THE CASL COUNTDOWN. Your week-by-week checklist to ensure your organization is CASL-ready for July 1st

Transcription

1 THE CASL COUNTDOWN Your week-by-week checklist to ensure your organization is CASL-ready for July 1st Inbox Marketer s CASL Countdown is a checklist of tasks for your organization to complete to ensure you comply with Canada s Anti-Spam Legislation before the July 1st enforcement date. This checklist begins during the week of March 24th, 2014 and assumes you can effect change fairly quickly in your organization. Of course, each organization is different, so please don t take this as a be all and end all schedule. Adjust it as needed to ensure you can implement the tasks in a timely fashion. Should you have any questions about this checklist or wish to enquire about our Customized CASL Audit, contact our Chief Privacy Officer Matthew Vernhout at mvernhout@inboxmarketer.com or call

2 YOUR -BY- CASL CHECKLIST 14 Educate yourself and your organization about CASL (i.e., Build education and awareness internally with all stakeholders at all levels of your organization Form a CASL Readiness team or establish an individual to lead your CASL compliance General assessment of companies operations and impacts to business related to: Commercial Electronic Messages (CEMs) Installation of computer programs Alteration of data in transit 13 Take inventory of your current digital marketing programs including: enewsletters Transactional s SMS/MMS Social media Identify all of your input sources, such as: Point of sale Call center Web Social channels Paper contests Events Third parties Identify the location of all of your data: service provider Call center Internal/External data warehouse Ecommerce vendor Agency Others Determine where your master records are located and ensure you sync all data to this record set Identify all of your output sources: service provider Mobile marketing provider Web pages/triggers Ecommerce solutions Corporate s Other(s) 2

3 12 Review data collection locations for prescribed information which includes: Postal address Privacy policy Contact method (phone, , contact form) Unsubscribe statement Identify missing forms and start updating processes Review CEM Templates for prescribed information: Postal address Privacy policy Contact method (phone, , contact form) Unsubscribe links (test to ensure they work!) Consider a preference center for managing mailing preferences Data management will be key to compliance 11 Review existing data and groups consents: Express (Express consents, obtained before CASL comes into force, to collect or to use electronic addresses to send commercial electronic messages will be recognized as being compliant with CASL.) Implied Third party Unknown None Identify gaps in database fields or other data collection solutions/processes: Consent date Consent level Consent source (Website, IP address) Last implied date Last contact date 10 Build messaging programs to upgrade consents where necessary Use the three year transition time effectively Identify consent types going forward Express* (consent good until withdrawn) - Good for long sales cycles or infrequent contact programs Implied (consent good for 24 months) - May work well for short or frequent sales cycles - Be sure to monitor 24 month expiry for a program like this Inquiry (consent good for 6 months) Blended consent - May be harder to manage *Highly recommended for all programs 3

4 9 Check-in on the progress of the items listed in the previous weeks, make note of anything outstanding Rollout completed CEM template changes for web and from Week 12 Validate changes are working as expected Validate data flow for subscriptions, timestamp updates and unsubscribes are working as expected 8 Begin development of pre-deployment checklists and assign gatekeepers for CEMs (i.e., get a second set of eyes to help ensure you re meeting CASL requirements) Validate recipient lists by channel and count Validate proper and new creative is being used for all messaging: - Check that prescribed information is included - Test delivery of s to ensure compliance with ESP, ISP 7 Computer Program Compliance (applicable to and software installations for PC or mobile devices) Review the install process: Does your software change the function of a computer in a way that would contravene CASL? Does your software try to install additional apps/features? Review permissions required and prescribed information Update install processes before January 15, Review Third Party Contracts Establish a checklist and revise contracts with any third party partners to require compliance with CASL Third party providers, review the contract to ensure they contain a representation & warranty that the list was assembled/maintained in compliance with CASL* Outsourced e-marketing to third parties, review and update services contracts to ensure they comply with CASL+ *Most ESPs forbid this by contract +Most ESPs have an all relevant local legislation clause in contracts 5 Develop an internal compliance monitoring program (i.e., scheduled self-audits) Identify sign off, deployment and logging processes Build record keeping systems Begin planning for Fire Drill scenario if something were to go wrong 4 Review program changes and impact to company Privacy Policies and Terms of Service Start internal process to update these documents and alert consumers of any changes, as required Update internal policies to be aligned with any required changes 4

5 3 Build internal training and education programs to update staff on new processes and program changes Align training for all new hires and staff involved with deployment of CEMs 2 Identify efficiencies and process changes that can help improve workflow and production changes Ensure all template changes are completed and old forms are removed from circulation Ensure all required notices are updated Test welcome programs and data collection forms are properly collecting information Test preference centers and data synchronization processes are functioning as expected 1 Begin CASL compliance program monitoring and testing Make any additional changes or updates to program efficiencies where possible JULY 1+ After July 1st Continue CASL compliance program monitoring and testing Build CASL compliance into future projects and development programs with your Project Management and Vendor development teams Consult with a CASL expert for scheduled audits and monitoring to ensure any new processes or initiatives are compliant About Inbox Marketer Inbox Marketer is a digital direct messaging company that helps organizations across North America to use , mobile, social media and the web to build online communities of customers and prospects. The company offers technologies and services that make it easier for digital marketers to integrate their communications across all digital channels and measure a cross-section of results. GUELPH OFFICE 381 Woolwich Street Guelph, Ontario Canada N1H 3W8 TORONTO OFFICE 1075 Queen St E Toronto, Ontario Canada M4M 1K inboxmarketer.com 5