Camera surveillance units

The Transport (Road Passenger Services) Regulations 2020 (the Regulations) require providers of on-demand booking services (ODBSs) and passenger transport vehicles (PTVs) to ensure that any vehicle used, or intended to be used for on-demand rank or hail work is fitted with a camera surveillance unit (CSU) that meets the Camera Surveillance Unit Standards 2020 (2020 Standards) and is in working order.

The 2020 Standards supersede previous versions of the Standards. 

Why is a CSU important?

Due to the anonymous nature of rank or hail work, it is important for on-demand rank or hail (taxi) PTVs to have a suitable type of CSU installed that meets the 2020 Standards – this protects both drivers and passengers.

When a taxi driver accepts a rank or hail job, limited trip details (such as passenger contact information) are recorded. In contrast, on-demand charter PTVs can only accept pre-booked work. This means that trip details are known prior to the driver accepting the job, and detailed records of who hired the vehicle, who drove the vehicle and the vehicle itself are recorded.

Other types of PTVs – such as on-demand charter or tourism – may choose to install a CSU, however this is not mandatory. Any CSU installed in a vehicle, where images may be recorded of people inside the vehicle, must be accompanied by signage and be operated in accordance with the Regulations.

	Camera Surveillance Unit Standards 2020	Kb
	Transport (Road Passenger Services) Regulations 2020

The Transport (Road Passenger Services) Regulations 2020 have introduced some significant changes to CSU requirements for taxis. 

By 1 July 2021:

• all taxis in Western Australia must have a CSU that meets the requirements of the 2020 Standards installed, including regional taxis;
• authorised ODBSs will be responsible for providing copies of recordings from CSUs when required; and
• authorised ODBSs can access CSU recordings for their own use in specific circumstances

	Transport (Road Passenger Services) Regulations 2020

In line with the chain of accountability framework in the Transport (Road Passenger Services) Act 2018, a greater responsibility is placed on ODBSs for ensuring that taxis meet mandated camera requirements. 

ODBSs are responsible for: 

• ensuring devices of the required standard are fitted in all taxi vehicles and are in working order;
• having systems in place to access and download recordings when requested by Department of Transport (DoT), Police, other agencies or for the ODBS’s own use;
• displaying signage to notify passengers that they are being recorded;
• maintaining processes to ensure that recordings are not used for unauthorised purposes; and
• ensuring that copies of recordings are stored for the minimum required time and properly disposed of as required in the Regulations.

Authorised uses of camera system recordings by ODBSs are outlined in the Regulations.

DoT recommends that ODBSs inspect every taxi when the CSU is first installed, and at least quarterly thereafter, for maintenance and compliance checks. CSU suppliers or installers should be contacted to obtain user manuals and support for specific CSU models.

To assist ODBSs in undertaking ongoing assessments of the CSU’s standards and operability, a Camera surveillance unit checklist template is provided below. 

CSUs in PTVs other than rank or hail (taxis)

Though CSUs are only mandated for taxis, the Regulations do apply some requirements to the use of CSUs in other categories of PTV.

If a CSU is installed in a PTV other than a taxi:

• a clearly visible sign notifying passengers that they are being recorded must be placed inside the front of the vehicle;
• recordings can only be used for authorised purposes as defined in the regulations; and
• copies of recordings must be provided to Police or Authorised Officers (such as DoT Education and Compliance Officers) when required.

	Transport (Road Passenger Services) Regulations 2020
	Camera surveillance unit checklist	Kb

Demand for CSUs will be high in the lead up to the installation deadline on 1 July 2021. It’s important to plan and act to ensure all taxis being dispatched work are compliant from July.

When deciding on which CSU type to install, ODBSs should consider:

How will you download recordings?

• It is the ODBS’s responsibility to access recordings when requested by DoT, Police or for their own use. ODBSs must have systems in place to access and provide copies of recordings from taxis they dispatch work to.

How will you maintain the device?

• ODBSs have an obligation to ensure CSUs are working at the required standard whenever the vehicle is operating. When choosing a device, think about how:
  • replacement parts will be sourced;
  • repairs will be made; and 
  • the device will be serviced.

Which device meets your business needs?

• ODBSs should try to choose a device that is simple to use and investigate any additional functionality that could boost their business – for example, many devices have wireless and remote downloading capabilities. 
• Some vehicles may require a modification approval in order to have a specific type of CSU installed. ODBSs should ensure they are aware of these requirements before choosing a specific CSU type. 

DoT has developed a checklist to help ODBSs ensure their CSUs meet the required standards (below).

	Camera surveillance unit checklist	Kb

The following devices have been assessed by DoT and found to be capable of meeting the requirements of the 2020 Standards as specified in the below table. 

Though these devices may be capable of meeting the required standard, it is the responsibility of service providers to ensure that they are installed and maintained in a way that complies with the relevant standard.

You may install a CSU that is not listed below, provided it meets the required Standards. Refer to the Transport (Road Passenger Services) Regulations 2020, 2020 Standards and Camera surveillance unit checklist (below) to help you decide whether a different CSU you have found is suitable.

	Camera Surveillance Unit Standards 2020	Kb
	Camera surveillance unit checklist	Kb
	Transport (Road Passenger Services) Regulations 2020

Applications for the inclusion of new system types in DoT’s list of suitable CSU devices for the WA rank or hail (taxi) market are encouraged.  

Suppliers who would like to market their product for use in WA rank or hail PTVs (taxis) should complete the Camera surveillance unit assessment application (below) and submit it via email to On-demand Transport. 

Submissions must include:

• a sample device with all related equipment to enable testing;
• instructional materials for the driver and the download operator;
• installation components and instructions;
• any items of equipment and software required to access recordings on the test device;
• details of any approvals in other Australian states or territories; and
• day/night testing footage recorded on camera's memory for testing and download.

You may also be asked to provide access to a test device installed in a vehicle for testing.

Submissions received will go through an assessment process which may include:

• running the system over the minimum 288 hours recording duration;
• accessing and copying recordings on the system;
• testing the system against current fluctuations; and
• assessment of image quality in both day and nighttime conditions, using the test chart available on the last page of the ANZPAA Recommendations for CCTV Systems.

Systems that meet some but not all of the required standards may be considered for inclusion in some circumstances. Devices approved in other Australian states that do not meet all of the requirements of the 2020 standards may also be included.

Important: Please note that depending on the installation of the CSU, suppliers and/or operators may require a modification permit for the camera mounting. This will be determined by the Authorised Inspection Station at the initial inspection. Details on how to determine if a vehicle modification permit is needed can be found on the Vehicle accessories and fittings webpage.

	Camera surveillance unit assessment application	Kb
	ANZPAA: Resolution test chart for use with ISO Standard 12233