DO NOT CALL LIST PRESENTATION AT MANAGING PRIVACY COMPLIANCE!!

Managing Privacy Managing Privacy Compliance Compliance

Federated PressFederated Press

April 23 & 23, 2008April 23 & 23, 2008

TheThe DO NOT CALL LISTDO NOT CALL LIST

George C. EyreGeorge C. EyreB. Math, M. Eng., L.L.B.B. Math, M. Eng., L.L.B.

WWW.LAW4IT.COMWWW.LAW4IT.COM

Introduction – Legal FrameworkIntroduction – Legal Framework

Bill C-37, An Act to amend the Bill C-37, An Act to amend the Telecommunications Act, S.C. 2005, c.50Telecommunications Act, S.C. 2005, c.50

Establish Operate & Enforce National Establish Operate & Enforce National DNCL – 3DNCL – 3rdrd party delegation party delegation

CRTC can impose Administrative CRTC can impose Administrative Monetary Penalties i.e. finesMonetary Penalties i.e. fines

CRTC Telecom Decisions CRTC 2008‑6 CRTC Telecom Decisions CRTC 2008‑6 2007-48 2007‑47, CRTC 2004‑352007-48 2007‑47, CRTC 2004‑35

September 30, 2008 September 30, 2008

CRTC Unsolicited CRTC Unsolicited Telecommunications Rules Telecommunications Rules

Consist of: [ Consist of: [ CRTC 2008‑6 ] CRTC 2008‑6 ] I DefinitionsI Definitions II National Do Not Call Rules [exemptions]II National Do Not Call Rules [exemptions] III Telemarketing Rules apply to DNCL III Telemarketing Rules apply to DNCL

exemptions [exemptions ]exemptions [exemptions ] IV ADAD RulesIV ADAD Rules V Express ConsentV Express Consent VI Record KeepingVI Record Keeping VII Liability - DefencesVII Liability - Defences

IntroductionIntroduction

Core Rule: Telemarketers may not call Core Rule: Telemarketers may not call numbers on National DNCL without numbers on National DNCL without express consent: Consumers to Registerexpress consent: Consumers to Register

Exemptions: Exemptions: Registered Charities Political PartiesRegistered Charities Political Parties Surveys / Polls General Circulation NewsSurveys / Polls General Circulation News B2BB2B Existing Business RelationshipsExisting Business Relationships

Introduction ( Cont’d)Introduction ( Cont’d)

Telemarketer Registration & RulesTelemarketer Registration & Rules Fax RulesFax Rules Complaints Complaints Administrative Monetary PenaltiesAdministrative Monetary Penalties DefencesDefences CMA Do Not Contact & iOptout.ca etc.CMA Do Not Contact & iOptout.ca etc. Implementation & ConclusionsImplementation & Conclusions Q & AQ & A

Consumers to RegisterConsumers to Register

Consumers register individual home, Consumers register individual home, wireless and fax numbers for free wireless and fax numbers for free through a toll free number or online through a toll free number or online

Effective for a three year period, after Effective for a three year period, after which the number will automatically be which the number will automatically be de-registered (consumer's de-registered (consumer's responsibility to re‑register)responsibility to re‑register)

No Costs to ConsumersNo Costs to Consumers Telemarketers to pay Telemarketers to pay

U.S. DNCLU.S. DNCL

Telephone numbers placed on the U.S. Telephone numbers placed on the U.S. National Do Not Call Registry will remain National Do Not Call Registry will remain on it permanently due to the Do-Not-Call on it permanently due to the Do-Not-Call Improvement Act of 2007, which became Improvement Act of 2007, which became law in February 2008. More than 157 law in February 2008. More than 157 million phone numbers are on the million phone numbers are on the National Do Not Call Registry.National Do Not Call Registry.

FTC Removes telephone numbers that FTC Removes telephone numbers that have been disconnected and reassigned have been disconnected and reassigned to other customers. to other customers.

Exemptions from National Exemptions from National DNCL Rules DNCL Rules

by or on behalf of registered by or on behalf of registered charities; charities;

by or on behalf of political parties; by or on behalf of political parties; to collect information for a survey; to collect information for a survey; to solicit a subscription for a to solicit a subscription for a

"newspaper of general circulation; " "newspaper of general circulation; "

Exemptions ( cont’d)Exemptions ( cont’d)

to a consumer that has an existing to a consumer that has an existing business relationship with the business relationship with the telemarketer (provided that consent telemarketer (provided that consent has not been withdrawn to be so has not been withdrawn to be so contacted). contacted).

B2B calls are exempt except if business B2B calls are exempt except if business person has asked to be put on individual person has asked to be put on individual do not call listdo not call list

Exemptions Exemptions

apply not to the entities themselves but to apply not to the entities themselves but to the telecommunications - hence all entities the telecommunications - hence all entities are subject to compliance with other are subject to compliance with other aspects of the Unsolicited aspects of the Unsolicited Telecommunications Rules (i.e. Telecommunications Rules (i.e. Telemarketing Rules, the Automatic Telemarketing Rules, the Automatic Dialing‑Announcing Devices (ADADs) Rules, Dialing‑Announcing Devices (ADADs) Rules, and the obligation to remove complaining and the obligation to remove complaining consumers from a telemarketer's own do consumers from a telemarketer's own do not call list, etc.). Telecom Decision CRTC not call list, etc.). Telecom Decision CRTC 2008‑6. 2008‑6.

““existing business relationship” existing business relationship” meansmeans

a business relationship that has been a business relationship that has been formed by a voluntary two‑way formed by a voluntary two‑way communication between , arising from communication between , arising from

(a) purchase, lease or rental of products, (a) purchase, lease or rental of products, services within the 18 month period ; services within the 18 month period ;

(b) an inquiry or application, within the 6 (b) an inquiry or application, within the 6 month period immediately preceding or month period immediately preceding or

(c) any other written contract (c) any other written contract not included affiliate different legal entity not included affiliate different legal entity

"Newspaper of General "Newspaper of General Circulation"Circulation"

means a printed publication in sheet form means a printed publication in sheet form that is intended for general circulation, that is intended for general circulation, published regularly at intervals of not published regularly at intervals of not longer than seven days, consisting in longer than seven days, consisting in great part of news of current events of great part of news of current events of general and local interest, and is sold to general and local interest, and is sold to the public and to subscribers.the public and to subscribers.

Only exemption is for calls for Only exemption is for calls for subscriptionssubscriptions

Bell Canada DNCL OperatorBell Canada DNCL Operator

National DNCL Operator - Bell National DNCL Operator - Bell Canada - five year Canada - five year

Operator - responsible for registering Operator - responsible for registering numbers, providing telemarketers numbers, providing telemarketers with up‑to‑date versions of the DNCL with up‑to‑date versions of the DNCL and receiving consumer complaints. and receiving consumer complaints.

Funded by Subscription fees from Funded by Subscription fees from telemarketerstelemarketers

Each Telemarketer Must Each Telemarketer Must RegisterRegister

Each Telemarketer Must Register Each Telemarketer Must Register before making telemarketing calls on before making telemarketing calls on its own; ensure Client registers before its own; ensure Client registers before calling on its behalf (2,3)calling on its behalf (2,3)

Register even if only doing exempt calls Register even if only doing exempt calls Fees & Investigation ProcessFees & Investigation Process Subscribers to the National DNCL may Subscribers to the National DNCL may

not use it for purposes other than those not use it for purposes other than those set out in the rulesset out in the rules

Telemarketing RulesTelemarketing RulesExemptionsExemptions

Do not apply in respect of an Do not apply in respect of an unsolicited telecommunication made unsolicited telecommunication made for purposes other than solicitation for purposes other than solicitation including those made solely for including those made solely for emergencies, account collection, emergencies, account collection, surveys for members of the public surveys for members of the public and market researchand market research

Telemarketing Calls - HoursTelemarketing Calls - Hours

Telemarketing is restricted to the Telemarketing is restricted to the hours of 9:00 a.m. to 9:30 p.m. on hours of 9:00 a.m. to 9:30 p.m. on weekdays, 10:00 a.m. to 6:00 p.m. weekdays, 10:00 a.m. to 6:00 p.m. on weekends, in the time zone of the on weekends, in the time zone of the recipientrecipient

statutory holidays – same hoursstatutory holidays – same hours

Telemarketing Calls (cont’d)Telemarketing Calls (cont’d)

At the beginning of a call a At the beginning of a call a telemarketer telemarketer

Must identify the name or fictitious Must identify the name or fictitious name of the individual placing the name of the individual placing the call. call.

Must identify the name of the Must identify the name of the telemarketer whether calling on its telemarketer whether calling on its own behalf or on behalf of a client of own behalf or on behalf of a client of the telemarketer. the telemarketer.


Upon request a telemarketer must Upon request a telemarketer must provide a local or toll‑free number provide a local or toll‑free number

allowing the customer access to speak to allowing the customer access to speak to an employee or other representative of an employee or other representative of the telemarketer and where applicable, the telemarketer and where applicable, its client; its client;

provide the name and address of an provide the name and address of an employee or other representative of the employee or other representative of the telemarketer and where applicable, its telemarketer and where applicable, its client, to whom the consumer can write. client, to whom the consumer can write.


For any telephone numbers provided For any telephone numbers provided to a consumer: to a consumer:

The telephone call shall be answered The telephone call shall be answered either by a live operator or a either by a live operator or a voicemail system to take messages voicemail system to take messages for the consumer. The voicemail for the consumer. The voicemail must inform consumers that their call must inform consumers that their call will be returned within three (3) will be returned within three (3) business days. business days.


The telemarketer or the client of the The telemarketer or the client of the telemarketer must return consumer's call telemarketer must return consumer's call within three (3) business days. within three (3) business days.

Telemarketers must display the Telemarketers must display the originating calling number or an alternate originating calling number or an alternate number where the call originator can be number where the call originator can be reached (except where the number reached (except where the number display is unavailable for technical display is unavailable for technical reasons). reasons).

Sequential dialing is prohibited. Sequential dialing is prohibited.


Random dialing and calls to non‑published Random dialing and calls to non‑published numbers are permitted, except to numbers are permitted, except to numbers registered on the National DNCL; numbers registered on the National DNCL; emergency lines; and healthcare facilities. emergency lines; and healthcare facilities.

DNCLs are to be maintained by the DNCLs are to be maintained by the telemarketer on its own behalf or on telemarketer on its own behalf or on behalf of a client of a telemarketer and behalf of a client of a telemarketer and remain active for 3 yrs 31 days effective remain active for 3 yrs 31 days effective within 31 days from the date of the within 31 days from the date of the consumer's do not call request. consumer's do not call request.


A consumer's request not to be A consumer's request not to be called must be made during the called must be made during the telemarketing call and not be asked telemarketing call and not be asked to call elsewhere to call elsewhere

ADAD RulesADAD Rules

Automatic Dialing and Announcing Devices Automatic Dialing and Announcing Devices (ADADs are equipment that store and dial (ADADs are equipment that store and dial telephone numbers automatically. telephone numbers automatically.

ADADs used for the purpose of ADADs used for the purpose of solicitation are prohibited which includes solicitation are prohibited which includes telemarketing for a charity, to request a telemarketing for a charity, to request a consumer to hold until a telemarketer is consumer to hold until a telemarketer is availableavailable

ADAD Rules ( cont’d ) ADAD Rules ( cont’d )

ADADs are permitted when no ADADs are permitted when no solicitation & for public service solicitation & for public service reasons, including reasons, including telecommunications made for telecommunications made for emergency and administration emergency and administration purposes by police and fire purposes by police and fire departments, schools, hospitals, or departments, schools, hospitals, or for calls to schedule appointments.for calls to schedule appointments.

ADAD Rules ( cont’d ) ADAD Rules ( cont’d )

Additional ADAD Rules Include:Additional ADAD Rules Include: Calling hours, identifying message, Calling hours, identifying message,

display number,display number, Sequential dialing is Sequential dialing is prohibited, Random dialing can be used prohibited, Random dialing can be used to non‑published telecommunications to non‑published telecommunications numbers, except to emergency lines numbers, except to emergency lines and healthcare facilities. and healthcare facilities.

ADAD equipment disconnects within 10 ADAD equipment disconnects within 10 seconds of person receiving hanging up seconds of person receiving hanging up

Abandonment rateAbandonment rate

The permissible abandonment rate for The permissible abandonment rate for telemarketers using a predictive dialing telemarketers using a predictive dialing device (i.e. a dialing device which uses a device (i.e. a dialing device which uses a pre‑determined list of numbers) will be fixed pre‑determined list of numbers) will be fixed at 5% per calendar month; telemarketers at 5% per calendar month; telemarketers must maintain records "permissible must maintain records "permissible abandonment rate" refers to "dead air" calls abandonment rate" refers to "dead air" calls that are abandoned when a PPD reaches a that are abandoned when a PPD reaches a consumer but there is no "live agent" consumer but there is no "live agent" available to handle the call at the available to handle the call at the telemarketer's end. telemarketer's end.

Fax Restrictions - HoursFax Restrictions - Hours

Fax telemarketing calls are restricted Fax telemarketing calls are restricted to weekdays (Monday to Friday) to weekdays (Monday to Friday) between 9:00 AM and 9:30 PM and between 9:00 AM and 9:30 PM and weekends (Saturday and Sunday) weekends (Saturday and Sunday) between 10:00 AM and 6:00 PM. between 10:00 AM and 6:00 PM. (the time zone of the customer (the time zone of the customer receiving the fax telemarketing receiving the fax telemarketing calls )calls )

Fax Restrictions ( Cont’d)Fax Restrictions ( Cont’d)

Certain information required on top of Certain information required on top of first page font 12 or larger: first page font 12 or larger:

The name of the telemarketer whether The name of the telemarketer whether it is sending the fax on its own behalf or it is sending the fax on its own behalf or on behalf of a client of the telemarketer. on behalf of a client of the telemarketer.

The name of the telemarketer's client The name of the telemarketer's client where applicable. where applicable.

The originating date and time of the fax. The originating date and time of the fax.


A local or toll‑free number voice and A local or toll‑free number voice and fax number allowing the customer fax number allowing the customer access to an employee or other access to an employee or other representative of the telemarketer, representative of the telemarketer, and where applicable, the client of and where applicable, the client of the telemarketer, for the purpose of the telemarketer, for the purpose of asking questions or making a do not asking questions or making a do not call request. call request.


The name and address of an employee or The name and address of an employee or other representative of the telemarketer, other representative of the telemarketer, or client where applicable, to whom the or client where applicable, to whom the consumer can write. consumer can write.

For any telephone numbers provided to For any telephone numbers provided to the consumer to call the consumer to call

The telephone call shall be answered The telephone call shall be answered either by a live operator or a voicemail either by a live operator or a voicemail system to take messages for the system to take messages for the consumer. consumer.


The voicemail must inform The voicemail must inform consumers that their call will be consumers that their call will be returned within three (3) business returned within three (3) business days. days.

The telemarketer or the client of the The telemarketer or the client of the telemarketer must return consumer's telemarketer must return consumer's call within three (3) business days. call within three (3) business days.


The fax telemarketing call must display The fax telemarketing call must display the originating calling number or an the originating calling number or an alternate number where the call alternate number where the call originator can be reached (except where originator can be reached (except where the number display is unavailable for the number display is unavailable for technical reasons). technical reasons).

Sequential dialing is prohibited. Sequential dialing is prohibited. Fax telemarketing calls are not permitted Fax telemarketing calls are not permitted

to any emergency line or healthcare to any emergency line or healthcare facility. facility.


DNCLs are to be maintained by the DNCLs are to be maintained by the telemarketer on its own behalf or on telemarketer on its own behalf or on behalf of a client of a telemarketer behalf of a client of a telemarketer and remain active for three (3) years and remain active for three (3) years 31 days effective within thirty‑one 31 days effective within thirty‑one (31) days from the date of the (31) days from the date of the consumer's do not call request. consumer's do not call request.

Part VI Records of Compliance:Part VI Records of Compliance:

Telemarketers need to maintain records Telemarketers need to maintain records of compliance, in any form, as they of compliance, in any form, as they maintain other ordinary course of maintain other ordinary course of business records, in regular place of business records, in regular place of businessbusiness

Telemarketers must provide such records Telemarketers must provide such records to the CRTC within 30 days of a request to the CRTC within 30 days of a request

In the event of a termination or sale, In the event of a termination or sale, records must be maintained by principal records must be maintained by principal or successoror successor

ComplaintsComplaints

Consumers who receive unsolicited Consumers who receive unsolicited telemarketing in violation of the rules telemarketing in violation of the rules must complain within 14 days of a callmust complain within 14 days of a call

Complaints may be made to the National Complaints may be made to the National DNCL operator DNCL operator

List Operator makes preliminary List Operator makes preliminary determination of whether violation determination of whether violation occurredoccurred

All complaints forwarded to 3All complaints forwarded to 3rdrd party party Complaints Investigator Complaints Investigator

PenaltiesPenalties

If the investigation determines that If the investigation determines that there has been a violation, CRTC will there has been a violation, CRTC will issue an enforcement Notification issue an enforcement Notification

administrative monetary penalties administrative monetary penalties (AMPs) of up to $15,000 on corporate (AMPs) of up to $15,000 on corporate violators, or up to $1,500 in the case violators, or up to $1,500 in the case of an individual.of an individual.

Penalties ( cont’d )Penalties ( cont’d )

Whether it decides to impose an AMP, and Whether it decides to impose an AMP, and the amount of the penalty, will be the amount of the penalty, will be determined in each case in light of the determined in each case in light of the following factors: (i) the nature of the following factors: (i) the nature of the violations, (ii) the number and frequency violations, (ii) the number and frequency of complaints and violations, (iii) the of complaints and violations, (iii) the relative disincentive of the measure and relative disincentive of the measure and (iv) the potential for future violations(iv) the potential for future violations

Both telemarketer & Client could be liableBoth telemarketer & Client could be liable

CRTC may make public details of violatorsCRTC may make public details of violators

DefencesDefences

The defences to breach of the National The defences to breach of the National DNCL Rules include express consent, the DNCL Rules include express consent, the due diligence defence applicable to the due diligence defence applicable to the Unsolicited Telecommunications Rules Unsolicited Telecommunications Rules generally, the exemptions and a prior generally, the exemptions and a prior business or personal relationship, business or personal relationship, Common law defences such as Common law defences such as res res judicata,judicata, mistake of fact, officially mistake of fact, officially induced error, abuse of process, induced error, abuse of process, entrapment, and de minimis.entrapment, and de minimis.

Express ConsentExpress Consent

In cases where a defendant intends to rely In cases where a defendant intends to rely on the express consent of a call recipient, on the express consent of a call recipient, the burden is on the Telemarketerthe burden is on the Telemarketer

Unsolicited Telecommunications Rules: Part Unsolicited Telecommunications Rules: Part V – Express ConsentV – Express Consent

the forms of consent for collection, use, and the forms of consent for collection, use, and disclosure of personal information described disclosure of personal information described in Schedule 1 (Section 5), Clause 4.3 of the in Schedule 1 (Section 5), Clause 4.3 of the PIPEDA Act are sufficient.PIPEDA Act are sufficient.

Part V – Express ConsentPart V – Express Consent

Express consent may be taken to be given by Express consent may be taken to be given by a customer where the customer provides:a customer where the customer provides:

written consent including signed application written consent including signed application form; form;

oral confirmation verified by an independent oral confirmation verified by an independent third party or where an audio recording of third party or where an audio recording of the consent is retained by the carrierthe consent is retained by the carrier

electronic confirmation through the use of a electronic confirmation through the use of a toll-free number;toll-free number;

Part V – Express ConsentPart V – Express Consent

electronic confirmation via the Internet;electronic confirmation via the Internet;

oror

consent through other methods, as long consent through other methods, as long as an documented record of customer as an documented record of customer consent is created by the customer or by consent is created by the customer or by an independent third party.an independent third party.

PIPEDA CASESPIPEDA CASES

the forms of consent for Clause 4.3 the forms of consent for Clause 4.3 of Schedule 1 of PIPEDA are of Schedule 1 of PIPEDA are sufficientsufficient

Hence provides guidance to the Hence provides guidance to the forms that can be usedforms that can be used

Will the decisions be consistent Will the decisions be consistent under the CRTC?under the CRTC?

Express Consent CASE 250Express Consent CASE 250

PIPEDAPIPEDA Case Summary #250 Case Summary #250 Customer objects to bank's consent Customer objects to bank's consent

practices "opt-out” consentpractices "opt-out” consent 8 weeks for opt-out to take effect8 weeks for opt-out to take effect 4.3.5 consider reasonable expectations4.3.5 consider reasonable expectations 4.3.7 allows use of opt-out consent4.3.7 allows use of opt-out consent Opt-out allowed strictly defined Opt-out allowed strictly defined

situationssituations Not sensitive informationNot sensitive information

Express Consent # 207Express Consent # 207

Cell phone company "opt-out" consent : Cell phone company "opt-out" consent : Called exemplaryCalled exemplary

DB privacy function suppression options i.e. DB privacy function suppression options i.e. "No direct mail", "No e-mail", "No "No direct mail", "No e-mail", "No telemarketing", "No market research“telemarketing", "No market research“

non-sensitive informationnon-sensitive information privacy brochure privacy brochure procedure new customer's attention once procedure new customer's attention once

again during the activation process.again during the activation process.

Due Diligence Defence Due Diligence Defence CRTC CriteriaCRTC Criteria

the telecommunication resulted from an the telecommunication resulted from an error and that as part of its routine error and that as part of its routine business practices it follows the rules:business practices it follows the rules:

1 established and implemented adequate 1 established and implemented adequate written policies and procedures to complywritten policies and procedures to comply

2 adequate on-going training to all 2 adequate on-going training to all 3 uses the National DNCL obtained from 3 uses the National DNCL obtained from

the National DNCL operator no more than the National DNCL operator no more than thirty-one (31) days prior thirty-one (31) days prior

Due Diligence ( cont`d)Due Diligence ( cont`d)

4 uses the telemarketer's and client DNCL 4 uses the telemarketer's and client DNCL updated within 31 days prior to the date updated within 31 days prior to the date

5 uses and maintains records documenting 5 uses and maintains records documenting a process to prevent a call on a DNCLa process to prevent a call on a DNCL

6 the person monitors and enforces 6 the person monitors and enforces compliancecompliance

7 enter into an agreement between itself 7 enter into an agreement between itself and the telemarketer requiring that the and the telemarketer requiring that the latter comply with the Unsolicited latter comply with the Unsolicited Telecommunications Rules.Telecommunications Rules.

Selection of the Telemarketing Selection of the Telemarketing Complaints InvestigatorComplaints Investigator

Announcement Pending by the CRTCAnnouncement Pending by the CRTC as to who will be the as to who will be the Complaints Complaints InvestigatorInvestigator

Pursuant to its February 15, 2008 Pursuant to its February 15, 2008 news release, the request for news release, the request for proposal was open until March 25, proposal was open until March 25, 2008 2008

Complaints Investigator Complaints Investigator ChargesCharges

The Complaints Investigator will be The Complaints Investigator will be entitled to charge telemarketers in entitled to charge telemarketers in relation to the investigation service, relation to the investigation service, which is expected to be levied at the which is expected to be levied at the time of registration time of registration

The National DNCL Rules are expected The National DNCL Rules are expected to come into effect on September 30, to come into effect on September 30, 2008, and the rules regarding the 2008, and the rules regarding the Complaints Investigator once it is Complaints Investigator once it is operational. operational.

CMA Do Not ContactCMA Do Not Contact

The Canadian Marketing Association offers The Canadian Marketing Association offers a free "Do Not Contact Service“ which is a free "Do Not Contact Service“ which is limited to screening telemarketing from limited to screening telemarketing from CMA participating companies only. CMA participating companies only. Registration by mail, phone or Internet Registration by mail, phone or Internet www.the-cma.org. After registration, it www.the-cma.org. After registration, it takes six weeks to be effective and lasts takes six weeks to be effective and lasts for three years. CMA to phase out service for three years. CMA to phase out service except for opt-out of receiving mail offersexcept for opt-out of receiving mail offers

Clients must continue DNCLClients must continue DNCL

iOptOut.caiOptOut.ca

March 28, 2008 iOptOut.ca, a free service March 28, 2008 iOptOut.ca, a free service which notifies callers selected by the user which notifies callers selected by the user that the individual exercises his or her that the individual exercises his or her right under privacy laws not to receive right under privacy laws not to receive communications from the notified communications from the notified business. Intended to cover National business. Intended to cover National DNCL exclusions DNCL exclusions

CMA advised members may ignore these CMA advised members may ignore these requests because they are requests because they are without without authenticationauthentication

Time LineTime Line

September 30, 2008 Launch National September 30, 2008 Launch National DNCLDNCL

Delegation of Investigation FunctionDelegation of Investigation Function Communication Plan for Consumers Communication Plan for Consumers

& Telemarketers& Telemarketers Review in 3 YearsReview in 3 Years

SummarySummary

Core Rule: Telemarketers may not call Core Rule: Telemarketers may not call numbers on National DNCL without numbers on National DNCL without express consent: Consumers to Registerexpress consent: Consumers to Register

ExemptionsExemptions Telemarketer Registration & RulesTelemarketer Registration & Rules Fax RulesFax Rules Complaints & Penalties ( AMP )Complaints & Penalties ( AMP ) DefencesDefences CMA & iOptout.ca etcCMA & iOptout.ca etc

Disclaimer:Disclaimer:

Thank you and please be advised Thank you and please be advised that this information is provided as that this information is provided as general information only and should general information only and should not be considered legal advice. You not be considered legal advice. You are advised to consult with a lawyer are advised to consult with a lawyer to consider your situation.to consider your situation.

George C Eyre, Law OfficesGeorge C Eyre, Law Offices

George C. EyreGeorge C. Eyre

……has extensive experience in computer science, has extensive experience in computer science, project management and systems, and therefore project management and systems, and therefore understands your businessunderstands your business

LAW4IT.COMLAW4IT.COM……applies this experience to assist you in meeting applies this experience to assist you in meeting

your goals and solving and preventing problemsyour goals and solving and preventing problems

LAW FOR INFORMATION TECHNOLOGY…LAW FOR INFORMATION TECHNOLOGY…

……registers and prosecutesregisters and prosecutesCanadian and AmericanCanadian and AmericanTrade MarksTrade Marks

……provides legal services in the majorprovides legal services in the majorareas ofareas of

Privacy, Computer & InternetPrivacy, Computer & InternetIntellectual PropertyIntellectual Property

Entertainment, Multimedia & Advertising Entertainment, Multimedia & Advertising Corporate, Commercial & Business LawCorporate, Commercial & Business Law

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DO NOT CALL LIST PRESENTATION AT MANAGING PRIVACY COMPLIANCE!!