INTRODUCTION – The Public Affairs Association of Canada (PAAC) provides a vital forum for public affairs practitioners throughout Canada to network, share experiences and improve their professional skills.
The purpose of this Policy is to establish rules that govern the creation and distribution of commercial electronic messages (CEMs) by PAAC in accordance with Canada’s anti-spam legislation (CASL).
A CEM is defined in CASL as a message that encourages the recipient to engage in commercial activity, is sent by any means of telecommunication (including a text, sound, voice or image message), and is sent to an electronic address (e.g. e-mail account, instant messaging account, telephonic account, or any similar account).
PAAC commits to ensuring that all CEMs are sent in accordance with CASL and that the distribution of CEMs by PAAC is minimized to the furthest extent possible.
COLLECTING INFORMATION – PAAC solely collects the name, title, business address, business telephone/fax number, and business e-mail address of an employee of an organization, i.e., the identifying information normally conveyed on a business card (“Business Information”).
PURPOSE OF COLLECTING INFORMATION – PAAC’s primary objectives are to promote the advancement of the public affairs field and facilitate the professional betterment of those working within it. A key means to those ends is fostering interaction and networking among public affairs professionals. Business Information is collected from PAAC members to facilitate their interaction, as well as from non-members who participate in PAAC events. The Business Information collected respecting members is recorded in the password-protected, searchable membership database on the PAAC web-site (www.publicaffairs.ca), which members are actively encouraged to use for networking purposes.
From time to time, individuals who provided consent (express, assumed, or implied – see “Consent to Collection of Information” below) to receive CEMs will receive notices of PAAC activities or events, or about events held by other organizations operating in the public affairs field (e.g., advising that PAAC has negotiated discounted registration fees for another organization’s conference or similar event). Such notices are invariably transmitted by PAAC itself. Moreover, it is PAAC policy not to accept and distribute commercial solicitations on behalf of third parties – though members are themselves free to use their access to the membership database to promote their own services to fellow members.
PAAC will not be responsible for any CEMs sent by individuals to any other individual on PAAC’s database. Similarly, PAAC may, from time to time, provide links on the PAAC website to third parties for informational purposes. By doing so, PAAC is not promoting or endorsing the services or goods of such third party. PAAC is in no way responsible for the anti-spam practices of third parties or their websites.
CONSENT TO COLLECTION OF INFORMATION – PAAC will only use your Business Information to send you CEMs if PAAC has obtained express, assumed, or implied consent from you to send you CEMs.
Standard wording consenting to PAAC’s collection and use of information to facilitate networking is used on the membership application form, event and conference registration forms, and records compiled in connection with other ongoing or occasional PAAC activities. This wording consents to the distribution of lists of conference or event registrants, including names and organizational affiliations of both members and non-members. To foster networking, registration lists are supplied as a courtesy to event presenters and provided upon request to any member.
Consent to receive CEMs can be withdrawn at any time (see “Opt-Out Procedure” below).
The following are situations where you are assumed to have given express consent to PAAC to send you CEMS:
- you are a PAAC employee;
- you are an employee of an organization that has a relationship with PAAC; or
- you are a director or officer of PAAC.
CASL does not apply in these situations; therefore, you cannot opt-out of receiving CEMs from PAAC.
The following are situations where you are deemed to have given implied consent to PAAC to send you CEMs:
- you have volunteered with PAAC in the past 2 years;
- you are currently, or have been in the past 2 years, a member of PAAC;
- you are currently, or have been in the past 2 years, a client of PAAC or have attended an event offered by PAAC;
- you have conspicuously published your business contact information, without stating “No CEMs”, and PAAC’s CEM relates to your business function;
- you gave your e-mail address to PAAC, without stating “No CEMs”, and PAAC’s CEM relates to your business function;
- you have requested information from PAAC about its services in the past 6 months; or
- your name has been referred to PAAC by someone that has a business or non-business relationship with you and with PAAC.
If PAAC sends you a CEM, and your consent was implied, the CEM will identify PAAC and will explain how to unsubscribe from receiving CEMs (see “Opt-Out Procedure” below). The contact information of PAAC given in the CEM must be valid for at least 60 days after the CEM is sent.
OPT-OUT PROCEDURE – At any point in time, ir you had given express consent to receive CEMs from PAAC, or your consent was implied, you may opt out from receiving CEMs from PAAC by:
- Clicking the link at the bottom of PAAC’s website that indicates “opt-out” or “unsubscribe; or
- Sending an email to PAAC’s Privacy Officer with the e-mail address or phone number from where you received communication from PAAC and specifying that you would like to be removed from any PAAC CEM list. You will be removed from the appropriate contact list within 10 business days of receipt of your request.
PRIVACY OFFICER – The Privacy Officer responsible for overseeing the implementation of PAAC’s privacy and anti-spam policy is Stephen Andrews, Borden Ladner Gervais, 416-367-6219, sandrews [at] blg.com. Information held by PAAC is safeguarded by standard office security measures, computer system virus protection, computer passwords, locked file cabinets, confidentiality requirements signed by all staff and other measures. The Privacy Officer is responsible for training and supervising staff to ensure compliance with PAAC’s privacy and anti-spam policy as well as for conducting periodic privacy and anti-spam audits. The Privacy Officer will conduct a privacy and anti-spam impact assessment of any new information system or of any significant change in existing information systems.
INQUIRIES AND COMPLAINTS – PAAC has established a procedure to receive and respond to inquiries and complaints respecting PAAC’s handling of information about members and other persons. Complaints of inaccuracy, which are solicited in writing, will be investigated promptly and action will be taken to correct any breaches of CASL. If the complainant is not satisfied by the action taken, the complaint will be referred for consideration to the PAAC board of directors.