Re: Connect App - Compliance Canada

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 <
skoyanagi@homecareassistance.com> 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 <tt@homecareassistance.com>
> 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 <tt@homecareassistance.com>
>>> wrote:
>>>
>>>> Thanks Amy.
>>>>
>>>> Steve, does this satisfy your concerns?
>>>>
>>>> Erika: Are there any other hurdles to overcome on your end, or can we
>>>> start looking at launch dates?
>>>>
>>>> On Mon, Feb 28, 2022 at 1:02 PM Amy Freeman <
>>>> afreeman@homecareassistance.com> wrote:
>>>>
>>>>> Hi Steve,
>>>>>
>>>>> The app currently doesn't collect any employee data - it does display
>>>>> employee name in the app and requires employee mobile number for
>>>>> authentication. We pull this data from ClearCare currently.
>>>>> Outside of that, we collect the time of clock in, clock out and
>>>>> location and then the caregiver marks tasks completed, not completed and
>>>>> makes notes.
>>>>>
>>>>> Amy
>>>>>
>>>>> On Tue, Feb 22, 2022 at 12:40 PM Steve Koyanagi <
>>>>> skoyanagi@homecareassistance.com> wrote:
>>>>>
>>>>>> Tim,
>>>>>>
>>>>>> Thanks for reaching out.  Can you provide an overview of what your
>>>>>> timeline is for implementation?
>>>>>>
>>>>>> Amy, can you also remind me of exactly what employee data is being
>>>>>> collected via the app?  Is it just a caregiver's name and email address?
>>>>>>
>>>>>> There are a number of Canadian privacy laws regulating an employer's
>>>>>> collection of consumer/employee data, including:
>>>>>>
>>>>>>    - Personal Information Protection and Electronic Documents Act
>>>>>>    - Personal Information Protection Act (Alberta)
>>>>>>    - Personal Information Protection Act (British Columbia)
>>>>>>    - An Act Respecting the Protection of Personal Information in the
>>>>>>    Private Sector (Quebec)
>>>>>>
>>>>>> In general, the laws related to collection of employment data are
>>>>>> less rigorous.  Depending on our project timeline and the exact data being
>>>>>> collected, my thought is we'll likely want to seek a quick opinion from
>>>>>> Canadian counsel on the current privacy landscape.
>>>>>>
>>>>>> Let me know on the above.  Thanks.
>>>>>>
>>>>>> On Tue, Feb 22, 2022 at 12:17 PM Timothy Thomas <
>>>>>> tt@homecareassistance.com> wrote:
>>>>>>
>>>>>>> Hey Steve,
>>>>>>>
>>>>>>> I'm workin with Erica and Amy on the roll out of the Caregiver
>>>>>>> Connect App in Canada. Before pushing the app out to our offices here we
>>>>>>> wanted to double check what the implications are around data collection in
>>>>>>> Canada. Last year Clearcare migrated us over to a Canadian server and .ca
>>>>>>> domain for compliance reasons so it's possible we would need to do the same
>>>>>>> for any data collection that HCA is doing behind the scenes.
>>>>>>>
>>>>>>> Let me know what you think, thanks!
>>>>>>> Tim
>>>>>>>
>>>>>>> --
>>>>>>> Timothy Thomas
>>>>>>> Head of Canada
>>>>>>> Home Care Assistance
>>>>>>> Office: 514-907-5065
>>>>>>> Fax: 514-221-4265
>>>>>>> 4464 Ste Catherine West
>>>>>>> <https://www.google.com/maps/search/4464+Ste+Catherine+West+Westmount,+QC,+H3Z1R7?entry=gmail&source=g>
>>>>>>> Westmount, QC, H3Z1R7
>>>>>>> <https://www.google.com/maps/search/4464+Ste+Catherine+West+Westmount,+QC,+H3Z1R7?entry=gmail&source=g>
>>>>>>> HomeCareAssistanceMontreal.ca
>>>>>>> ---
>>>>>>> Read Our Testimonials
>>>>>>> <https://www.homecareassistancemontreal.ca/reviews.html>
>>>>>>> We Are Hiring!
>>>>>>> <https://www.homecareassistancemontreal.ca/careers.html>
>>>>>>>
>>>>>>> <https://www.linkedin.com/company/home-care-assistance-montreal-soins-%C3%A0-domicile-/>
>>>>>>> <https://www.facebook.com/HCAGreaterMTL>
>>>>>>> <https://homecareassistance.com>
>>>>>>> Champions of Longevity
>>>>>>>
>>>>>>
>>>>
>>>> --
>>>> Timothy Thomas
>>>> Head of Canada
>>>> Home Care Assistance
>>>> Office: 514-907-5065
>>>> Fax: 514-221-4265
>>>> 4464 Ste Catherine West
>>>> <https://www.google.com/maps/search/4464+Ste+Catherine+West+Westmount,+QC,+H3Z1R7?entry=gmail&source=g>
>>>> Westmount, QC, H3Z1R7
>>>> <https://www.google.com/maps/search/4464+Ste+Catherine+West+Westmount,+QC,+H3Z1R7?entry=gmail&source=g>
>>>> HomeCareAssistanceMontreal.ca
>>>> ---
>>>> Read Our Testimonials
>>>> <https://www.homecareassistancemontreal.ca/reviews.html>
>>>> We Are Hiring! <https://www.homecareassistancemontreal.ca/careers.html>
>>>>
>>>> <https://www.linkedin.com/company/home-care-assistance-montreal-soins-%C3%A0-domicile-/>
>>>> <https://www.facebook.com/HCAGreaterMTL>
>>>> <https://homecareassistance.com>
>>>> Champions of Longevity
>>>>
>>> --
>> Timothy Thomas
>> Head of Canada
>> Home Care Assistance
>> Office: 514-907-5065
>> Fax: 514-221-4265
>> 4464 Ste Catherine West
>> Westmount, QC, H3Z1R7
>> HomeCareAssistanceMontreal.ca
>> ---
>> Read Our Testimonials
>> <https://www.homecareassistancemontreal.ca/reviews.html>
>> We Are Hiring! <https://www.homecareassistancemontreal.ca/careers.html>
>>
>> <https://www.linkedin.com/company/home-care-assistance-montreal-soins-%C3%A0-domicile-/>
>> <https://www.facebook.com/HCAGreaterMTL>
>> <https://homecareassistance.com>
>> Champions of Longevity
>>
>