Unsubscribe Email Requests: To scrub or not to scrub?

With respect for your client requests, and to avoid potential fines associated with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM”), you definitely want to scrub your emailing list before each use.

CAN-SPAM strives to prevent consumers from receiving unwanted emails.  CAN-SPAM sets the rules for commercial email and gives consumers the right to “unsubscribe” from commercial messages.  The penalties, primarily enforced by the Federal Trade Commission (“FTC”), for emailing someone who has unsubscribed from National Life’s marketing emails can be hefty – up to $46,517 for each email sent.

What is email list scrubbing?

Each time you send a marketing email, National Life requires you to remove any unsubscribed email addresses prior to sending your communication.  This is known as “scrubbing.”  To assist you in scrubbing, National Life has contracted UnsubCentral, a third-party vendor, and established a self-service scrubbing tool which can be accessed via the Agent Portal.

How do I scrub my distribution list?

The UnsubCentral scrubbing tool is located on the Agent Portal, under “Training” > “Compliance” > “Telemarketing and Email Solicitation.”  Directions on how to use the tool are also located in this area.  It is a quick and straightforward process, all you need to do is upload your email list as a “.txt” file, select “Non-Matching Emails” and you’ll receive a scrubbed list for download.  The process only takes a few minutes and can save you time and money in the future!

Requirements of CAN-SPAM:

In addition to scrubbing your email distribution list, CAN-SPAM also requires you to:

1. Use truthful header information in all emails.
2. Use honest subject lines in all emails.
3. Clearly identify the message as an advertisement.
4. Include your physical address.
5. Include a way to opt-out of receiving future emails.
6. Quickly respond to opt-out requests.
7. Monitor what others do on your behalf.

The requirements do not apply only to bulk emails and there are no exemptions for business-to-business emails.  Please note, CAN-SPAM does not apply to emails you send to existing National Life clients that are only transactional in nature with no marketing message.

As a reminder, consumers who want to unsubscribe should visit  National Life’s Unsubscribe Manager where they can submit their email address and it will automatically be added to the unsubscribe list.  If a consumer asks you directly to “unsubscribe” them, it is your responsibility to immediately remove them from your mailing lists and load their email address into National Life’s Unsubscribe Manager.

If you need more information, please contact NLGCompliance@NationalLife.com.