We are staring at the strong probability of New Zealand entering Level 2 as early as Thursday. For almost all businesses, there will be a requirement for some form of contact tracing. Businesses will also need to monitor and control the numbers of people within their premises to no more than 100. Additionally, under the Health and Safety at Work Act, firms need to keep an accurate record of all people in their premises so that they can have information in case of any emergency.
Unfortunately, the government has not been very explicit about what that contact tracing will look like. Mention of QR codes had been made many times. There was talk of a mobile app to be released soon.
Houston was invited to help the MoH
Even before the debate about the best contact tracing app for NZ hit the front pages, Houston had argued for the inclusion of QR codes in the design for the app.
Houston was invited to submit such a proposal to the Ministry of Health and had now been told that its idea had been accepted by the Ministry. While the full details of the app have not been released, this is what we believe it will look like:
Unique QR codes will be used to identify the businesses (supermarkets, retailers, sports venues, public transport vehicles, open homes, et cetera) and their locations
People including staff, customers and other visitors will use their mobile phones to scan the QR codes on entering premises. This transfers contact details from the mobile phone owners to the businesses’ register in the cloud in a totally contactless manner
In the event that a person is identified as COVID-19 positive, the MOH can easily identify where that person had been and who had been in close contact with him/her.
The MoH app will not meet all the requirements for opening
However, the MoH app will not meet all the requirements for opening such as information on the number of people in the building at any one time. Businesses therefore will be unable to easily guarantee that the number of people in the premises do not exceed regulated limits.
Previously, the requirement for keeping a register of visitors was necessary. In the new environment, this requirement is critical and needs to be expanded to include movements of staff. Additionally, businesses need to perform visitor screening by asking guests questions about their movements and symptoms in the past 14 days. Finally, it will be very prudent for businesses to ensure that visitors acknowledge businesses’ policies on COVID-19 prevention.
None of the above requirements will be included in the MoH design.
It is obvious that the ministry will be relying on third-party software writers to fill the gaps. As a result of the vacuum, I have observed a rush to the market of many mobile apps claiming to meet the requirements for COVID-19 contact tracing.
Unfortunately, the standards for the QR code as well as the structure of the APIs (the connector software that allows third-party apps to send data to the secure MoH database) have not yet been published by the MoH. Without that information, no app developer can complete development and the MoH cannot even commence the process of certifying the compliance of any app.
What should businesses do and prepare then?
In the face of these unknowns, what should businesses do to meet the contact tracing requirements for reopening? The following advice is based on information that I had researched from public sources as well as private conversations with knowledgeable contacts.
I recommend that all businesses start contact tracing with whatever means they have: an existing visitor registration system including a hard copy register.
The Ministry will release more than one version of its app. It had already indicated that version 1 would merely be for users to update their contact details in the government database. Future versions will be useable for contract-tracing and connect to the National Contact Tracing System. Only then will the MoH allow third party apps to join the system. For this reason, the MoH is urgently developing a certification process for third party apps.
For this reason, I strongly advice businesses to not jump into using any (and particularly paid) apps but to wait for the certification process to be in place (most likely by middle June) before doing so. Any third party app claiming to meet the MoH’s COVID-19 contact tracing requirements are doing so without sound basis.
Additionally, be on the lookout for mobile apps that will work both as a contact tracing as well as visitor registration in one single application. Otherwise, staff and visitors will need to use two separate apps which will be time consuming and annoying.
Watch out for the release of such two-in-one apps by players like Houston as soon as the certification process has been completed.