Loyalty programme communications not CASL-compliant
Canadian Anti-Spam Legislation requires express consent for commercial electronic messages. A loyalty programme sign-up that automatically enrolls the member in marketing email communications without a separate, explicit consent opt-in is not CASL-compliant. CASL implied consent — which may apply to a transactional email following a purchase — does not cover ongoing loyalty programme promotional communications. A CASL audit of the loyalty programme sign-up flow, list management configuration, and consent records is the first step before any loyalty communication expansion.