10 things to do in order to prepare for CASLMatthew VernhoutChief Privacy Officer, Mgr of Deliverability Inbox Marketer

• Consent options• Explicit vs. Implied• Installed software

• Preference management• Data management• Creative development

The end goal

• Grandfathered express consent under common law definition

• Implied consent three year transition• PRA Suspended until 2017• New exclusions:

• Political parties and Charity fundraisers• Foreign recipient exclusions• B2B Clarifications

Transition Period

You need to be compliant by July1, 2014 and there is

a lot to do to get ready.

• Use the next three years wisely• Transition period is three years from date

of enforcement

• Start an Audit of data sources• Where do you get names from:

POS, web page, co-registration, events, etc...• How are you asking for information

opt-in vs. opt-out 3rd party data use approval

• Do you collect source, time/date, IP, etc...

Audit Everything…

• Plan upgrade path• Build a communication calendar• Rules of engagement• Recency/Frequency

Multi-brand organizations

Get Organized

• Multiple teams increases risk where data is not centrally managed

Align data teams Centralize databases and unsubscribe

programs Build preference centers to make

subscription management easier for consumers

Streamline your email programs

• Upgrade your forms, and phone scripts Include proper disclaimers and required

information Visible signage in retail locations Centralized/standardized subscription

management forms• Subscribe pages, unsubscribe pages• Preference Centers

Upgrade your process

• Review existing Data Buckets: Known good sources (implied) Known good sources (express) 3rd party data Unknown sources Old Data (no longer used) Other?

• Develop a contact strategy for each of the buckets

Group “like” consent

• Cross Channel Awareness• Email, SMS, Social, IM, Future Tech

Multi-Channel approach

No

Silos

• Train your Staff and affiliates• Franchised organization make sure owners are

aware

• Build it into your company culture from the CEO to the Interns

• Due diligence is key

Training

• Build sun setting and reactivation programs

• Plan permission upgradeprograms

• Develop declining engagementprograms

Plan for the future

• Engage your vendors or think about getting a vendor if you don’t have one

• Shorten times for compliance• Already have much of this built into

their systems

Bonus!

Thank youMatthew Vernhout

Chief Privacy Officer, Manager of Deliverability @emailkarma