| Comment Number: | OL-102991 |
| Received: | 4/14/2004 3:03:13 PM |
| Organization: | |
| Commenter: | Eli Fry |
| State: | CA |
| Agency: | Federal Trade Commission |
| Rule: | CAN-SPAM ANPR |
| Docket ID: | [3084-AA96] |
| No Attachments |
Comments:
To whom it may conern, Thank you for your efforts to address the issue of spam. I am concerned however, about the proposed requirement for merchants to maintain suppression lists. The best method in my opinion, is to have the choice in the hands of the consumer itself, by utilizing an automated system. The opt-out mechanism should be managed by the company actually sending the email (using their own resources) If company A sends email for company B -- then company A should managed the opt-outs. If the law simply required that all commercial emails have a legitimate, automated remove/unsubscribe link in all messages (not email addresses to send a request to) -- then I think credibility of the remove option would increase and people could utilize it more. Especially, if certain 3rd party providers got involved and utilized their own domains for the removal process. For example, having a remove link similar to: "Unsubscribe here: http://remove.yahoo.com/removeservice/unsub.asp?merchantID=18237&clientID=1742" This type of link would create legitimacy, credibility, and instant results. People would trust their info would not be stolen. I believe the best way to handle things, is to require an automated system whereby the customer themselves can modify their information, or remove/unsubscribe themselves altogether. This is a better system I believe, because it is instant for the consumer (no waiting on human intervention). This keeps it simple for the list manager, which in turn makes sure it gets done. PLUS... there is no potential for a suppression list to make it's way into the hands of spammers. Which it most definitely will eventually. If people can get access to it, there's a good chance a copy of it will get out. My company has uses email to reach our past customers. These are people who have purchased from us in the past, and have consented to receiving new product updates, information, and special offers. There is also a form on our website, where people who are not yet customers, can sign up to receive updates, and information by email when available. We use an automated system just like the one I described above. Every single contact message sent, automatically includes 2 links at the bottom. 1 for modifying your information, and the 2nd for unsubscribing altogether. The system we use always includes the 2 links, ensuring the customer ALWAYS has the ability to modify their preferences through any message. Our customers are fully in charge of their info, and we do not share our lists with any other company. This method is working very well for us, and we get ZERO complaints. (If people want off, they simply click and unsubscribe -- effective the moment they click the link. I hope you consider this model as a viable alternative. Most people enjoy receiving emails if it's regarding something they've purchased, or are interested in. It's the garbage that people do not need or ask for that clutters up the inboxes. Please be careful not to create legislation which will hurt legitimate, and well working (no complaints) publications and businesses on the internet using email as a contact medium. My specific concern is for harm to publishers who require permission from the consumer prior to adding them to any list. If we as a company, already have our customer list (built over time) with one broadcasting / list managing service (which automates the remove and updating process) -- But then wish to switch to another provider due to business costs, or service -- we are concerned that we may not be able to move our list. When the consumer is initially in charge of their own decision whether or not to be on the list, we do not wish to ask them to subscribe again if we switch providers. Please make sure any legislation regarding this manner, is well thought out with balance. Thanks for your time, Eli Fry California