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v22.0 Limited Public Directory Pilot Risk Disposition (2026-07-02)

This record documents the conservative owner disposition for continuing only a narrow public-directory pilot while full Gate 0 remains blocked.

This is not legal advice, not lawyer review, and not a legal compliance certification. It is an owner self-review for a solo-dev project that cannot fund external legal counsel in this phase.

Decision

Field Value
Decision limited_public_directory_pilot_allowed_with_constraints
Full Gate 0 status NO-GO
Legal review status owner_self_review_only_no_lawyer
Review date 2026-07-02
Owner jer
Full C1 closure deferred
Full D4 closure deferred

CareConnect may remain available as a limited public directory only if the constraints below stay true. This decision does not approve partner/API expansion, 211 integration, legal claims, or outreach execution.

Solo-Owner Closeout Interpretation

This record is the required owner disposition for the current solo-dev public-directory scope. External legal counsel, third-party partner evidence, and private partner/API terms are not required to keep this limited scope open or to close the current platform-ops PLAN-033 owner-evidence bookkeeping item.

This interpretation is deliberately narrow:

  1. It does not make any legal-compliance certification.
  2. It does not close full v22 Gate 0 for partner/API expansion.
  3. It does not authorize 211 integration, partner workflows, outreach execution, or marketing campaigns.
  4. It records the owner's decision that the current limited public-directory operation can continue under the constraints in this file.

Reference Inputs

The owner self-review used these public reference surfaces:

  1. Government of Canada, PIPEDA full text, and Office of the Privacy Commissioner of Canada, summary of privacy laws in Canada.
  2. Government of Ontario, Personal Health Information Protection Act, 2004.
  3. CRTC, CASL FAQ and guidance on implied consent.
  4. 211 Ontario, Terms of Use / Privacy Policy, treated as source-specific terms that must be reviewed before any integration or content-reuse dependency.
  5. Existing CareConnect governance controls, threat model, privacy architecture, public legal surfaces, and v22 Gate 0 evidence documents.

Allowed Limited Scope

The limited pilot may continue only as:

  1. A public information directory for manually curated social-service records.
  2. A privacy-first search experience where search queries are not logged as raw user query text.
  3. An information-only service with emergency, medical, legal, eligibility, and referral decisions left to the user and official service providers.
  4. A maintenance posture focused on data accuracy, stale-record handling, privacy-safe analytics, and conservative public copy.

Prohibited Until Further Review

The following remain blocked:

  1. 211 API integration or other external API/data-source integration without compatible terms and C1 clause review.
  2. Partner-data sharing, partner portal expansion, or partner claims workflow activation without D4 evidence.
  3. Collection of personal health information, health records, case details, or eligibility/intake facts.
  4. Claims that CareConnect is legally compliant, lawyer-reviewed, medically approved, clinically validated, or an official referral authority.
  5. Bulk outreach, marketing campaigns, or recurring commercial electronic messages without a separate CASL review covering consent, sender identification, unsubscribe, and proof-retention expectations.
  6. Publishing private partner details, private contracts, credential material, provider-console screenshots, or raw legal terms in public docs.

Risk Controls

The limited pilot depends on these controls staying in force:

  1. Public pages keep directory/information-only disclaimers.
  2. Crisis and emergency copy directs users to emergency services and official providers rather than CareConnect.
  3. Source data remains manually curated and provenance-aware.
  4. Stale records are visibly constrained by the freshness policy.
  5. Search analytics stay minimized and do not store raw query text.
  6. Admin/partner access remains restricted and does not create new public claims or partner obligations.
  7. Any unclear source/API terms default to no integration and no reuse beyond clearly permitted public references.

Gate 0 Disposition

This record does not close G0-3 / C1 or G0-8 / D4.

  1. G0-3 / C1 remains pending because candidate partner/API terms have not been attached and reviewed clause-by-clause.
  2. G0-8 / D4 remains pending because named partner list, outreach owner, and dated outreach execution evidence are not attached.
  3. npm run check:v22-gate0 is expected to remain blocked until the full evidence requirements pass.

The practical result is: limited public-directory operation is acceptable under the constraints above; full partner/API Gate 0 exit remains deferred.