# Harper Daily Log — 2026-02-21

## Payday Super Awareness — 00:50 AEDT

### Source
Radar (msg-1771592758374-7e66ba) — informational flag.

### What
Payday Super law commences 1 July 2026. Employers must pay superannuation on the same day as wages (currently quarterly).

### RateRight Impact: NONE (EXEMPT)
- RateRight is a marketplace — we don't employ workers and don't pay wages
- The obligation falls on builders/contractors who hire through us (they're the employer)
- No compliance action needed for RateRight

### Competitive Angle
- Labour hire companies ARE employer of record — they face significant admin burden increase
- Same-day super = more cash flow pressure on labour hire firms
- Makes RateRight's $50 flat fee model even more attractive vs traditional labour hire
- Worth flagging to Herald for potential marketing content

### Added to Compliance Calendar
- Item: Payday Super commencement
- Date: 1 July 2026
- Status: Monitoring only (RateRight exempt)

### ACK'd and responded to Radar with analysis.

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## No-Show Policy — T&Cs Legal Analysis — 12:30 AEDT

### Source
Task from Rivet (system wake) — Michael wants input on no-show policy for Terms of Service.

### Michael's Proposal
- Full refund to contractor
- Next hire free
- 2-strike system (2 no-shows = worker removed)

### My Analysis & Recommendations
Researched industry standards (Airtasker, Uber, TaskRabbit) and Australian Consumer Law requirements.

**Three key changes recommended:**

1. **Drop "next hire free"** — above market standard, costs $100/incident, creates perverse incentive
2. **Change 2-strike to 3-tier graduated system** — 2-strike permanent removal risks unfair contract terms challenge under ACL (illegal since Nov 2023, penalties up to $50M). Recommended: warning → 14-day suspension → removal with appeal rights
3. **Frame $50 as introduction fee, NOT guaranteed worker** — critical liability distinction. If we promise a worker, no-show = ACL service failure. If we promise an introduction, refund is goodwill.

### Deliverables
- Full report: `memory/no-show-policy-analysis.md` (industry comparison, legal analysis, draft T&Cs clause, financial impact)
- Sent to Rivet via inbox (msg-1771636035636)

### Key Legal Points
- Unfair contract terms regime (since Nov 2023) — must give workers due process before removal
- Define "no-show" precisely (60 min + no 2hr notice)
- Allow emergency exceptions with evidence
- 12-month rolling window with clean slate reset
- ACL s23-28 compliance throughout

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## Onboarding PDF — Privacy & Legal Analysis — 12:45 AEDT

### Source
Task from Rivet (system wake) — Michael wants branded onboarding PDF where workers enter bank details, next of kin, super, white card, tickets, licence. PDF saves to their phone, RateRight doesn't store it.

### Key Finding: CLIENT-SIDE ONLY
The entire analysis hinges on one architecture decision:
- **Client-side PDF generation** (jsPDF/pdf-lib in browser) → data never touches our servers → Privacy Act collection rules don't apply → minimal risk
- **Server-side PDF generation** → even transient processing = "collection" under Privacy Act s6(1) → full compliance obligations → breach notification risk for bank/super data

### Important Discovery: Small Business Exemption Probably Doesn't Apply
RateRight discloses worker personal info (contact details) to contractors for $50. OAIC defines this as "trading in personal information" which removes the small business exemption (<$3M turnover). We should treat ALL data handling as Privacy Act-compliant.

### Three Disclaimers Needed
1. Form page: data stays on device
2. PDF footer: self-reported, unverified, not employment contract
3. Next of kin: confirm third-party consent

### Deliverables
- Full report: `memory/onboarding-pdf-privacy-analysis.md`
- Sent to Rivet via inbox (msg-1771636537154)

### Competitive Angle Noted
"Fill it once, use it everywhere" + "we never see your bank details" = strong marketing differentiator. Flagged for Herald.