Apple has added recently at least for the BTLE implementation an address randomization much like they did for wifi, details of which can be found here: https://support.apple.com/guide/security/bluetooth-security-...
>For Bluetooth, this would allow an attacker to circumvent anti-tracking techniques such as constantly changing the address a mobile device uses to connect to Internet networks.
Maybe not easy, but also not hard. The only thing that screws you up is someone playing with the airplane mode toggle of their phone while moving within your detection radius.