Bulk Email Policy

Policy Definition

1. This Bulk Email Policy paper seeks to establish best industry practices for our Datacenter email operations. While the requirements following may be considered stringent or counterproductive at first, we believe that following the policy will result in a healthier Internet presence and reputation, lower costs of doing business and better deliverability to the targets of our email activities.

2. Scope: this policy applies to all emails sent from eResources company equipment.

a. Bulk Email: Email is considered to be Bulk Email if it is part of a large send containing substantially identical information unrelated to a transaction. IE: a newsletter is bulk email even when opted-in, while an application deadline reminder is not because the latter relates to a transaction in progress.

b. Unsolicited Email: Email is considered to be unsolicited if the recipients of the emails have not confirmed their desire to receive the email via a “Closed-loop opt-in” confirmation process. Normal emails from one person to another in casual communication would fall into this category.

c. Spam: Email is considered to be Spam if it is both Bulk Email and Unsolicited Email, regardless of content. This is illegal and will harm our Internet presence and reputation, and our relationships with Internet service providers.

d. Closed-loop opt-in: Also known as COI, this process confirms the validity of a subscription by sending the recipient an email requesting positive confirmation of subscription. If the recipient never responds to the confirmation request, they have not opted in and do not receive bulk emails. A bulk mailing list is considered to be COI if every recipient on the list has confirmed their subscription status as described above.

3. Definitions:

a. All bulk email sent from eResources equipment will conform to the COI standard as described above.

b. eResources will maintain records of the confirmation dates of the recipients’ confirmations on all bulk email lists.

c. Those records will be available in a format ready for reporting to ISP’s, for answering complaints and questions about our policy and adherence to that policy.

d. All existing mailing lists that are not known to conform to the COI standard will be subject to a “Permission Pass” process, in which all recipients on a non-COI list are sent a request to confirm their subscription status. Any non-responders are removed from the list.

e. When clients bring their mailing lists to eResources, we require that the lists be certified as COI by listing the confirmation records as described in 4.b or be subjected to the Permission Pass as described in 4.d.