Contact Tracing and your Beauty Establishment

contact tracing during covid 19 in salons and spas
Disclaimer!
The following information comes from the firm of Maclaren Corlett LLP. The following text and its contents are not intended as legal advice nor do they create a solicitor client relationship between the firm of Maclaren Corlett LLP, with any person reading this text or subsequently reviewing its contents. 
Facts are as currently know on June 22, 2020. Changes come rapidly. 

Although there are various ways of saying it, Contact Tracing is basically a method of identifying people who may have unknowingly been in close contact with someone who has contracted COVID-19 and notifying them that they may now be at risk, so they can then self-isolate until they can be tested and get the results. 
The intention of this blog is not to deal with the use of Contact Tracing Apps by the general public, but rather the more basic techniques to trace the contacts of clients, beauty professionals and general service providers if one of them has become infected with the virus. 
Some Fundamentals: 
  • Keep up with the basic COVID-19 guidelines in your Province! 
  • Take appointments only, no walk-ins. 
  • Identify and note the client and their contact information, the beauty professional they are meeting with, the date and times they arrive and leave. 
  • Make sure any existing client contact information is complete and up to date.
  • Maintain social distancing practices. 
  • Transfer to digital/cashless payments. 
  • Included benefit is the Credit/Debit card machines record can be used as client time of departure. 
  • Keep a diligent record of who is in your salon and when. 
  • As a rule of thumb, this should include anyone who comes in contact with your establishment, especially for more than 15 minutes. 
  • Delivery Services should also be recorded, especially if time and date is not included on the invoice.
  • “COVID” Work schedule should record all beauty professionals by date and time.  
  • Record any unusual attendances if contact is made (i.e. emergency plumbers). 
What Happens if you get “The Call”? 
With expanding social circles and businesses opening, it can happen; you get “the Call” from a client, one of their family members or a Public Health Official saying you have had an individual with COVID in your establishment.
Especially if the call has come from Public Health, clarify who will notify the appropriate people; i.e. designate an individual who will be responsible for taking the information down from the caller. Get as much detail as you can so you can focus the contact list of individuals to notify. 
You MUST BE CAREFUL of who you tell this information to, as there may be privacy issues. The infected individual’s name and information cannot be divulged, nor can the information included in the focused contact list created. Hence the suggestion to designate a specific individual for “the Call”. 
You cannot broadcast that someone has the virus, but you (or Public Health) must notify those who came in contact with the COVID-19-postive person, that someone tested positive and they may have been exposed, and you can identify to Public Health who the people are who may have come in contact with that COVID-19-positive person.
What detail is required to be provided?
  • Requirements may vary by jurisdiction and many have none or are generally vague.
  • As an excellent and very ‘common sense’ example, in Nova Scotia a client registry (name, phone number, date and time of visit) and a staff registry (name, date, time of shift worked) must be kept to assist with facilitating any necessary contact tracing by Public Health. The Cosmetology Association of Nova Scotia has some very helpful resources on their website (https://www.nscosmetology.ca/)
  • As another example, restaurants in Ontario must maintain logs for customer and staff contact information. Operators are required to keep logs of the name and contact information for customers and staff, with a check in time. If there is a case of COVID-19 who was contagious while at the restaurant, public health will use that list to notify the staff and customers.
  • Where procedures are invasive, more stringent information is required.
  • As time progresses rules and requirements will change, so this is something to continuously monitor.
Privacy Issues
If you’re in a situation where privacy concerns are coming up and you’re not sure what to do, contact legal representation right away.
Thank you Maclaren Corlett LLP for assisting with both our Facebook Live presentation (watch here: https://www.facebook.com/watch/live/?v=2744403869150017) and this blog post. 
Maclaren Corlett LLP Contacts: 
Gordon Greenwood 
ggreenwood@macorlaw.com
Megan Fife 
mfife@macorlaw.com
Mary Griffith 
mgriffith@macorlaw.com

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