We have been working hard to try to figure out how this pertains to us as an organisation, and by extension, each of our churches. The only thing we can tell you for sure is that, well, we don’t know for sure. There are lots of organisations that are interpreting this in lots of different ways – in our estimation, from underplaying it to going overboard.

One things we do know is that non-profits are not the primary targets of this. This is designed to give the authorities teeth to go after the larger spam offenders. There will be due process and deliberation as cases are brought to authorities on these matters. However, the reality is that these laws are going into effect, and we are subject to them.

What we all need to be doing is keeping records which show that people have opted-in to our communication. The process where people sign up to Pulse records a date stamp for us, which demonstrates that a reader initiated contact. At this stage, these laws only affect commercial messages. But the definition of a commercial message is broad: it can include any information about an event, service or product that costs money (this is a grey zone).
Curiously, Messages with the express purpose of fundraising have been exempt from this law given that most non-profits would suffer heavily if restricted.

For people who have a relationship with us, we have implied consent to send them messages. This lasts for 2yrs, during which we need to work to migrate our people and our systems to express consent. It means that we need to build consent into the ways that we’re asking for e-mail addresses, whether on contact cards, or online e-mail sign-up pages.

To create effective e-mail protocols, we need:
• To go from implied consent to express consent.
• To quickly identify the sender of each message, and what its purpose is.
• Provide an unsubscribe mechanism for mailing-list type services.

If you’d like to dialogue about this, comments are open, and we can process it together there.

2 replies
  1. Al Bergsma
    Al Bergsma says:

    I noticed that the 4C’s have an article out on this just this past week. Some organizations are sending out an email asking for permission to continue to communicate. I think that the format used in these emails are almost all the same, so it would pay to look into it, and send it out.

    • EFCC
      EFCC says:

      Thanks for the comment, Al. Yes, we’re seeing those as well. We’re in the process of streamlining our email operations with better focused tools (esp. MailChimp). This is going to enable us to obtain and track permissions better, and give us simpler unsubscribe mechanisms, which are two elements brought up by CASL.

      I couldn’t find anything on CCCC’s public blog about CASL — is there a link I could share here?

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