Contactless Deliveries and the Code
Retail Drinks has recently received several enquiries from Code Signatories regarding the ability to conduct contactless or “low contact” alcohol deliveries.
We assure Code Signatories that compliance with the Code can be maintained in conjunction with low or no contact deliveries.
The following update contains important information on how Code Signatories can conduct contactless alcohol deliveries whilst still maintaining compliance with the Code and other relevant regulatory obligations.
Retail Drinks reminds Signatories that all provisions within the Code (as well as other relevant State and Territory government regulations), including no same-day unattended deliveries and relevant identification procedures, still apply to contactless deliveries. Retail Drinks confirms it will still be conducting audits of compliance with the Code during this period.
Finally, Retail Drinks has been advised that some delivery agents are stating that they will deem packages as having an authority to leave (including for same-day delivery) even if the customer has not selected this option. These agents have not indicated that alcohol is excluded from this new procedure. This may amount to a breach of law by a licensee and you should seek advice if in doubt. Please note, this does not apply to all Code Signatory delivery agents who have confirmed they will continue to comply with the Code.
Frequently asked Questions (FAQ)
Further information regarding contactless deliveries is provided below.
Can alcohol deliveries be left unattended?
“Same day” or “express” alcohol deliveries CANNOT be left unattended under any circumstances as per Section 4.1.1 of the Code.
All same-day deliveries must occur as attended deliveries and delivery drivers are still subject to the same identification requirements (see below for further information regarding satisfying identification requirements for contactless delivery).
Non same-day alcohol deliveries CAN be left unattended where the age of the purchaser has been verified as per Section 4.1.3 of the Code. Following this, the delivery must then be in accordance with the customer's provided instructions.
During contactless deliveries, how do I check for ID?
As per the Code, all customers appearing to be under the age of 25 must be requested to provide ID to prove that they are over the age of 18.
This can be done by a delivery agent sighting the customer’s ID from a distance without having to physically touch it. Alternatively, if the delivery agent is unable to sufficiently view an ID from the distance recommended by the Australian Government for social distancing, they may ask a customer to place the ID on the ground or another surface and then step away, so that the delivery agent may view the ID safely.
Any details regarding the delivery which need to be recorded on a device following the acceptance of a delivery (particularly having regard to the record keeping requirements under South Australian legislation) should be recorded manually by the delivery driver.
As a further note, Retail Drinks also recommends that all drivers regularly wash their hands and do so prior to and after each delivery where practicable.
How do I ID a customer if they are wearing a face mask?
Retail Drinks' EDM outlining appropriate identification procedures to follow for any customers attempting to purchase alcohol while wearing face masks can be accessed here. The same procedures should also be applied in the delivery environment, that is:
If a customer is wearing a face mask, or any other type of facial covering (e.g. helmet, religious head scarf, sunglasses, etc), all RSA requirements still apply.
As such, a driver must be satisfied that they can identify the person (when ID checking) to ensure compliance with the Code.
If a driver is unsatisfied, then additional measures should be taken to confirm a customer’s age (e.g. requesting an alternative form of ID or requesting that the customer temporarily remove any facial covering for this purpose). Note: State & Territory legislation does not provide any power for the seller to require that the purchaser removes any item of clothing, however the seller is able to refuse sale should they be unable to establish the age of the purchaser.
If the driver is still in doubt, then the delivery should be refused.
Advice from Australia Post
For all Signatories partnering with Australia Post for deliveries, the following procedures apply for contactless deliveries. Please note that this advice has been provided by Australia Post directly.
For articles containing alcohol, where the customer comes to the door, our people will do an assessment on whether the person looks under or over the age of 25. From this, they will either:
where the customer looks over 25, record customers details and delivery on the hand-held device and leave the parcel on the ground for the customer to collect after they have left
only sight an ID where the customer looks under 25 and if the ID requirement is met, record delivery and customer details on the hand-held device and leave the parcel on the ground for the customer to collect after they have left (in SA only, the date of birth will be requested and recorded based on verbal advice)
if the ID requirement is not met, for the eParcel wine service, a card will be left and the parcel taken to the Post Office for collection and for our OnDemand and StarTrack Courier services, standard redelivery procedures will apply
For other articles requiring identification, the same process will be followed but given it is not age dependent, if no identification is provided a card will be left and the parcel will be taken to the Post Office for collection.
For all deliveries which require the last 4 digits of the ID, this will be requested and recorded based on the verbal advice given.
If you have any further questions regarding contactless deliveries and the Code, please contact Retail Drinks directly on (02) 8335 3200 or firstname.lastname@example.org.