Suppressing e-mail communication to adhere to CAN-SPAM act

Has anyone implemented an e-mail suppression process to prevent iMIS users from sending e-mail to customers who have opted out of receiving e-mail per the CAN-SPAM act? We maintain a table of the e-mail addresses of our customers who have chosen not to receive any promotional e-mail. We use that table to exclude that set of customers when selecting lists for mass e-mail marketing campaigns. We also want to programatically prevent our iMIS users from sending e-mail through iMIS to these customers. One proposed solution is to use a Customer Service Alert to notify our customer service reps that the customer that they're viewing has opted out of receiving e-mail (using their e-mail address). That would provide a clear warning to the customer service rep but would not prevent them from sending an e-mail. We would like to programatically prevent such e-mail. We're interested in hearing from anyone who has implemented an e-mail suppression solution in iMIS 10.6 to support the CAN-SPAM act.

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Be sure to define your business rules clearly first

There are several things to consider especially when looking at the CAN-SPAM Act. The CAN-SPAM Act is a tool for the FTC to regulate email solicitation. It specifies that you must have an "opt out" or "unsubscribe" option for anyone who will receive solicitation emails. (You should also include a statement that the email is a "solicitation" in either the subject or the first few lines of the email body if it is a solicitation only email. These restrictions do not apply to emails involving orders, purchases, accounts or membership, pure informational communicaitons, etc. This also means an individual email from a staff member to a contact should not even fall under CAN-SPAM restrictions, only mass marketing emails.

Most iMIS users are incorporated under a 501(c)6 and have limited regulation by the FTC. Also, 501(c)3 organizations are completely exempt from the CAN-SPAM Act.

General best practice is to allow your contacts a choice in what communications they do or do not receive. This usually applies to mass marketing efforts, and even general communications (like an email Newsletter), however, more specific communications, like an email sent out to all members of a particular committee would usually trump these restrictions and still go the contact, since sitting on a committee generally includes receiving committee-specific emails. Another example would be an email confirmation for an event registration, dues billed or paid, or a product order.

You can control emails by utilizing a custom demographic tab with restrictions in place. Two examples are listed below, however, this does not prevent a staff member from just clicking on the "envelope" button next to the email address and sending out a single email. If you really have someone who chooses to never receive emails from you, this could be handled by setting restrictions on that email address at your email server, or by just removing the email address from anyone's access completely.

Examples using custom demographics to control communications:

  1. Simple opt out checkboxes: Set up a checkbox for "No mass Email at all", "No Email Solicitations", "No Email News", etc. Include these fields as they apply in all selection filters for a particular email selection, whether IQA, Crystal Reports, Omnis Ad Hoc queries, etc. and make sure the field is not "True" or <> 1
  2. More complicated opt out list string: This option allows for more detailed controls over communications and allows for quick additions to the "opt out" options without having to radically change all selection filters already in place. In this option, create a demographic field for "Opt Out" and set it up as a multi-select lookup field (recommend a length of 255). Set up your lookup with more detailed options as needed from the general overriding down to the specific opt out: "No Contact", "No Email Solicitations", "No Email News", "No Event Information", "No legal/political info", "No e-News", "No e-President's message", etc. Then use your selection filter to look at this field where it does not "contain" the given code for a given type of communication.

For emails directly from iMIS, e-communicate and Informz can access any of these controls.

For the MS Word Lettering System, just set up omnis ad hoc queries that include the business controls.

For direct Emails from the .NET side of iMIS, build a custom communication control business object that must be included in all email IQA queries. This object would incorporate your email control business rules and control whether the email address is available for this communication or not. This is usually done by setting up a view with the business rules that return an ID or ContactKey, the email address and the type of communication that is valid. You link this object in on ContactKey or ID and then specify the type of communication you are sending out under filters. Any records in this object that didn't meet this criteria would be excluded.

There are many other options you can set up including a very specific "Communication" control demographic where you could actually get down to very specific controls on all communications and could build a complete communication strategic plan into the use of the fields you set up, including controls for communication: Type, Method, and Timing. Going to this level can really drive all your communications into highly personalized messages, delivering the right message to the right person at the right time.

The point of all this is, start with a clear definition of your communication strategy and business rules, including what a contact can "Opt Out" of and then proceed from there. Be consistent and allow for contact-driven choices. In most business rules, you will have exceptions. By focusing on "opt out" management strategies, you should always be able to define a control feature for communications.

 If a contact chooses to never receive emails from you, take steps to eliminate the email address from iMIS and all other places, or lock it down at your email server level... (since you never know if this email address is lurking in one of your staffer's Outlook address book).

-K

Kevin Blouin - enSYNC Corp.