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#1159292 - 04/07/09 08:00 PM Email Advertising
ComplyWithMeToo Offline
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Joined: Feb 2007
Posts: 225
We offer our clients online banking. Within that product each client has a secure message (email) tab.

We would like to put a purely advertising message on the email to this client. Do we have to give them the opt out disclosures required by CamSpam?

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eBanking / Technology
#1159320 - 04/07/09 08:14 PM Re: Email Advertising ComplyWithMeToo
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
In my opinion, yes.
_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions

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#1159473 - 04/07/09 10:30 PM Re: Email Advertising RVFlyboy
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
This one is tricky, but the answer is clearly "no." Closed-system messages slide off the C-S hook in the definitions.

Only "COMMERCIAL ELECTRONIC MAIL MESSAGE"s are subject to the rules. Per the definitions,
"The term ‘‘commercial electronic mail message’’ means any electronic mail message..."
"The term ‘‘electronic mail message’’ means a message sent to a unique electronic mail address."
The term ‘‘electronic mail address’’ means a destination, commonly expressed as a string of characters, consisting of a unique user name or mailbox (commonly referred to as the ‘‘local part’’) and a reference to an Internet domain (commonly referred to as the ‘‘domain part’’), whether or not displayed, to which an electronic mail message can be sent or delivered."

So, emails to "somebody@somedomain.com" would be covered and messages handled within a closed proprietary system would not.
_________________________
...gone fishing.

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#1159601 - 04/08/09 12:57 PM Re: Email Advertising Richard Insley
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
Richard, as usual, is correct. I misread the original post and didn't pick up that the message was not a true "e-mail", but rather a closed system message.

That said, I would still consider whether there is a benefit to offering customers the ability to opt out of such messages. Do you really want customers ticked off at you because they don't want to get marketing mail in their e-banking system but have no way to get rid of it?
_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions

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#1159618 - 04/08/09 01:14 PM Re: Email Advertising RVFlyboy
Richard Insley Online
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Wise advice, Jim.
_________________________
...gone fishing.

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