This document sets forth the policy of HRTech360Hub and is designed to provide reasonable assurance that (I) a consistent process is followed with respect to the dissemination of commercial electronic messages from HRTech360Hub to prospective clients in Canada, and (ii) HRTech360Hub is sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.
The HRTech360Hub Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all HRTech360Hub personnel sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of HRTech360Hub, or using a HRTech360Hub email address or using a device owned or provided by HRTech360Hub, comply with CASL.
The Anti-Spam Policy describes HRTech360Hub commitments relating to the provisions of CASL and electronic messages of a commercial nature sent from HRTech360Hub to prospective clients and others, as applicable. From time to time, HRTech360Hub may implement additional policies, procedures, and/or practices as it relates to anti-spam measures.
This Policy applies to HRTech360Hub personnel who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada.
With respect to HRTech360Hub operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and HRTech360Hub is committed to complying with CASL. All other Tech World Solutions policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.
HRTech360Hub obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with HRTech360Hub within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, HRTech360Hub also obtains express, opt-in consent for the sending of CEMs to HRTech360Hub prospects.
The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. A verbal consent is acceptable where a record of the details of the consent is maintained in a database.
All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:
HRTech360Hub takes steps to require that any third-party service provider who sends CEMs on behalf of HRTech360Hub complies with CASL.
A key component of complying with CASL involves maintaining records of HRTech360Hub relationships with clients and prospective clients.
Each business unit of HRTech360Hub is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from HRTech360Hub and prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with HRTech360Hub at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with HRTech360Hub are not considered clients for purposes of this Policy.
Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.
Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after HRTech360Hub ceases sending CEMs to the client or prospect.
All personnel at HRTech360Hub sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.
A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images, or attachments) that:
Examples include promotional event invitations (e.g., webcasts or HRTech360Hub events), marketing newsletters, etc.
The following messages do not have to comply with the requirements applicable to CEMs:
Messages that HRTech360Hub email each other internally using a device that HRTech360Hub owns or provides, or using a HRTech360Hub email address, should be related to HRTech360Hub business. HRTech360Hub may not internally email each other offers, promotions, advertisements, or referrals unrelated to HRTech360Hub business without the internal recipient’s verbal consent.
All third-party contracts with service providers who may send CEMs on behalf of HRTech360Hub must contain contractual clauses obligating the service provider to comply with CASL, including the form and content requirements of CEMs.
CEMs that are not exempt from the requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow HRTech360Hub to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent, or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.
All emails sent by HRTech360Hub employees will be compliant with CASL and will include the option to ‘unsubscribe.’
You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting .com/unsubscribe">https://HRTech360Hub.com/unsubscribe or by emailing .com">info@HRTech360Hub.com with ‘Unsubscribe’ in the subject line.
The Anti-Spam Policy is maintained by the Compliance department of HRTech360Hub and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require the approval of the respective HRTech360Hub Board or equivalent.
HRTech360Hub Compliance is responsible for the review and revision of this Policy, subject to approval of the respective HRTech360Hub Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.
Compliance with this Policy, and any related procedure, may be reviewed by HRTech360Hub at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with the applicable Global Human Resources Disciplinary policy or procedure.