Annex Business Media’s Vesna Moore, director of circulation and CASL compliance officer, explains why circulation and CASL are a good fit, how CASL impacted their business and why others need to seek out help.
AAM: Tell us a little bit about yourself and how you became involved with CASL compliance.
Vesna Moore: I don’t recall actually volunteering for CASL (laughs). As we started reviewing what CASL was and how it impacted our business requirements, we realized that a lot of the new legislation was similar to AAM audit requirements. We needed to manage the data, manage the emails, establish best practices and be the gatekeeper. It fit naturally with circulation; I can’t see how we would have been nearly as successful if another department was managing CASL. We’re the ones who manage the data and have our hands in the data so we needed the authority to make the changes required by CASL.
AAM: How is your business impacted by CASL? How have you changed your email marketing strategy to accommodate CASL?
Vesna Moore: CASL has impacted us on a number of fronts. We’ve always had a very large email marketing business and guarding our email addresses has always been a priority. I think that made it easier for us to get up to CASL standards but we still had to do a lot of development, processes reviews, assessments and training. We spent a good three months working with developers to establish tracking, consent forms and recordkeeping.
A secondary impact was dumping some of our emails that did not meet the standards. We lost about 10 percent of our email database, which means a loss of future revenue.
Finally, we had to look at how to process and budget for future efforts for expiry, ongoing consent and increasing express consent. We now have an ongoing budget for costs related to CASL so that we can maintain our compliance.
AAM: The July 1, 2017 PRA was suspended. Has this changed any of your CASL compliance initiatives?
Vesna Moore: It didn’t really make any difference to us because if we’re not compliant then we’re not compliant, regardless of the consequences. Without the PRA element, businesses still run the risk of a $10 million fine from the CRTC. Being compliant avoids fines.
AAM: You were one of the first in the industry to really take charge on CASL. Why was it so important to you?
Vesna Moore: We maintain a very robust database and work hard to monetize that database. As soon as we started to familiarize ourselves with CASL, we knew that a part of our list would be impacted and so would our business.
At Annex Business Media, a lot of the direction came from the top down. The resources we needed to become CASL compliant wouldn’t have been accessible if our upper management hadn’t understood the true risk of CASL.
Obviously, the severity of the penalties was a real instigator for us to be serious about CASL. But a lot of the CASL requirements are good best practices that benefit our customers, so it made sense for us to adopt those standards.
AAM: Why was an audit from AAM helpful in ensuring you were CASL compliant? Would you recommend other businesses engage in such an audit?
Vesna Moore: If you have your magazines audited, you already know that your claim of integrity for CASL is no different than audit statements for circulation. When we sell our lists in the U.S., some U.S. businesses want to pull out the Canadian names because of CASL concerns. Our AAM audit goes a long way in establishing trust with those clients to ensure they are not going to incur any risks or fines. A certification is valuable as a sales and marketing tool.
The other side of the certification is that we learned how compliant we were or weren’t. It gave us the opportunity to see our processes through someone else’s eyes and gave us a clear vision of where we were in the compliance process. The certification also helps us mitigate any risk with the CRTC. If you know you’re nowhere near compliant, it’s even more important to find a third party to help you fill in the gaps before you get in trouble with the CRTC.
AAM: Can you share some of the key steps you took to ensure CASL compliance?
Vesna Moore: The foundation of CASL is to take an inventory of everything you send: how it is classified, does it have advertising, what email addresses you have and how you acquired them. Once you have all that sorted out, the next step is to look at who has access to the data. What are the controls around it? Is it locked down enough that a rogue employee or intern can’t access the data? Those are great places to get started and can be sorted out by gathering people together in a room and walking through it.
AAM: What are some of the ongoing tasks you do to ensure you remain CASL compliant now that you’ve established a program?
Vesna Moore: Any good CASL compliance program is ongoing. We send a lot of emails and every single one goes through three people before it is deployed to check the unsubscribe and the content. That is something that will never go away.
AAM: What is one thing you wished your colleagues in the industry understood about the implications of CASL?
Vesna Moore: A lot of people don’t think it is real; these are people who should know better. Many think it is an onerous or silly law and don’t want to do anything to abide by it.
It’s the law, it’s the legislation and you cannot break the law without consequences. What you’re currently doing isn’t enough and the implications are too significant to ignore.
But regardless of the legislation, CASL makes good business sense. It gives your audience the ability to manage their own accounts and gives them control over their email.
AAM: Anything else you think businesses should know about CASL?
Vesna Moore: Don’t ignore CASL. Seek out help if you need it. CASL is not going away and you’re not too small to get noticed by the CRTC.