New code for Facial Recognition Technology in New South Wales aims to improve legacy self-exclusion problems | AGB
Summary
New South Wales government has introduced a new Code for Facial Recognition Technology (FRT) aimed at improving the effectiveness of gambling self-exclusion registers in hotels and clubs. The code is not primary legislation but places substantially greater responsibilities on operators to use FRT to identify and manage excluded patrons.
The measures combine requirements for how facial data is used, who can access it, and how it must be stored and reported. While intended to strengthen harm-minimisation and reduce problem gambling, the code has prompted concerns about data privacy, implementation costs and increased compliance risk for operators and venues.
Key Points
- NSW has released a new Code for Facial Recognition Technology focused on improving gambling self-exclusion effectiveness in hotels and clubs.
- The code increases operators’ responsibilities — though not legislated, compliance expectations are significantly raised.
- Strict controls are proposed for data use, access, storage and reporting to address privacy concerns and reduce misuse.
- Operators will likely face higher implementation costs, procurement considerations and potential legal or reputational risk if systems are mismanaged.
- The code aligns with broader industry trends toward tech-driven harm-minimisation but highlights tensions between public safety and data privacy.
Context and Relevance
This change matters to venue operators, compliance teams, technology suppliers and policy watchers. Governments globally are increasingly mandating or encouraging use of technology to tackle gambling harm — NSW’s code is a clear example of that push. For operators, the code signals that passive compliance is no longer sufficient: venues must evaluate their systems, data governance and vendor contracts to meet the new expectations.
For technology vendors and integrators, the code creates market opportunity but also forces higher standards around privacy-by-design, audit trails and transparency. Regulators and consumer advocates will watch how the balance between harm prevention and individual privacy is managed as implementation proceeds.
Why should I read this?
Short and sharp: if you work in a venue, run compliance, supply FRT tech or advise operators — this directly affects you. It ramps up what regulators expect, nudges the market towards stricter data controls, and could change procurement and operating costs. We skimmed the detail so you don’t have to — but don’t ignore it.