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Industry committee  If I could add quickly—

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  The definition of “charity” and “not-for-profit” is not the same under CASL as it is under the Income Tax Act, so one opportunity, and it's in our submission, is to sort of make them the same. That may eliminate some of the confusion. The fact that we're here, and we can't even a

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  It's how one interprets the exceptions. To the extent that the charity is not engaging in a commercial electronic activity, that part of the business is exempt, but then every once in a while they're going to creep into soliciting money. They're going to creep into things, and wi

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  As Commissioner Therrien explained, there is no doubt they have a very narrow and small piece of CASL that they implement, so obviously any sort of outreach they can do to clarify so that there is no inadvertent.... Being offside of those provisions would be helpful, but if we sl

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  To your question, if the $40,000 that the Canadian Marketing Association...which would be a trade association really trying to do the right thing, you can't just really wing it, because if you do, then you're subject to potentially being found to be not compliant. If the CRTC wer

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  Sure. Thanks for the question. From a large business perspective, you gather the resources and you do what you need to do to comply. As someone who has worked on implementing CASL internally at a few organizations, but also in working with external counsel and my colleagues in o

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  The very fact that you're asking those questions is really the first step. As Mr. Schwartzman explained, even when CASL was being debated before committee, back when it was introduced, definitely one of the comments about it made by the business and legal profession was that it w

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  I'm going to focus on a few main points, many of which have been echoed by others who have appeared before you. The CBA sections believe that CASL must strike a balance between protecting consumers from damaging and deceptive electronic communications while at the same time all

October 24th, 2017Committee meeting

Suzanne Morin

Industry committee  Thank you very much, Mr. Chair. Good afternoon, honourable members of the committee. My name is Suzanne Morin, and I am chair of the CBA's national privacy and access law section, and I work for Sun Life. With me today, as you know, is Gillian Carter, who is a lawyer with the l

October 24th, 2017Committee meeting

Suzanne Morin