Sunday, 22 August 2021

On Mandatory Recordkeeping for Contact Tracing

On 22 August 2021, Minister Chris Hipkins announced that recordkeeping for contact tracing purposes would become mandatory at "busy places and events" at all alert levels. Below are comments written for the Science Media Centre. I have also previous written about how businesses can support NZ COVID Tracer use.

The delta variant is much more transmissible than previous variants of COVID-19. We know that time-to-isolation is one of the key factors that determines how successful we are at containing any outbreak of the disease. Contact tracing is a key epidemiological tool that helps us identify the right people who need to isolate or get tested. Manual-only methods can be effective, but technology can significantly augment and speed up the process, giving ourselves the best chance of cutting off chains of transmission. Digital contact tracing supports this process by helping us keep track of our movements, and provide the information to contact tracers in a format that helps them act faster.

The government’s announcement today about mandatory recordkeeping for “busy places and events” (which translates roughly to the language of “higher-risk venues” that is used in overseas jurisdictions) at all alert levels is an important and significant step. The list given in the press conference includes “cafes, restaurants, bars, casinos and concerts, aged care, healthcare facilities (excluding patients), barbers, exercise facilities, nightclubs, libraries, courts, local and central government agencies, and social services providers with customer service counters.” The new rules will be introduced 7 days after we move down each alert level, applying to the set of venues that can open up at each level.

One of the big challenges with digital contact tracing in NZ has been the relatively low level of participation. Before the current outbreak of cases, only approximately 10% of New Zealand adults were scanning QR codes on a regular basis. The Bluetooth Tracing participation rate was more promising (around 35-40%), but this is still not high enough to give us confidence that the data will cover any outbreak anywhere in the country. Modelling from Te P┼źnaha Matatini last year showed that we need at least 60%, and preferably 80%, of adults participating in digital contact tracing to have a meaningful impact on the reproducibility rate of COVID-19. With the delta variant, we need that participation rate to be higher than ever.

The international evidence suggests that making recordkeeping mandatory is the strongest driver for increasing the participation rate. Some form of mandated recordkeeping has been in place in Australia at a State level, in Singapore, Qatar, China, India, and previously in the United Kingdom. In New Zealand, we have seen evidence that even unenforced mandates (e.g. mask wearing on public transport) have a significant effect on behaviour, and that it sends a clear signal to the public on what the government expects is necessary for us to keep COVID-19 under control. The current penalties in the COVID-19 Response Act are not massive ($300-$1000), but they are under review and could increase.

It is important to note that this announcement relates to mandatory recordkeeping, not QR code scanning specifically. While people who cannot use NZ COVID Tracer are also welcome to try Rippl, venues will also be required to have pen and paper options available. It is important that businesses move away from using sheets of paper on clipboards, and use ballot boxes where available. With the sheets of paper, anyone can read the details of other people who have signed-in already, which can lead to some of the privacy breaches we saw last year with serious consequences. With the ballot box, individuals write their details on a small slip of paper, and then drop them into a box (like an election box) so that other members of the public cannot easily access them. Venues can then clear the box once a day, putting the slips of paper into a bag with the date on it in case they are needed by contact tracers later on, or otherwise discarding them after 60 days. The government has a ballot box template available online.

Business owners and those organising events will also be concerned about enforcement of recordkeeping. At this stage, the onus falls on them and their staff to enforce it – clearer guidance will need to be provided by the government on how those staff deal with people who insist on not providing their details. If it is too restrictive (e.g. people are turned away), there may be human rights implications if this means people cannot access services that provide basic needs. A common-sense balance needs to be struck between keeping the community safe, and not further antagonising those who choose not to comply.

This would also be a good opportunity for the government to invest into addressing the digital exclusion challenges that face many New Zealanders. By some estimates, as much as 20% of the adult population does not have access to a smartphone or the skills to use one effectively, and policies such as vouchers for smartphones or more funding for community skills training could help improve the proportion of NZers participating in digital contact tracing. That digital access and skills training will have long-term benefits beyond the pandemic as well.

It is also an opportunity for the government to introduce legislation that protects the data collected through digital contact tracing platforms to ensure that it can only ever be used for contact tracing purposes. In Singapore and in some Australian states, trust and confidence in digital contact tracing were significantly impacted when it was revealed that Police had accessed the data for law enforcement purposes. While New Zealand Police have stated that they “have not, and will not” use NZ COVID Tracer data for law enforcement purposes, legislation to create stronger penalties for misuse would further assure New Zealanders that participation is safe. Such legislation would also protect against employers or businesses misusing that data as well.

There are some risks that come with mandatory recordkeeping, but the government has the tools to mitigate many of them. For the rest of us, it serves as a reminder of the role that movement records play in the contact tracing process, and how critical it is for all of us to play our part. In the best-case scenario, we keep these records and then throw them away because we didn’t need them. But infected people and contacts having their records from before they get sick could make the difference between managing the outbreak successfully and the virus running out of control. We have all done a lot more, for a lot less.

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