CASL Countdown: Week 17 Data Collection Review

Hopefully the last few days have been fruitful and your inventory of information from week 18 is ready for a more detailed review. This weeks idea is all about creative changes to your data collection practices and CEM templates. No time like the present to review how you are collecting data and build a plan to bridge the gaps between your current processes and potentially a new processes under CASL.

Here are some questions to get you thinking about some changes your programs may require:

Are you burying consent in a Terms of Service, End User License Agreement or Privacy policy?
    If so you will need to move this notice and make it front and center for new subscribers and customers. The CRTC guidelines have clearly stated that consent cannot be burried within any of these documents and must be clearly stated at the point of subscription. This also need to be separated by each form of consent your are asking for; CEMs, Install of software, material changes to applications or functions of a device/computer.
Are you using pre-checkboxes on your forms?
    These pre-checked boxes will need to be unchecked and clarified with additional language clarifying the requirement of supplying consent “I agree to receive CEMs…”. Another option is to remove the requirement of a check box all together and have the statement reads “By clicking “submit” the user agrees to receive CEMs”. While you still have time test these options over the next few months and see which works best for your organization. Be sure to take this opportunity to use wording that provides your organization with “Express” consent and that you are able to track this properly in your internal data warehouse, CRM and/or your ESP database.
Do you have all the prescribe information at the point of data collection and within your email templates?
    CASL requires a number of items be made available at the point of consent collection and within every CEM that is sent. These include; Postal Address, Contact information (phone, email, contact form, etc…), Privacy Policy and a statement about unsubscribe being available at any time. Build this same information into your data collections scripts at Point of sale, Call Center, Printed Materials and on the web.

** For POS solutions having this information on display at the checkout on a easy to see card/sticker will allow your staff to share this information with clients, this also works for the business card in a fishbowl draw at a trade show or on the counter of your business. If your POS solution allows for customization including this on the receipt or as a take away flyer is also an option for consumers to have a reminder when they get home and have questions. Bonus points for also building this into an automated welcome program, eReceipt solution and transactional templates. **

Do you upsell in your Transactional messages?
    CASL doesn’t distinguish between messages with multiple purposes like CAN-SPAM does where the 80/20 rule allows marketers to have a small space reserved for promotions or upsell opportunities. Any commercial content in your email will change the focus from a Transactional message to a Commercial one, requiring adherence to the unsubscribe and other prescribed elements of CASL. Consider breaking these into two different messages where the transactional message is sent and an upsell is sent separately but only to individuals that have provided their consent.

Once you have identified all of the required changes to your Messaging programs begin working with your design, programming and web teams to schedule changes to your systems, web pages, forms and templates to ensure these new elements are properly captured and upgrades are scheduled within time for CASL enforcement. Planning ahead here will save stress in the long term as development resources are typically scheduled several months in advance and require input from other groups beyond Marketing… IT and possibly other vendors will need to be made aware of your new requirements.

Author: Matt V - @emailkarma

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2 Comments

  1. Question for you Matt…does PO box satisfy the postal address requirement under CASL as it does Can Spam?

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