
7) Where footage is stored and who we share it with
Storage. CCTV footage is stored in our CCTV system and/or a trusted cloud service with access controls. ALPR detection records and associated images are stored in a separate access-controlled system.
Internal access. Access to non-public footage is limited to authorised personnel on a need-to-know basis. Access to the ALPR system is restricted to the business owner.
Disclosures. We disclose non-public 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 and their audiences for the posts and public broadcasts described in Sections 3 and 4. These platforms may process or store content overseas.
If you appear in published footage and have questions or want removal or further de-identification, contact us and/or use the platform's reporting tools.
8) 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 where applicable.
Publicly broadcast footage is accessible to viewers outside our control and cannot be protected in the same manner as footage retained within our CCTV system.
9) How long we keep footage
Routine CCTV footage is retained for up to 30 days and then automatically overwritten. ALPR images and detection records are handled separately, as explained in Section 5.
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.
Social media posts, selected livestream recordings, screenshots and highlights may be retained for longer than 30 days and may remain publicly accessible until we choose to remove them.
Social media platforms and third parties may independently retain copies beyond our control.
10) Your options
Live broadcasting. Signs at the entrance and relevant washing areas notify customers that livestreaming may occur. Customers who do not wish to appear in a livestream may choose not to enter the affected areas while broadcasting is in progress.
Use in social posts. If you do not wish your appearance to be used in our social media posts, 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 where necessary.
Previously broadcast footage. If you have concerns about identifiable footage of yourself appearing in a livestream or recording, please contact us. We will consider reasonable requests relating to material within our control. We cannot guarantee removal of footage already recorded or redistributed by third parties.
ALPR enquiries. If you have questions about ALPR records or their accuracy, please contact us. We will consider reasonable enquiries while taking account of other people's privacy and security concerns.
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.
11) 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.