--000000000000f1cff705e065875f Content-Type: multipart/alternative; boundary="000000000000f1cff505e065875d" --000000000000f1cff505e065875d Content-Type: text/plain; charset="UTF-8" ---------- Forwarded message --------- From: Steve Koyanagi Date: Fri, Mar 11, 2022 at 2:39 PM Subject: Re: Connect App - Compliance Canada To: Timothy Thomas Cc: Amy Freeman , Bjorn Cooley , Erica Smith , Ken Citron , Nina Kani , Terrence Vetter Tim, As a follow-up, we had a good conversation with Canadian counsel this week about the rollout of the CG app in Canada. The short summary is there are no major red flags and we'll just want to get a few items in place related to both clients and caregivers. Here is a quick summary: 1. *Reimbursement for CG Required Cell Phone Use - *If we're going to require CG's to use their personal cell phones for the use of the app (which I believe we are), British Columbia and Quebec law requires reimbursement for work required cell phone use. Our recommendation is to apply our California policy, which is $.50 per paycheck to CG's. Payroll will need to be looped in on this so we can do this appropriately. 2. *Disclosure to Clients Related to Use of Client Data* - There is both a federal privacy law and provincial laws in Alberta, BC and Quebec requiring disclosure to consumers relating to exactly what data we're collecting (name, email address, phone #, etc.) and what we're doing with it. We recommend adopting our California privacy notice that we provide to all clients as part of the CCA and adopting it such that it meets all applicable Canadian laws. For your reference, attached starting at page 4 is our California privacy notice. 3. *CG Agreement to Use of App* - Finally, on the CG app we have standard terms and conditions and a privacy policy related to our CG's use of the app. We will work with Canadian counsel to ensure these policies meet all Canadian laws. Let me know if you want to chat about the above. Otherwise, our plan is to work with Canadian counsel on these items such that we can get them into place for the rollout. On Mon, Mar 7, 2022 at 2:23 PM Steve Koyanagi wrote: > Hi Tim, > > We are scheduling a call with Canadian counsel this week. Please continue > to move this forward, but we will let you know if any material concerns > come out of our meeting. We will be in touch. Thanks. > > On Mon, Mar 7, 2022 at 2:22 PM Timothy Thomas > wrote: > >> Great, thanks for the update. >> >> On Mon, Mar 7, 2022 at 5:20 PM Amy Freeman > afreeman@homecareassistance.com> wrote: >> >>> Hi Tim, >>> >>> We are still analyzing the ClearCare connectivity since the Canadian >>> data resides in a different instance. We have been waiting on ClearCare to >>> get back to us with some information which they did late Friday. We have an >>> engineer reviewing their input today. Once tha analysis is complete I will >>> be able to provide an estimated timeframe for roll out. >>> >>> Amy >>> >>> On Mon, Mar 7, 2022 at 1:31 PM Timothy Thomas >>> wrote