One Customer List in Three Different Places

Three lists, one business

The point-of-sale system holds the addresses customers gave for emailed receipts or loyalty points. The newsletter tool holds the people who signed up on the website. The manager's inbox holds years of special orders, questions and replies.

Sooner or later somebody suggests putting them together and sending one email to everybody. The newsletter tool's import screen makes it look like ten minutes' work.

It is not, because the three lists are not the same kind of list. Each address arrived with a different kind of permission, or none, and an import erases the difference.

What follows is general information about CASL, Canada's anti-spam law, not legal advice.

What each list actually holds

• The newsletter tool: express consent, usually with the date and form recorded.
• The till system: purchases, which give implied consent for two years.
• A loyalty sign-up box: express consent only if the customer ticked it.
• Enquiries by email: implied consent lasting six months from the enquiry.
• Special orders by email: purchases, so two years again.
• Unsubscribes, scattered across all three and binding on all three.

The last is the one an import most often breaks. Somebody who unsubscribed from the newsletter two years ago is still in the till system, and a careless import puts them straight back on the list.

Why the difference matters

Under CASL, the sender must be able to show consent for every commercial email. A merged list with no record of where each address came from is a list you can no longer defend.

Implied consent also runs out. A customer who bought once in 2015 can no longer be emailed on that basis, and a till export will not say so unless it includes the date of the last purchase.

And people notice. Somebody who gave an address for a receipt and starts getting weekly promotions feels the business took something it was not given, and the spam button is one tap away.

Export with the details

Start with three exports, each holding more than the address.

From the till system: name, email, the date of the most recent purchase, and any marketing checkbox it records, with the date it was ticked.

From the newsletter tool: subscribers and unsubscribes, with when and where each person signed up, which most tools record for their own forms.

From the inbox, by hand: the address, what the person asked or ordered, and the date. It is slow work, which is one more reason to stop the inbox growing into a list again.

Unsubscribes first

Before importing anything, gather every unsubscribe and every reply asking to be removed, from all three places, into one list.

Load that list into the newsletter tool first, marked as unsubscribed. Many tools will then refuse to add those addresses back through an import, which is exactly the protection wanted.

Watch for a second list inside the same tool. An unsubscribe from one list often does not carry to another, so a fresh list can email people who left the old one.

A worked example

A health food store in Penticton had three sources: a loyalty program in its till system, a newsletter list from a website form, and the manager's inbox, full of special orders and back-in-stock requests.

The owner wanted one monthly email to all of them, announcing new products and the month's in-store talk.

The till export showed the trouble. In the program's first year, cashiers had ticked the newsletter box themselves to keep the line moving, so those ticks were not consent.

Those customers could be emailed only on the strength of a purchase within the last two years. Dozens of addresses in the till system had also unsubscribed from the newsletter, and the inbox held enquiries going back three years.

The store loaded the unsubscribes first, then imported each source with tags for its origin, its consent type and the date. Express subscribers get the monthly email.

Recent customers on implied consent received one invitation to join, and only those who accepted were added. The till now asks two separate questions, one about receipts and one about the newsletter.

Keeping the consent with the address

Most newsletter tools let each subscriber carry extra fields or tags. Use them for three things: where the address came from, whether consent is express or implied, and the date it was given.

For implied consent, add the date it runs out. People whose implied consent ends next month are the ones to invite to subscribe, while you are still allowed to write to them.

Check the tool's own rules as well. Some require that every imported address asked to hear from you, which can be stricter than the law.

Duplicates and which record wins

The same customer often appears in all three lists, sometimes under two addresses: a work one in the inbox and a personal one at the till.

Where the same address appears twice, the most recent decision wins. An unsubscribe last month outweighs a purchase last year, and recorded express consent outweighs implied.

Two different addresses for one person stay two records. Do not merge them by guesswork; each keeps the consent it came with.

Stopping the lists drifting apart

A merge done once and then left alone produces three lists again within a year.

Connect the website form directly to the newsletter tool. Ask at the till, separately from the receipt question, and get those answers into the tool on a schedule, or automatically if the two systems connect.

When somebody in the inbox asks to hear about new products, reply with the sign-up link instead of adding them by hand. Their click is the record.

The counter-case

A business whose whole list came through one form with clear wording has nothing to merge, and should keep doing what it does.

Others will find the honest result disappointing: after sorting, the list they may email today is far smaller than the three lists combined. That is the right result, not a failure.

Where the records are a mess or a lot rides on the list, a lawyer familiar with CASL is worth paying. For most, the order holds: record the source, apply the unsubscribes, then import.

Before you import

1. Export all three sources with dates attached.
2. Gather every unsubscribe into one list.
3. Load the unsubscribes before anything else.
4. Tag each address with source and consent type.
5. Leave out enquiries older than six months.
6. Invite recent customers to subscribe, once.
7. Ask about the newsletter separately at the till.

Step three protects the people who already said no. Every other mistake on this list can be corrected later; an email to somebody who unsubscribed has already arrived by the time anyone notices.

The emails your staff send one at a time deserve care too, as covered in email signatures that break.

Frequently asked questions

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