Canada’s Anti-Spam Legislation (CASL)

Policy Statement: This document outlines B2B Network Services’s policy, aiming to ensure compliance with Canada’s Anti-Spam Legislation (CASL) regarding the transmission of commercial electronic messages (CEMs) to B2B Network Services clients and potential clients within Canada. The Anti-Spam Policy and associated CASL Procedures guide B2B Network Services employees in sending CEMs from or to computer systems in Canada, ensuring adherence to CASL regulations.

Policy Details: The Anti-Spam Policy delineates B2B Network Services’s obligations under CASL concerning commercial electronic messages sent to clients, potential clients, and others. B2B Network Services may introduce additional policies and procedures to enhance anti-spam measures over time.

Application: This Policy applies to B2B Network Services employees involved in sending CEMs from or to computer systems in Canada or electronic addresses accessed from Canada. B2B Network Services has adopted the Anti-Spam Policy to align with CASL requirements and commits to compliance. All B2B Network Services policies and procedures must align with the Anti-Spam Policy to deter spam activities within Canada effectively.

Consent: B2B Network Services obtains express, opt-in consent before sending CEMs to individuals without an existing business relationship within the preceding two years, unless implied consent or consent exceptions apply. Verbal consent is acceptable if documented in a database. Consent requests must be separate from other communications and cannot be bundled with agreement terms.

Form and Content of CEMs: CEMs must adhere to CASL requirements, including identifying the sender, providing contact information, and offering an unsubscribe mechanism. B2B Network Services ensures third-party service providers sending CEMs on its behalf also comply with CASL regulations.

Storage of Relationship Details: Maintaining records of client and potential client relationships is crucial for CASL compliance. B2B Network Services business units must record implied and express consent in CRM systems for at least three years after ceasing CEM transmissions.

Commercial Electronic Messages: All CEMs sent by B2B Network Services employees from or to computer systems in Canada must comply with this Policy. Exceptions include messages to existing clients about their business, internal communications, legally required notices, and responses to inquiries.

Compliance by Third Parties: Service provider contracts must include CASL compliance clauses.

Unsubscribe Mechanism: CEMs must include an unsubscribe mechanism processed within 10 days of the request. Recipients can unsubscribe by visiting a designated link or emailing with ‘Unsubscribe’ in the subject line.

Policy Administration: The Compliance department of each XpertLync legal entity maintains the Anti-Spam Policy, reviewed and updated annually, with any changes requiring board approval.

Review and Approvals: XpertLync Compliance reviews and revises the Policy annually, subject to board approval.

Enforcement and Audit: Non-compliance may lead to disciplinary action as per the Global Human Resources Disciplinary policy. Compliance is subject to periodic review by XpertLync.