I think from the efficiency standpoint, it has enabled marketers to look at their email community and take out any of the addresses that were unknown. As we were consulting with a lot of companies, we had to audit their database and inquire about where they got permission for all the records. For anybody they didn't have permission for or for whom they didn't know the source of the opt-in, we recommended that they take the conservative approach and just suppress.
What we found is that when CASL came into force, marketers and brands were forced to remove email addresses that were maybe not of good quality. In the email marketing space, some brands go for quantity over quality, and it forced marketers to drop their list sizes. Some list sizes went from a million records to 200,000 records, but those 200,000 records are now engaged, relevant people who want to be in the database. Now their email marketing programs are working a lot harder for them, so it's more efficient, because all of their practices are getting them a higher return on investment at this point.
It has been efficient in that way, and we agree that there have to be regulations on how we use email. There have to be restrictions on it. However, CASL has been way too onerous and costly for organizations, and it's too complex. A law like this shouldn't be that complex, and three years later we shouldn't have companies coming to us asking what the difference between “implied” and “express” is.