A celebrant asks:

 

RE NSW weddings

Covid sign in is doing my head in. Until recently I’ve asked couples to create their own Safety Plan(via https://www.nsw.gov.au/form/covid-safety-plan/wedding-ceremonies-and-receptions) to cover the ceremony, and reception too if that suits them. This way the couple becomes aware of their obligations and communications with guests, and guests/staff only have to sign in once for duration of wedding. The couple emails me their plan (I print and have at ceremony should it be asked for) and QR code (displayed for signing in), and couple organises someone to help those that need. Takes any pressure off me and covers all venues.

Also, I have my own safety plan that I provide couples and say, “where it says the couple will do xxx – that means you guys need to do that.” I don’t police anything.

Is this what other NSW celebrants are doing? Or what do they do? For all wedding venues, ie; public space, business venue, private home, community hall…

And… since it’s okay to record attendees on https://www.nsw.gov.au/sites/default/files/2020-09/COVID-19-record-of-visitors-at-premises-form.pdf, how do you/the responsible ‘business/couple’ upload that info into Services NSW to be used for contact tracing? I’ve called the NSW Services hotline and gotten nowhere. Does each entry on the sheet need to then be added manually via the online concierge? Um – not. gonna, happen.

I think the easiest way to be covid safe is for the couple to create a compatible spreadsheet of anticipated guests, organise someone to tick them off as they arrive, add any extra guests by hand. I’d be happy to collect the list after the ceremony and upload it to Services NSW under my business name – if only I could.

What are other celebrants doing? What is the simplest, compliant way?

Open to suggestion and constructive criticism:)

 

Because neither Josh nor I work much in NSW, I contacted friend-of-The-Celebrant-Institute (and one of our OPD trainers) Alison Pickel to put together this response for us!

I don’t blame you for being confused! Across the country, COVID-19 regulations are changing all the time and it can be hard to keep up. In NSW, changes such as the number of people who can be on the dance floor are pretty well advertised, but less sexy changes – such as new ways we must keep records – are less well signposted and easy to miss.

What can make it even more difficult is that there are multiple documents to which we need to refer, and the wedding COVID-19 Safety Plan has been written with wedding venues in mind – not celebrants conducting outdoor ceremonies. Also, the Safety Plan is a mix of legal obligations and suggestions that are not requirements – it’s a minefield!

But to keep it as simple as possible, I’m going to address the main points in your question:

  • When is the celebrant responsible for COVID-19 Safety?
  • How should we collect attendee information?
  • How do we submit that information?
  • What are our other obligations as celebrants?
  • How do other NSW celebrants handle COVID responsibilities?

A caveat: I am not a lawyer. I have never had any kind of formal legal training. Everything below is general information based on my interpretation of the regulations. I’m also ONLY going to talk about NSW-specific regulations – sorry rest of Australia, Sarah and Josh will have to find another expert for you.

 

But first, some background

At the time of writing this article (9th March 2021) there are two separate documents that work together to outline all the COVID restrictions for weddings in NSW:

It’s important to check back on these regularly as they are changing all the time – what I write here today may not be relevant next week, so do your due diligence.

And in my experience, it’s usually much more useful to skip the National Coronavirus Hotline and go through Service NSW on 13 77 88 for any questions. However, even then a lot of the operators are just quoting from fact sheets and haven’t read the Public Health Order, so don’t be shy about asking to speak to someone else if you feel like your question isn’t being answered properly.

 

When is the celebrant responsible for COVID-19 Safety?

Short answer: only for ceremonies held in public places, such a park.

Long answer: Under the Public Health Order, a wedding is considered a “significant event” which is covered under Division 3. Section 18 states:

18 Definition

In this Division—

responsible person means—

(a) for a significant event held in a public park, a reserve or a public garden—the person organising the event or conducting the service, and

(b) for another significant event—the occupier of the premises.”

Here’s a quick table of what I think that means:

Wedding ceremony or reception location Responsible person
Public park, reserve or garden The celebrant and/or MC OR the wedding planner OR the couple
Wedding venue or community hall The venue operator
Private residence (outside Greater Sydney only) The people who live there

Note that currently weddings at private residences in Greater Sydney (including Wollongong and Central Coast) are not considered significant events and therefore don’t need safety plans – instead they operate under the residential premises rules which limits the number of visitors to 50.

 

What is the “responsible person” responsible for?

There are three key things the responsible person must do:

  1. Develop and comply a COVID-19 Safety Plan based on the approved checklist i.e., THIS – that also means they are responsible for ensuring other comply with the plan (Section 19(a)).
  2. Have a copy of the COVID-19 Safety Plan at the event, ready to present to an authorised officer or police officer on request (Section 19(b)).
  3. Comply with all record keeping requirements (Sections 41 (2 & 5)) – more on this below.

The responsible person must also make sure no more than 30 people are dancing at the same time (Section 21), but this is covered as part of the Safety Plan.

 

How must we collect information?

The relevant part how people must provide their information for civil wedding ceremonies is in Section 41(3)(c):

“ […] by electronically registering the person’s contact details by means of a mobile phone or other device at the time the person enters the premises with—

(i) Service NSW, or

(ii) the occupier of the premises.

Note. For example, electronically registering a person’s contact details may be by the use of a QR code or another electronic method that records the person’s name, telephone number or email address and the time at which the person entered the premises.”

Because of this, you must have a QR code or something similar for people to enter their details at a wedding. You can either use the Service NSW app (you’ll receive a QR Code for your business if you register as a COVID-Safe Business here) or use your own QR code and form to collect the information.

If the ceremony and venue are at different locations, people will need to check in at each location. If someone cannot check-in because of age, disability or language barriers, there are provisions for another person to complete registration on their behalf.

Recording attendees on a pdf or spreadsheet and ticking people off by hand would not be compliant.

 

How do we submit that information?

The beauty of using the Service NSW app is that you don’t have to submit anything. All the info goes straight to the relevant authorities automatically and you don’t have to worry about keeping everyone’s information secure.

The downside is that the business registration is fixed to an address, so if a cluster emerged, it might look like you had 300 people chilling out at your home. I called the NSW COVID-19 hotline about this and they didn’t really have a solution for this. They just suggested that when the contact tracers called to say that a case had occurred at the business, we explain the nature of what we do so they can manually update the location.

If you decide to collect the info with your own QR Code and form, then you are required to hold on to the information for 4 weeks, after which you can delete it. You are only required to submit that information on request to the Chief Health Officer within 4 hours (Section 41(4)). There is no need to upload this information anywhere unless specifically requested.

 

What are our other obligations as celebrants?

Even if we are not the “responsible person”, we still must comply with all the COVID-19 Safety regulations and, in fact, all laws. It’s part of our Code of Practice and it’s, well, ya know, the LAW. So please do read the Public Health Order and the Safety Plans – ignorance is not an excuse if you’re caught doing the wrong thing.

 

How do other NSW celebrants handle COVID responsibilities?

I can only tell you what I do – and my way is not the only way to be compliant, but you might find it helpful.

  • In a public place, I take on the role of the responsible person rather than the couple. It makes sense to do this because I’m doing weddings all the time and I’m a super-nerd who has read all the requirements and understands how to implement them. Also, I just don’t trust the couple to do it properly, and if we get caught out, I could be considered culpable.
  • If the wedding is NOT in a public place, I don’t collect info or make a plan – it’s simply not my job. However, if it’s at a private residence, I will usually help the couple/residents write the plan (I just don’t take responsibility to implement it).
  • I write a separate COVID-19 Safety Plan for each wedding. I do this during a Zoom meeting with the couple the week of the wedding and email them a copy. Of course, I have a template to speed things up, but there is some specific information that only the couple can provide. There are also some things I need the couple to do, such as inform their guests not to come if they are unwell.
  • I use the QR code for the Service NSW app for people to sign in with. I set it up near the front of the ceremony and remind everyone to sign in BUT…
  • I also ask the couple for a spreadsheet with all the guests and vendors names and contact numbers or emails, which I delete after four weeks exactly. Let’s face it – a QR code at an outdoor ceremony is impractical. Unlike a wedding venue that can hire a staff member to stand at a physical door and ensure everyone checks in, an outdoor ceremony is harder to police, especially while you’re also busy setting up for the wedding. Also, the wedding party will often not have their phones on them anyway.Just to clear, this is NOT a compliant way to collect information, so I still have to use the QR code, but I just like to have it as a back-up in case the contact tracers ever get in touch. It also increases my liability by storing personal information I don’t need to hold on to, so that is something to consider if you also want to try this.

 

I said I was going to keep it simple, but the truth is, there are a lot of “it depends” factors when it comes to COVID-19 regulations. But as long as you are across when it’s your responsibility, how to collect information, and filling in the Safety Plan, you should have most of your bases covered.