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Industry committee Of course, if we could have the privilege to have you as a customer, the purpose we aim for with the emails we want to send.... Obviously some are commercial, obviously some may be useful to alert you to fraud, to transactions that are being done in your account, if they're more
October 5th, 2017Committee meeting
Natalie Brown
Industry committee Under the current regulation, that can still be sent because technically the bank has your implied consent. So those emails you're talking about are permitted today.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee I think the objectives of the law are exactly those that you mentioned, and with good clear definitions, that could still be attained.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee First, on the issue of the cost of compliance, we will have to forward you that information at a later date. We never bothered to establish a grand total. Furthermore, having chaired the Desjardins Group's anti-spam committee, as Aïsha is doing now, I can tell you that we are ta
October 5th, 2017Committee meeting
Natalie Brown
Industry committee Of course.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee I would add that we should keep in mind that the general rules of statutory interpretation call for a restrictive interpretation of these exemptions. In other words, despite the provided exemptions, we often end up having to stick to a restrictive interpretation, even when the in
October 5th, 2017Committee meeting
Natalie Brown
Industry committee I can speak only for our business, and seniors are a large part of our business in Quebec. Don't forget that we're under a tremendous amount of regulation. Our regulatory authority is the AMF, which checks for sound practices. We're under the Consumer Protection Act. There are
October 5th, 2017Committee meeting
Natalie Brown
Industry committee How could we narrow the—
October 5th, 2017Committee meeting
Natalie Brown
Industry committee Absolutely, narrow the scope. There's an exemption in the law, which is a partial exemption that allows us to send without consent but requires us to have “unsubscribe”. All of those definitions should not fall under the definition of CEM.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee Beat 'em up.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee The CRTC is sufficient.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee We're relying, in part, on technical solutions. The problem is that they're extremely expensive and, given all the different levels of exceptions and delays, they are almost impossible to manage. I would like to address your point on disproportionality very quickly. I've had to
October 5th, 2017Committee meeting
Natalie Brown
Industry committee If you want to come to Desjardins, we have that service.
October 5th, 2017Committee meeting
Natalie Brown
Industry committee I would like to add to that. An email that facilitates, completes, or confirms a commercial transaction is deemed to be a CEM. I can give you two examples of emails that are sent in the context of sound business practices and that would fall under that definition. We are an issu
October 5th, 2017Committee meeting
Natalie Brown