Canada

1
Canadas Anti-Spam Law(CASL)

• Important information for Independent
  Representatives and Leaders

2
Supporting Documents

• Following the webinar, Avon will be providing you
  the following documents for future reference
• QA
• Tips to Consider when sending out CEMS
• Link to webinar
• Unsubscribe Matrix

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What is CASL

• CASL stands for Canadas Anti-Spam Law, which
  comes into effect July 1st, 2014. It prohibits
  any unsolicited commercial electronic messages,
  known as CEMs.

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What is a CEM

• A Commercial Electronic Message (CEM) is a
  message whose purpose is to encourage
  participation in a commercial activity
• For example Avons e-brochure
• A CEM includes a message sent to
• An email account
• A telephone account (text, SMS, etc.)
• An instant messaging account (iMessage, BBM,
  etc.)
• Any similar account

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What is the impact of CASL

• One will need consent from the recipient before a
  commercial electronic message (CEM) can be
  sentincluding
• Emails to promote products or a business
  opportunity
• Instant messages, text messages and other
  electronic communications to promote products or
  a business opportunity

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What is the impact of CASL

• Mandatory content will be required in all CEMs,
  i.e.
• Name and contact information
• mailing address and telephone number or email
  address or web address
• an electronic signature automatically including
  such requirements could be helpful
• Stéphanie Lefebvre5500 Trans-Canada Highway,
  Pointe-Claire, Québec, H9R 1B6Phone
  514.630.5432stephanie.lefebvre_at_avon.com

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What is the impact of CASL

• Mandatory content will be required in all CEMs,
  i.e.
• Unsubscribe mechanism or language reminding
  Recipient that they can opt out of receiving
  CEMs. For example If you no longer wish to
  receive campaign updates, please let me know by
  replying to this email.
• Opt out requests will need to be acted upon with
  ten (10) days. This means updating your contact
  list to reflect such wish!
• AVON Canada will, in addition to the above,
  provide the possibility of opting out of CEMs for
  Registered Customers, Representatives or Leaders
  through their Communication Preferences page on
  Avons website

Customers must unsubscribe from their
Representative and Avon separately as these are
two (2) different entities!
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Updating your Communication Preferences

• Avon has updated the functionality of
  Communication Preferences page.
• As a result, we will ask each Representative to
  re-enter their preferences accordingly (July
  timeframe).

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Unsubscribe Requests
Requestor Unsubscribe from Actions/replies from Leader Actions/replies from Representative
Avon Representative Avon.ca or DSM emails Ask Representative to update their own preferences on avon.ca website. When a Representative changes their preference to unsubscribe from DSM emails, a notice is sent to the DSM (notice to be sent by Sales Admin every campaign). N/A
Avon Representative Leader emails Leader should maintain their own unsubscribe list. N/A
Customer Avon.ca Ask Registered Customer to update their own preferences on avon.ca website. Ask Registered Customer to update their own preferences on avon.ca website.
Customer Representative emails Ask Customer to contact their Representative directly to unsubscribe. Representative should maintain their own unsubscribe list.
Prospect DSM emails Ask Prospect to contact the DSM directly to unsubscribe. Ask Prospect to contact the DSM directly to unsubscribe.
Prospect Leader emails Leader should maintain their own unsubscribe list. Ask Prospect to contact the Leader directly to unsubscribe.
Prospect Representative emails Ask Prospect to contact the Representative directly to unsubscribe. Representative should maintain their own unsubscribe list.
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Exemptions to CASL

• Face-to-face meetings
• Voice (telephone) and facsimiles (fax)
• Electronic messages responding to an inquiry
• Electronic messages to Friends and Family (close
  relations / reasonable person test)
• Posts on social media, including Twitter and
  Facebook (as opposed to one-to-one or one-to-many
  social media messaging)
• Electronic messages covering transactional
  communications (for example information on
  delivery)
• Electronic messages covering non-commercial
  activity (for example holiday wishes)
• Electronic messages from a business to another
  business (B2B) For example Avon, when
  communicating with its Independent
  Representatives and Leaders.

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How does CASL affect your business - prospecting
Prospecting Activity CASL applies?
Face to Face Meetings including AVON on locations / Tailgating / Power Hours/ Home Parties NO - exempt
Referrals YES
Social Media (e.g. Facebook, LinkedIn, Twitter, etc.) YES for one-to-one messaging, NO for posts
Prospecting via online or local bulletin boards or websites such as Kijiji, Craigs List, Emploi-Quebec, etc. YES
Cold calling NO exempt (but be wary of the DO NOT CALL list)
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Face to face contacts

• AOLs, Tailgating, Power Hours, Door knocking,
  home parties
• Excluded from CASL (since no electronic messages
  are exchanged)!
• If an email address is given to you to receive
  future electronic communications about Avon,
  follow up by email is therefore appropriate

13
Referrals

• Consent is not required for the first CEM
  following a referral from a friend, customer (but
  mandatory content remains required, i.e. contact
  information and opt out option)
• Stéphanie Lefebvre5500 Trans-Canada Highway,
  Pointe-Claire, Québec, H9R 1B6Phone
  514.630.5432stephanie.lefebvre_at_avon.com
• If you no longer wish to receive emails from
  myself, please let me know by replying to this
  email.
• In additionthe full name of the individual who
  gave the referral, as well as the connection to
  such individual is required in the first message.
  
• For example Hi Doris! I am an Independent
  Representative for Avon and your name was given
  to me by one of my customers, Alexandra Lewis,
  who I understand is your neighbor and good
  friend.

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CASL and Social Media (Facebook, etc.)

• Posts are Fine!
• One can post the AVON opportunity on its page
• One can highlight the brochure every campaign
• One can share success stories
• One can offer incentives to join Avon
• One can post a Facebook party

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Email addresses showing/published/disclosed

• Kijiji, Craigs List, Facebook groups, bulletin
  boards, etc.
• If one has published his or her email address,
  you may contact them as long as a relevant
  connection to AVON applies
• Examples of a relevant connection to the Avon
  opportunity people running home
  based-businesses, people looking for part-time
  work, seasonal jobs, etc.
• Example of non-relevant connection to the Avon
  opportunity puppy selling ad, etc.

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Ballot Boxes

• Avon is currently reviewing its ballot forms so
  that a standardized and CASL compliant format is
  used going forward.
• Post-July 1st, 2014, a customer/prospect should
  not be contacted by e-mail, unless he or she has
  clearly indicated his/her consent on the ballot
  form (checked yes).
• If check boxes are left blank, you should not
  contact the customer/prospect by e-mail as
  consent was not provided (calling is fine but be
  wary of the do not call list).
• The customer/prospect provided me with their
  e-mail address therefore why cant I contact
  them?
• The reason the customer/prospect disclosed their
  e-mail address to you is to take part in the draw
  which is not a relevant connection to why you
  would want to contact him/her, therefore
  expressed consent is required as per CASL.

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Tips for Sending CEMs

• Dont send an electronic message without their
  consent
• Clearly identify yourself and your business
• Provide an opportunity to opt out

Representatives when dealing with your Customers
Leaders when dealing with your Customers and
team members
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Where can I get more information

• Although Avon has provided general guidelines on
  CASL, you might find the government website
  (www.fightspam.gc.ca) useful for any further
  questions or interpretation

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