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.

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 on-demand charter 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 line with the Regulations.

CSUs in rank or hail (taxi) vehicles 

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 (taxi) 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 Camera surveillance unit checklist (below) details the requirements that a CSU in a taxi must meet. 

CSUs in wheelchair accessible vehicles (WAVs)

Due to the size and layout of wheelchair accessible vehicle (WAV) taxis, one camera may not be sufficient to capture all required areas of the vehicle.

ODBSs should work with their camera installer to ensure that the device chosen for the WAV has sufficient cameras to capture footage of all passengers from the torso up.

Visit Wheelchair accessible vehicles for more information about WAV specifications.

CSUs in other PTVs

Although 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, ensure the following requirements are met.

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

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 taxis and are in working order;
• having systems in place to access and download recordings when requested by DoT, Police, other agencies or for the ODBS’s own use;
• displaying signage on and in vehicles 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 no longer conducts CSU downloads directly. ODBSs who do not maintain a process for accessing recordings from their vehicles can be fined.

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 is provided below. 

When deciding on which CSU type to install, ODBSs should consider the following things.

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. 

Does the device come with a manual or other supporting resources?

As it is the ODBS’s responsibility to access recordings and maintain operational CSUs, it’s important to ensure your device comes with resources to help you do this. Look out for devices that come with manuals, training resources and technical support to help you meet your CSU responsibilities. 

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

The following devices have been assessed by DoT and found to be capable of meeting the requirements of the Camera Surveillance Unit Standards 2020 (the Standards) which govern the use of camera surveillance unit (CSU) devices in taxis. A copy of the standards is provided below. 

You may install a CSU that is not listed, provided it meets the requirements of the standards. 

The standards do not apply to CSU installed in vehicles other than taxis however the Regulations do provide requirements for the management of CSU recordings in both taxis and other passenger transport vehicles. 

The Camera surveillance unit checklist provided below will help you decide whether a CSU device is suitable for use in a taxi.

It is the ODBS's responsibility to ensure that CSU devices are installed and maintained in a way that complies with the standards, and that recordings are properly stored and managed.  

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.