Private right of action could mean costlier penalties
Just over three years ago, employers faced a daunting headline: Compliance with Canada’s anti-spam legislation (CASL) by July 1, 2014. Essentially, that meant any commercial electronic messages (CEMs) such as emails or texts sent by employers needed consent, identification information and an unsubscribe mechanism. The installation of computer programs without express consent was also not allowed, and there were restrictions around the collection of personal information and electronic addresses.