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Independent adversarial review — Child & Vulnerable-Person Protection Policy Generator

Reviewer: Fable 5.1 (independent; did not author the rules). Date: 2026-09-25. Files reviewed: sources/protection-policy/{rules.yaml, clause-library.yaml, test-cases.yaml, open-questions.md}. Method: primary sources only, reached by direct URL (WebSearch unavailable). 17 WebFetch calls used of a 20 cap. Two PDFs the fetch model refused to quote were saved locally and text-extracted with pdftotext; quotes below come from that extracted text. Nothing below is from memory; anything not fetched is marked UNVERIFIED.

Counts: 3 critical · 9 major · 14 minor (26 findings). Verification log at the end.

CRITICAL​

F-01 — A blank child-protection phone number can ship inside a LAW section, and the tests require the blank​

  • Severity: critical
  • Location: clause-library.yaml C-11-DUTY-ON line 279–281, C-11-DUTY-BC 324–326, C-11-DUTY-AB 375–377, C-11-DUTY-CA-OTHER 406–408, C-11-DUTY-US 449–453; test-cases.yaml global_invariants line 18 and TC-20 lines 333–334.
  • Problem: The "Where to call" line is {{local_child_protection_agency_name}}, {{local_child_protection_agency_phone}} (24 hours). Nothing in any file (a) gates output on the phone being filled, (b) renders a visible warning when it is blank, or (c) tests the filled state. Worse, the global invariant and TC-20 assert the literal placeholder string MUST be present in the generated policy, so the harness passes only when the number is missing. A volunteer holding a printed policy at the moment of a disclosure will read "call {{local_child_protection_agency_phone}}" or an empty gap. The "(24 hours)" annotation is also asserted about whatever number the church types in, which the generator cannot know (an Ontario CAS office line is not necessarily 24h). The 911 line is the only fallback, and 911 is not what the statutes name as the recipient.
  • Source: CYFSA s.125(1): "the person shall immediately report the suspicion and the information on which it is based to a society" — Bill 89 as enacted (Royal Assent 2017-06-01), https://www.ola.org/sites/default/files/node-files/bill/document/pdf/2017/2017-06/bill---text-41-2-en-b089ra_e.pdf. "Immediately" is defeated by a blank number.
  • Fix: (1) Make local_child_protection_agency_phone and _name HARD-REQUIRED for any children/youth policy: refuse to render the final document (or stamp every page "DRAFT — REPORTING NUMBER MISSING") until filled. (2) Drop "(24 hours)"; replace with "confirm hours; if closed, call police / 911". (3) Split the tests into draft_mode (placeholder present) and final_mode (no {{ anywhere; phone matches a phone pattern). (4) Add a negative test: blank phone → generation blocked.

F-02 — Code of conduct routes suspicions about an adult (incl. grooming) to the Coordinator only, with the church deciding whether "the law requires" a report​

  • Severity: critical
  • Location: clause-library.yaml C-04-CODE-OF-CONDUCT lines 132–135: "report any concern about another adult's behaviour, including 'grooming' behaviour (special attention, secrets, gifts, seeking time alone), to the Safeguarding Coordinator. Breaches lead to removal from ministry pending review, and to a report to authorities where the law requires it." Same pattern in C-09-ONLINE lines 205–206 ("saved and shown to the Safeguarding Coordinator the same day") with no pointer to section 11.
  • Problem: This is the most likely real-world path (volunteer notices grooming → tells coordinator → church "reviews"). In Ontario, reasonable grounds to suspect a risk that a child is likely to be sexually abused is itself a listed circumstance (para. 4), the duty is personal, and the reporter "shall not rely on any other person". The clause creates exactly the internal-first pipeline the rules (ON-02 notes, line 99–100) say is "wrong". It also lets the church, not the volunteer, judge whether the law is engaged.
  • Source: CYFSA s.125(1) para. 4: "There is a risk that the child is likely to be sexually abused or sexually exploited as described in paragraph 3." s.125(3): "A person who has a duty to report a matter under subsection (1) or (2) shall make the report directly to the society and shall not rely on any other person to report on the person's behalf." (Bill 89 enacted text, URL above.) BC CFCSA s.13(1)(c): "if the child has been, or is likely to be, physically harmed, sexually abused or sexually exploited by another person and if the child's parent is unwilling or unable to protect the child" — https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/96046_01.
  • Fix: Add to C-04 and C-09: "If what you have seen gives you reason to suspect a child has been or may be harmed — including grooming — section 11 applies: YOU report to the child-protection authority directly. Telling the Coordinator is in addition, never instead." Replace "where the law requires it" with "and any suspicion is reported under section 11 by the person who holds it." Add a test: C-04 and C-09 must contain "section 11" and must not contain "where the law requires it".

F-03 — Disclosure clause tells vulnerable-adult-only ministries the report is "governed by section 11, which is the law" — but section 11 is not generated for them​

  • Severity: critical (dangling instruction at the point of action)
  • Location: clause-library.yaml C-10-DISCLOSURE lines 216–217 and 224 ("Follow section 11 now"); test-cases.yaml TC-05 line 96 includes C-10 and line 106 excludes C-11-DUTY-ON; TC-08/TC-11/TC-17 likewise only render C-12.
  • Problem: For an adults-only policy the volunteer is told, at the REPORT step, to follow a section that does not exist and is told it "is the law". The adults material lives in section 12 and (correctly) states no legal duty for most settings. The volunteer has no usable instruction.
  • Source: Internal inconsistency; no statute needed.
  • Fix: Parameterise C-10: "REPORT. Follow section 11 (children and youth) or section 12 (vulnerable adults) now." Generate an adults-only variant or make the sentence conditional on ministry_type. Add a test: every rendered cross-reference ("section N") must resolve to a rendered section.

MAJOR​

F-04 — "Child" defined as under 18 policy-wide contradicts BC and Nova Scotia (under 19) — verified​

  • Severity: major
  • Location: clause-library.yaml C-02-DEFINITIONS lines 64–66 ("this policy applies to everyone under 18"); C-08 header "(ages 13-17)"; C-11-DUTY-BC must_not_contain "under 19" (line 302); test-cases.yaml TC-06 forbidden "under 19" (line 125); rules.yaml BC-02 notes line 283–286; open-questions.md item 4.
  • Problem: In BC an 18-year-old is a "child" and the s.14 duty applies to them. The policy's scope sentence excludes 18-year-olds while the BC clause says only "has the meaning given in the Act" — a BC volunteer with an 18-year-old participant gets contradictory scope. The forbidden string "under 19" now blocks the correct statement. Nova Scotia is also under 19. Alberta is under 18 (verified) so the Alberta clause can state it.
  • Source (verbatim): BC CFCSA s.1(1): "child" means a person under 19 years of age and includes a youth; and "youth" means a person who is 16 years of age or over but is under 19 years of age. — https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/96046_01. Alberta CYFEA s.1(1)(d): "child" means a person under the age of 18 years and includes a youth unless specifically stated otherwise; — https://kings-printer.alberta.ca/documents/Acts/c12.pdf (extracted p.7). Nova Scotia CFSA s.3(1)(e): "child" means a person under nineteen years of age; — https://nslegislature.ca/sites/default/files/legc/statutes/children%20and%20family%20services.pdf. Ontario CYFSA s.2(1): "child" means a person younger than 18; (Bill 89 enacted).
  • Fix: C-02: "this policy applies to everyone the law of {{province_or_state}} defines as a child (under 19 in British Columbia and Nova Scotia; under 18 in Ontario and Alberta) and in every case to everyone under 18". State the age in C-11-DUTY-BC ("a child is anyone under 19") and C-11-DUTY-AB ("under 18"). Delete "under 19" from BC must_not_contain and TC-06 forbidden; add must_contain "under 19" for BC. Raise BC-02 confidence to high (see F-19). Close open-questions item 4.

F-05 — Two template variables are used but not declared; one has no data source​

  • Severity: major
  • Location: clause-library.yaml header lines 17–22 (declared list) vs {{screening_renewal_years}} (line 93) and {{provincial_statute_name}} (lines 401, 415).
  • Problem: Undeclared variables will render literally unless the generator happens to know them. {{provincial_statute_name}} is "filled from rules.yaml by jurisdiction" but rules.yaml has no machine-readable statute-name field — only source_title, which contains reviewer notes such as "statute name from prior knowledge, not verified" (SK-01, NB-01, PE-01, YT-01, NT-01, NU-01, VA-BC-01, VA-AB-01). A naive fill would print that phrase into a church's policy. TC-14 depends on the fill but nothing tests the source of it.
  • Fix: Declare both variables. Add statute_short_name: to every rule (e.g. NS: "the Children and Family Services Act, ss. 23–24"). Add a test that the rendered policy never contains "prior knowledge", "not verified", "REFER", "confidence".

F-06 — Test harness contradiction: the child-911 sentence is a GLOBAL must_contain but four adults-only cases cannot contain it​

  • Severity: major (harness cannot be green and honest at once)
  • Location: test-cases.yaml global_invariants line 16 ("# children/youth cases" comment on a global rule); TC-05 (excludes C-11-DUTY-ON), TC-08, TC-11, TC-17.
  • Problem: C-10 says "If anyone is in immediate danger, call 911 first" and C-12 says "If a vulnerable adult…", neither of which matches "If a child is in immediate danger, call 911". Either the four cases fail, or the harness is silently lenient — which would also hide real failures. Per house rule, a negative result needs a positive control.
  • Fix: Move the sentence to a children_youth_invariants block applied by ministry_type; add a global "call 911" check instead. Run the harness against a deliberately broken fixture to prove it fails.

F-07 — No reporting path when the Safeguarding Coordinator or pastor is the person of concern​

  • Severity: major
  • Location: Every internal-notification sentence: C-04, C-09, C-10 ("Give it only to the Safeguarding Coordinator"), C-11-* "After you report", C-12-*, C-13, C-15.
  • Problem: All internal routes terminate in one named person. If the concern is about that person (or the pastor who supervises them), the volunteer is told to hand the incident form and the concern to the subject. The legal report still goes direct (good), but the code-of-conduct route (F-02) has no alternate.
  • Fix: Add {{alternate_safeguarding_contact}} (board chair / denominational safeguarding office) to C-02 and one sentence in C-10 and C-04: "If your concern involves the Safeguarding Coordinator or the pastor, inform {{alternate_safeguarding_contact}} instead." Test: every clause that names the Coordinator as recipient also names the alternate.

F-08 — REFER clause for other provinces states "has a law requiring people to report" as fact for eight unverified jurisdictions​

  • Severity: major
  • Location: clause-library.yaml C-11-DUTY-CA-OTHER lines 399–400; test-cases.yaml label_rules line 27 ("no clause with label REFER states … a 'must report' rule as fact").
  • Problem: The sentence breaches the file's own REFER rule for SK, NB, PE, YT, NT, NU (confidence low, nothing fetched) and glosses Québec, where — per the unverified QC-01 — non-professionals are required to report only some situations. The generalisation is probably true, but the standard set in rules.yaml line 6–8 is "conservative wording beats breadth".
  • Fix: "Every province and territory has child-protection legislation with reporting provisions. This policy does not state the {{province_or_state}} rule." Keep "Our rule…" as church policy.

F-09 — Ontario clause says "the full list of thirteen circumstances" while the rules quote fifteen (1–13 plus 4.1, 4.2)​

  • Severity: major (numeric claim in a LAW section; also TC-01 must_contain "s. 125" only, so untested)
  • Location: clause-library.yaml C-11-DUTY-ON line 256; rules.yaml ON-01 excerpt lines 67–69.
  • Problem: I verified thirteen paragraphs in the 2017 enacted text. Paragraphs 4.1 and 4.2 (child sex trafficking, cited to 2020 c.25 / 2021 c.21) are in the rules' excerpt but I could NOT verify them (e-Laws is JS-only; CanLII 403). If they exist, "thirteen" is wrong; if not, the ON-01 excerpt is wrong. One of the two files is wrong either way.
  • Source: Bill 89 enacted text lists paragraphs 1–13 (URL in F-01).
  • Fix: Replace "thirteen" with "the full list of circumstances". Verify 4.1/4.2 from the consolidated e-Laws page (Chrome-rendered) and record the check.

F-10 — Ontario "protected … in good faith" paraphrases a two-part statutory test​

  • Severity: major (over-promise of legal protection in a LAW section)
  • Location: clause-library.yaml C-11-DUTY-ON line 270–271: "A person who reports in good faith is protected from legal action (s. 125(10))."
  • Problem: The statute protects a person "who acts in accordance with this section unless the person acts maliciously or without reasonable grounds for the suspicion." Good faith without reasonable grounds is not protected. Alberta and BC clauses quote their tests correctly; Ontario does not.
  • Source (verbatim): s.125(10): "This section applies although the information reported may be confidential or privileged, and no action for making the report shall be instituted against a person who acts in accordance with this section unless the person acts maliciously or without reasonable grounds for the suspicion." (Bill 89 enacted.)
  • Fix: Quote it: "No action may be brought against you for making the report 'unless [you act] maliciously or without reasonable grounds for the suspicion' (s. 125(10))."

F-11 — "Do not discuss the matter with anyone else" is over-broad for the reporter​

  • Severity: major
  • Location: C-11-DUTY-ON line 283–284 and the parallel sentence in C-11-DUTY-BC, -AB, -CA-OTHER, -US.
  • Problem: Read literally it bars the reporter from answering the CAS/director/police follow-up questions before "cooperate fully" is reached, from telling the child's non-offending parent when the agency asks them to, from making the further report Ontario s.125(2) requires, and from seeking their own pastoral or legal support. Standard guidance limits discussion to "people who need to know", not "anyone".
  • Fix: "Do not discuss the matter with anyone who does not need to know; you may and should speak with the society/director, the police, and your own lawyer or counsellor."

F-12 — Forbidden-content tests are exact-string only; the generator's output mode is unspecified​

  • Severity: major (test coverage)
  • Location: test-cases.yaml header lines 5–9; forbidden lists throughout.
  • Problem: Every forbidden check is a literal phrase ("report to your supervisor, who will report"). If the generator ever paraphrases (LLM-assisted rendering) or a church edits, "tell your team leader and they will contact CAS" passes. Nothing states the generator is template-only. There is also no test that the direct-report sentence appears in every children/youth output regardless of jurisdiction, no test for (24 hours), none for undeclared variables, none for the scope/age contradiction (F-04), none for cross-reference integrity (F-03), none for C-04/C-09 routing (F-02).
  • Fix: State "template-only rendering; no free text" in the header and enforce with a hash of the clause set. Add positive structural invariants: for ministry_type ∈ {children, youth} the output must contain the jurisdiction's direct-report sentence; must not contain {{ in final mode; every "section N" resolves. Add regex forbids: /tell(ing)? (your|the) (supervisor|leader|pastor|coordinator)[^.]{0,80}(will|who) (report|call|contact)/i.

MINOR​

F-13 — Criminal Records Act definition truncated in two places​

  • Location: rules.yaml CA-SCREEN-01 excerpt line 723, VA-ALL-01 line 1088; clause-library.yaml C-02 line 68.
  • Problem: Both drop the final words "of being harmed".
  • Source (verbatim, as returned by the fetch): s.6.3(1) "vulnerable person" means "a person who, because of his or her age, a disability or other circumstances, whether temporary or permanent, is in a position of dependency on others; or is otherwise at a greater risk than the general population of being harmed" — https://laws-lois.justice.gc.ca/eng/acts/C-47/section-6.3.html. The fetch ended the quotation at "of being harmed"; whether further qualifying words follow in the statute was NOT returned and is UNVERIFIED. Definition location confirmed: s.6.3(1) — closes open-questions item 16.
  • Fix: Append "of being harmed" and re-fetch to confirm whether the definition continues past that point.

F-14 — CRA s.6.3(3) conditions and scope overstated in C-03-SCREENING-CA​

  • Location: clause-library.yaml C-03 lines 88–93; rules.yaml CA-SCREEN-01 rule lines 712–716.
  • Problem: (a) The statutory verification is only for the notation of Schedule 2 convictions for which a record suspension was ordered; the clause says "whether the applicant has a record of a listed sexual offence, including one for which a record suspension (pardon) was granted" — the un-pardoned record comes from an ordinary criminal record check, not s.6.3. (b) Omits condition (3)(a) "the position is one of trust or authority towards that child or vulnerable person". (c) "a police force" — statute says "a member of a police force or other authorized body".
  • Source (verbatim): s.6.3(3): "At the request of any person or organization responsible for the well-being of a child or vulnerable person and to whom or to which an application is made for a paid or volunteer position, a member of a police force or other authorized body shall verify whether the applicant is the subject of a notation made in accordance with subsection (2) if (a) the position is one of trust or authority towards that child or vulnerable person; and (b) the applicant has consented in writing to the verification." s.6.3(8): "A person or organization that acquires information under this section in relation to an application for a position shall not use it or communicate it except in relation to the assessment of the application."
  • Fix: Describe the VSC as "a criminal record check plus the s.6.3 verification of pardoned sexual-offence records"; add the trust/authority condition; quote (8) for the confidentiality sentence.

F-15 — Wrong internal cross-reference: training is section 14, not 12​

  • Location: clause-library.yaml C-03-SCREENING-CA line 97 "Orientation and training (section 12)". Section 12 is Vulnerable adults.
  • Fix: "section 14". Covered by the cross-reference test proposed in F-03.

F-16 — C-03-SCREENING-US: label REFER, banner text "Recommended practice, not law"​

  • Location: lines 101–108.
  • Problem: Label and banner disagree; TC-18-style counting would mis-classify it.
  • Fix: Pick one (RECOMMENDED PRACTICE fits the content) and add a test that banner text matches label for every clause.

F-17 — Ontario s.125(4) permissive report is conditional; clause omits the condition​

  • Location: C-11-DUTY-ON lines 265–267.
  • Problem: The Act permits a report about a 16/17-year-old only "if either a circumstance or condition described in paragraphs 1 to 11 of subsection (1) or a prescribed circumstance or condition exists". Clause says "permits but does not require a report" without the condition. Low risk (church policy requires reporting anyway) but a LAW-labelled paraphrase.
  • Source (verbatim): s.125(4) as quoted in ON-04 — VERIFIED identical in Bill 89 enacted text.
  • Fix: "permits (where one of the listed circumstances exists) but does not require".

F-18 — BC s.14(1) quoted without its lead-in; s.14(1.1) now verified and could be included​

  • Location: C-11-DUTY-BC line 305–308; rules.yaml BC-01 notes line 251–252.
  • Source (verbatim): "(1) Subject to subsection (1.1), a person who has reason to believe that a child, including an Indigenous child, needs protection under section 13 must promptly report the matter to a director or a person designated by a director. (1.1) A person who has reason to believe that an Indigenous child needs protection under section 13 and who reports the matter to an Indigenous authority is not required to report the matter to a director, or a person designated by a director, under subsection (1) of this section if the Indigenous authority confirms to the person that the Indigenous authority will assess the information in the report."
  • Fix: Either quote from "a person…" without opening quotation before "Subject", or include (1.1) as a sentence for churches serving Indigenous communities. Update BC-01 notes: (1.1) verified; close open-questions item 5 (s.13(1)(a)–(c) also verified verbatim, see log).

F-19 — BC-02 confidence can rise to high; s.14(3), (6), (7) now verbatim​

  • Location: rules.yaml BC-02 lines 280–286.
  • Source (verbatim): "(3) A person who contravenes subsection (1) commits an offence." "(6) A person who commits an offence under this section is liable to a fine of up to $10 000 or to imprisonment for up to 6 months, or to both." "(7) The limitation period governing the commencement of a proceeding under the Offence Act does not apply to a proceeding relating to an offence under this section."
  • Fix: Update excerpt and confidence. Note the statute writes "$10 000" (TC-06 requires "$10,000"; TC-09 requires "$10 000" for Alberta) — pick one house style and note the statute's own form in the rule.

F-20 — Alberta s.4(5) generalised to "registered professionals"​

  • Location: C-11-DUTY-AB lines 373–374; rules.yaml AB-03 rule line 383–384.
  • Source (verbatim): "(5) … if a director has reasonable and probable grounds to believe that a person has not complied with subsection (1) and that person is registered under an Act regulating a profession or occupation prescribed in the regulations, the director shall advise the appropriate governing body…" (kings-printer c12.pdf, extracted p.15–16).
  • Fix: "members of professions prescribed in the regulations".

F-21 — Ministry/agency names in "Where to call" lines are unverified administrative facts​

  • Location: C-11-DUTY-BC line 324 ("Ministry of Children and Family Development"), C-11-DUTY-AB line 375 ("Alberta Children and Family Services / child-intervention line"), C-12-VA-ON line 485 ("Ministry of Long-Term Care").
  • Problem: None of the statutes name a ministry (BC: "director" = "a person designated by the minister under section 91, 91.1 or 91.2"; AB: "director" = "a person designated by the Minister"). Ministry names change with cabinet shuffles. Not fetched; UNVERIFIED.
  • Fix: Use the statutory term ("a director designated under the Act — in practice the provincial child-protection intake line") and let the church fill the current name.

F-22 — "(24 hours)" annotation (see F-01) and generation-date reuse​

  • Location: C-11-DUTY-ON line 280; C-00 lines 36–41 uses {{policy_adoption_date}} for both "generated … on" and "Adopted … on".
  • Fix: Remove "(24 hours)"; add {{generation_date}}.

F-23 — label_rules vs C-12-VA-ON: a REFER clause quotes a "shall immediately report" duty as law​

  • Location: test-cases.yaml line 27 vs TC-05 must_contain line 99.
  • Problem: The spec forbids what TC-05 requires. FLTCA s.28 itself is UNVERIFIED by me (JS-only page).
  • Fix: Either label C-12-VA-ON "LAW (long-term care) / REFER (other settings)" with a split clause, or relax the label rule to "no unverified rule".

F-24 — TC-19 forbidden "gather evidence" passes only because of the quotation marks in the clause​

  • Location: C-10 line 222–223 do not gather "evidence"; TC-19 line 321.
  • Problem: Fragile: any edit that removes the quotes flips a correct negative instruction into a forbidden hit, and the test cannot distinguish "do not gather evidence" from "gather evidence".
  • Fix: Forbid the positive-instruction form with regex (/(should|must|please) (gather|collect) evidence/i) or test at sentence level.

F-25 — Global forbidden "the church will investigate" does not catch "we will look into it first"​

  • Location: test-cases.yaml line 21.
  • Fix: Add synonyms: "look into", "internal investigation", "before contacting", "before reporting", "fact-find".

F-26 — 911 assumed universal; not verified for every Canadian territory​

  • Location: every clause's first line; rules.yaml ON-07 line 214–215.
  • Problem: Whether basic 911 exists in every Nunavut community was not checked (UNVERIFIED; do not act on this without a source). If it does not, the first line of a Nunavut policy is wrong.
  • Fix: Add {{emergency_number}} defaulting to 911 with a note for NU/NT churches to confirm, or verify from a government source before launch.

Things checked and found CORRECT (so the next reviewer need not re-check)​

  • ON-01/02/03/04/05/06/07 excerpts match the enacted CYFSA s.125 word for word for subsections (1) paras 1–13, (2), (3), (4), (5), (6)(a),(c)–(g), (7), (8), (9), (10), (11), (12) and s.126(1). The correction that s.125(6)(c) reads simply "a religious official;" is CONFIRMED — the enacted 2017 text already dropped the CFSA "including a priest, a rabbi and a member of the clergy" wording, and the only later amendment to s.125 (2024, c. 17, s. 5) reads: "Clause 125 (6) (b) of the Act is amended by adding 'early childhood educator' after 'a teacher'." (https://r.jina.ai/https://www.ontario.ca/laws/statute/s24017). The must_not_contain on the old wording is therefore right.
  • Ontario under-16 mandatory / 16–17 permissive split: correct (s.125(4) verbatim).
  • Ontario s.125(10)–(11): privilege override + liability protection in (10), solicitor-client preserved in (11) — correct as quoted; only the "good faith" paraphrase (F-10) is off.
  • BC s.14(1), (2), (4), (5) excerpts: verbatim match. BC s.13(1)(a)–(c) verified: "(a) if the child has been, or is likely to be, physically harmed by the child's parent; (b) if the child has been, or is likely to be, sexually abused or exploited by the child's parent; (c) if the child has been, or is likely to be, physically harmed, sexually abused or sexually exploited by another person and if the child's parent is unwilling or unable to protect the child".
  • Alberta s.1(2)(a)–(h), s.1(3)(c), s.4(1)–(6): verbatim match, including "(b) a police officer" and "(1.2) A police officer who receives a report pursuant to subsection (1)(b) shall report the matter to a director as soon as practicable." AB-02's guardian-framing note is accurate.
  • BC-03 / AB-03 "no express non-delegation clause": confirmed — neither s.14 (BC) nor s.4 (AB) contains one. Conservative wording is appropriate.
  • CWIG clergy PDF: "Approximately 29 States and Guam…", "approximately 16 States, Puerto Rico, and the Virgin Islands…", "This privilege, however, is not absolute… typically interpreted narrowly… in some States, it is denied altogether", footnote 2 "current only through May 2023" — all verbatim matches. US-02's decision not to reproduce the State lists is sound.
  • Nova Scotia ss.23(1), 23(3), 24(2)(b) "member of the clergy", 24(6): verbatim match (local text extraction of the Legislative Counsel PDF, consolidated to April 9, 2026). Also available for a future pass: s.23(2) "No action lies against a person by reason of that person reporting information pursuant to subsection (1), unless the reporting of that information is done falsely and maliciously." and s.24(3) "This Section applies whether or not the information reported is confidential or privileged."
  • CRA s.6.3(3), (4), (5), (6), (7), (8) now verbatim; definition sits in s.6.3(1).

Verification log​

SourceURLResult
BC CFCSA full Act (s.1, 13, 14)https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/96046_01 (x2)VERIFIED verbatim: s.1 "child", "youth", "director"; s.13(1)(a)–(c), (2), (3) summary; s.14(1)–(7)
Ontario e-Laws CYFSAhttps://www.ontario.ca/laws/statute/17c14JS shell only — NO TEXT
Ontario e-Laws via rendering proxyhttps://r.jina.ai/https://www.ontario.ca/laws/statute/17c14s.2(1) "child" verified; page truncated before s.125
CanLII CYFSAhttps://www.canlii.org/en/on/laws/stat/so-2017-c-14-sch-1/latest/so-2017-c-14-sch-1.html403
Ontario "Report child abuse" pagehttps://r.jina.ai/https://www.ontario.ca/page/report-child-abuse-and-neglectsecondary; "directly to a children's aid society" and solicitor-client-only exception confirmed
OACAS duty to reporthttps://www.oacas.org/childrens-aid-child-protection/duty-to-report/secondary; "reporting for 16 and 17-year-old youth is not mandatory"
OLA Bill 89 pagehttps://www.ola.org/en/legislative-business/bills/parliament-41/session-2/bill-89gave Royal Assent PDF link
OLA Bill 89 PDF (guessed URL)…/bill---text-41-2-en-b089ra.pdf404
OLA Bill 89 Royal Assent PDFhttps://www.ola.org/sites/default/files/node-files/bill/document/pdf/2017/2017-06/bill---text-41-2-en-b089ra_e.pdfVERIFIED (pdftotext): s.2(1) "child"; s.125(1)–(12); s.126(1) — 2017 enacted text, not the consolidation
Ontario 2024 c.17 (amending Act)https://r.jina.ai/https://www.ontario.ca/laws/statute/s24017VERIFIED: s.5 amends only 125(6)(b)
Alberta CYFEAhttps://kings-printer.alberta.ca/documents/Acts/c12.pdfVERIFIED (pdftotext): s.1(1)(d), (j), (l); s.1(2), (2.1), (3)(c); s.4(1)–(6)
CWIG clergy resource pagehttps://www.childwelfare.gov/resources/clergy-mandatory-reporters-child-abuse-and-neglect/summary only
CWIG clergy PDFhttps://artifacts.childwelfare.gov/public/documents/clergy-mandated-reporters.pdfVERIFIED (pdftotext)
Criminal Records Act s.6.3https://laws-lois.justice.gc.ca/eng/acts/c-47/section-6.3.html (x2)VERIFIED (1)–(8)
Nova Scotia CFSA(PDF already cached from the author's session; not re-fetched)VERIFIED ss.3(1)(e), 23, 24, 24A

Not verified (no fetch budget or unreachable): CYFSA consolidated text incl. paras 4.1/4.2 and the 2020/2021 history notes; FLTCA 2021 s.28 (all of VA-ON-01); Retirement Homes Act; NL, QC, MB, SK, NB, PE, YT, NT, NU statutes; BC Adult Guardianship Act; Alberta Protection for Persons in Care Act; all ministry/agency names and hotlines; Volunteer Canada and Commit to Kids pages; Nunavut 911 availability. Everything under those headings in rules.yaml should be read as the author's claim, not as confirmed.

Fetch budget: 17 of 20 used. No source files were edited.