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Protection Policy Generator — open questions

Revision 2, 2026-09-25, after three adversarial reviews (Opus, Fable, Codex). Budget this pass: 20 direct fetches (8 official statute files, 10 further provincial/territorial attempts, 2 WebFetch for the Nunavut emergency number); WebSearch unavailable. Everything marked CLOSED below was verified verbatim from the official consolidation this pass. Items are ordered by how much they could change what a volunteer is told.

A. Must resolve before public launch​

  1. Local reporting phone numbers remain church-filled — now HARD-GATED. No provincial or State hotline was verified. The generator never prints a number it did not verify and refuses to render while any reporting contact is blank (validation: required_nonblank on every variable; gate_cases GATE-01..12). Decision still open: verify and offer per-jurisdiction intake lines as defaults in a later pass, or keep church-filled only.
  2. CDC (2007) "Preventing Child Sexual Abuse Within Youth-serving Organizations" still not retrieved. RP-03..RP-06 stay at confidence medium, labelled recommended practice.
  3. Lawyer review of the LAW sections. Now seven LAW variants (ON, BC, AB, NS children; ON LTC/retirement homes, BC AGA, AB PPCA adults). Given life-safety adjacency, one review by a lawyer or denominational safeguarding office per province before the tool goes public.
  4. Ontario "religious official". CLOSED as to wording (current s.125(6)(c) reads simply "a religious official"; 2024, c. 17, s. 5 amended only clause (6)(b)). Still open: whether lay elders / ministry leaders are "religious officials" for the s.125(5) offence. The policy tells all leaders to act as if it applies.

B. Closed this pass (kept for the audit trail)​

  • BC and Alberta age definitions — CLOSED. BC "child" = under 19 (CFCSA s.1(1)); AB "child" = under 18 (CYFEA s.1(1)(d)); ON "child" = younger than 18 (CYFSA s.2(1)); NS "child" = under nineteen (CFSA s.3(1)(e)). Encoded in derived_values.child_age_statement.
  • BC s.13 grounds and s.14(1.1) — CLOSED. Both verbatim; (1.1) is stated in the clause.
  • BC s.14(3), (6), (7) — CLOSED; BC-02 confidence raised to high.
  • Ontario CYFSA paras 4.1/4.2 — CLOSED. Present in the consolidation (2020, c. 25; 2021, c. 21); the list has 15 items. Clause no longer says "thirteen".
  • Nova Scotia — CLOSED and PROMOTED to LAW. ss.3(1)(e), 22(2), 23, 24, 25, 25A verified from the Legislative Counsel consolidation to April 9, 2026. Agency intake line is church- filled and gated.
  • Ontario FLTCA s.28(5) — CLOSED. Full (1)-(7) verified. Offence class excludes volunteers; s.28(4) protections cover only listed professionals. Clause says so.
  • Ontario Retirement Homes Act s.75 — CLOSED and added as LAW (VA-ON-03). Report to the Registrar; no offence for a member of the public located in s.75.
  • BC Adult Guardianship Act Part 3 — CLOSED. s.46(1) "may report" = permissive. LAW variant states the permissive rule; church rule requires the external report.
  • Alberta Protection for Persons in Care Act — CLOSED and PROMOTED to LAW. s.7(1) duty on "every individual"; s.7(5) offence; s.24(2)(a) fine ≤ $10 000; s.24(1) false/malicious/ no-reasonable-grounds offence; s.8(1) "as soon as reasonably practicable".
  • CRA s.6.3 — CLOSED. Full (1)-(9) verified; definition is in s.6.3(1) and ends "of being harmed by a person in a position of trust or authority towards them"; (3)(a) trust/authority condition and (8) use limit now in the clause.
  • Nunavut 911 — CLOSED as a risk. RCMP Nunavut page: "For emergency assistance, dial 1-867-979-1111." Nunavut does not use 911; emergency_number has no default for CA-NU and generation blocks until the church confirms its local number. The 867 number is NOT printed (not verified as territory-wide).
  • Manitoba s.18, Newfoundland and Labrador s.11, New Brunswick s.35 — text verified (MB unofficial online consolidation current to 2026-09-23; NL House of Assembly page; NB enacted 2022 chapter). Still REFER (intake model / consolidation currency not verified), but derived_values.provincial_statute_name now prints verified names and sections.
  • PEI — the Child Protection Act, R.S.P.E.I. 1988, c. C-5.1 is REPEALED BY 2023, c. 17, s. 78.1 (Legislative Counsel notice). Successor Act not retrieved; generic phrase printed.

C. Should resolve before promoting another REFER jurisdiction​

  1. Newfoundland and Labrador — cheapest promotion candidate: s.11 and definitions verified; need the consolidation currency date and the intake model ("manager, social worker or peace officer").
  2. Manitoba — confirm from the official bilingual PDF; note the s.18(1) parent/guardian route and the s.18(1.1) agency-only exceptions before generating text.
  3. New Brunswick — confirm the 2022 Act is in force and consolidated; find the intake line.
  4. Québec (legisquebec 403 twice), Saskatchewan (publications API 404), PEI successor Act, Yukon (403), NWT (404), Nunavut (403) — nothing verified; generic phrase printed; the coordinator attaches the current text before adoption.

D. Vulnerable adults — still open​

  1. Ontario "no general adult duty" — bounded negative finding. We verified two sector statutes (FLTCA, RHA); we did not survey the Substitute Decisions Act, the Adult Protective Service Worker program, or health-sector reporting. Clause keeps "to our knowledge ... asked a lawyer to confirm".
  2. BC designated agencies — the Act defines them by designation under s.61(a.1); the church fills the current regional contact. Not verified which bodies are designated.
  3. Alberta PPCA reporting line — the complaints-officer line is church-filled; the regulations (AR 97/2010) prescribing "a committee, body or person authorized under another enactment" and prescribed professions were not read.
  4. US Adult Protective Services — no source retrieved.

E. Screening​

  1. Six-month waiting period and renewal interval — church choices; both variables now declared and required. No verbatim insurer source.
  2. US screening — no federal summary retrieved; NSOPW not verified. US clause is recommended practice only.

F. US summary source​

  1. CWIG "Mandatory Reporting of Child Abuse and Neglect" companion — URL 404; cite by title only. The clergy PDF is three years old; check for a newer edition.

G. Product decisions for the founder​

  1. Launch with four LAW child jurisdictions (ON, BC, AB, NS) and REFER for the rest, or wait for NL/MB/NB promotion?
  2. Should the US version exist at launch, given every duty-to-report statement is REFER?
  3. Section 11 (child duty) and section 10 now render in EVERY policy, including adults-only ministries, because the duty is on every person in the LAW provinces and this removes all dangling cross-references. Confirm this product choice (it means adults-only churches must also fill the child-protection intake contacts).

Fetch log (revision 2, for reproducibility)​

Succeeded (downloaded and text-extracted locally): ontario.ca/laws/docs/17c14_e.doc (CYFSA, consolidation saved 2026-06-24); /laws/docs/21f39_e.doc (FLTCA); /laws/docs/10r11_e.doc (Retirement Homes Act); kings-printer.alberta.ca c12.pdf (CYFEA, current as of 2026-03-26) and p29p1.pdf (PPCA, current as of 2025-12-18); nslegislature.ca CFSA PDF (to 2026-04-09); bclaws 96046_01 (CFCSA) and 96006_01 (Adult Guardianship Act), both "current to September 15, 2026"; laws-lois.justice.gc.ca c-47 s.6.3 (current to 2026-09-03); web2.gov.mb.ca c080.php (unofficial, current as of 2026-09-23); assembly.nl.ca c12-3.htm; laws.gnb.ca 2022-c.35.pdf (enacted text); princeedwardisland.ca c-05-1 PDF (repeal notice); rcmp.ca/en/nunavut (WebFetch: emergency number sentence). Failed: laws.yukon.ca PDF (403); justice.gov.nt.ca PDF (404); nunavutlegislation.ca (403); legisquebec (403); publications.saskatchewan.ca API (404); gov.nu.ca emergency-services (403).