CASL Countdown: Weeks 7 and 8 – Verbal Consent

As the countdown marches on most of the grunt work for CASL should be in the works at this point and targets and goals should already be clearly scoped and under development. This week we will focus on verbal consent and some tips to help inform customers and provide a consistent level of service and consent collection to your database whether you have one or one thousand locations. As this is a big project it’s about the right time to start moving forward on this process update and tank the next two weeks to get it right. Getting this out-of-the-way makes room for some of the lighter, but still important and complicated, work for the next few weeks before the enforcement deadline.

Reminder at this point you should already be;

  • New CEM templates should be in testing and tweaking mode, or if you are eager already in use.
  • Updating your websites to use the new consent based data collection forms
  • Drafting, editing or testing scripts for call center/store level staff – possibly using new signage to convey CASL’s prescribed information to customers
  • Testing data models to synchronize unsubscribes and other data flows internally and between your data partners/vendors, and capture additional details for consent management purposes

Lets get started on building that training processes for new and existing front line team members. Building a formalized training process will help educate staff on why something that may not seem intuitive at first are properly explained and the importance of why they are in place are properly explained. Training for verbal consent is especially important for “Brick and Mortar” locations where lines are long and staff are trying to complete a transaction in as short of time as possible to get to the next customer.

Pitfalls to watch for and how to deal with them:

Under CASL if your staff are now trained to ask “Would you like a eReceipt?” but don’t ask for additional communications you may be unknowingly limiting the types of communications that you are seeking permission for in order to send CEMs to your customers. CASL is very specific on the questions being asked when it comes to consent based marketing. Having a sign “Why we ask for your email?” with a list of reasons – Marketing, Coupons and eReceipt communications – along with the other prescribed information can allow a client to self-educate themselves while they are waiting their turn at the register. This same type of information can be built into the self-service checkouts that are becoming more common at major retail and grocery locations. Having this informational sign handily avoids the situation where a customer asks “Why do you need my email?” and a staff member replies with “I don’t know I just get prompted to ask for it?” or “For coupons and stuff“. Both of these answers may not pass the test should the enforcement officers start asking questions about your business practices. I would also recommending including as a reminder on all receipts CASL’s prescribed information so that each customer gets a copy to take home with them when they leave the store.

Collecting consent via call center:

CASL allows for the collection of consent verbally, so being sure your call center is properly trained will also be a key area where you can collect consent from your customers. Building a script that details the types of communications that customers can consent to receive will be very important. Working with your call center to send timely welcome messages with all the prescribed information to the individual recipients will also be a key solution to investigate. Build into the script points that talk about how to contact customer care (they are already on the phone), that your privacy policy and address can be found on your companies website and that users can change their preferences (unsubscribe) via the proper channels will be very important. Conducting call sampling and recording of calls can act as proof of consent practices should you need to confirm the process is working.

Remember to build into your CRM solution tools to track where you gained consent (store level info, call center recording information) and define a process to confirm the new processes are being followed by staff members. Also look to shorten the time between data collection and a welcome email as much as possible, while reinforcing the prescribed information and making it easy to find for your consumers.

Author: Matt V - @emailkarma

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