Mass Email Policy

1. Purpose

The purpose of this policy is to provide rules and guidance for the use of mass email to disseminate information within and beyond the Western Michigan University community.

2. Justification

Email is an important tool for academic, research and administrative communications; however, it is not the only tool, nor is it always the best tool. The cumulative amount of time spent by students, faculty and staff on processing unwanted email represents an enormous loss of personal and institutional productivity. Furthermore, improper use of mass email potentially exposes the University to blacklisting by various email providers and to liability under the federal CAN-SPAM Act of 2003. Thus, the standards and restrictions enacted by this policy are necessary to:

• Provide for mass emailings at Western Michigan University that are accessible, concise, consistent and coordinated.
• Establish guidelines for the appropriate use of mass email versus other communication tools.
• reduce the number of email messages sent to students, faculty and staff;
• ensure compliance with federal law and the "best practice" expectations of recipients' email providers; and
• preserve the effectiveness of email as a communication tool, without unduly restricting the free flow of information within the University community.

3. Scope

This policy applies to all mass email messages sent from a University-owned domain (e.g., wmich.edu, millerauditorium.com, wmualumni.org, etc.), as well as to mass email messages sent through third-party services on behalf of any unit of the University.

4. Definitions

• Mass email is defined as identical or substantially similar messages sent to more than 50 addresses.
• Unsolicited email is defined as any message that the recipient did not specifically request and would not reasonably expect to receive on the basis of either an active, opt-in subscription to a mailing list or a current or past relationship with any part of the University (e.g., students, prospective students, alumni, employees, customers, etc.).
• Mailing list is defined as a system that allows an email message to be sent to multiple addresses such that a recipient only sees his or her own address or an address representing the entire list (e.g., @email) in the To: or CC: field, without revealing the addresses of other recipients in the list.

5. Rules for messages

All mass email messages must conform to the following standards:

5.1. No spam

Sending unsolicited mass email—commonly known as spam—is prohibited.

5.2. Sender must use a WMU email address

The From: address must be a valid email address at wmich.edu or another domain owned by the University and registered through the Office of Marketing and Stategic Communications (for example, millerauditorium.com). Use of an address at a domain not owned by the University (such as gmail.com) to distribute mass email is prohibited.

5.3. Sender must provide contact information

The body text of the message must include contact information for the person, office or group that sent it. Minimally, the contact information must include a phone number and a valid email address at a domain owned by the University.

5.4. Recipients must be addressed using a mailing list

All recipient addresses must be concealed through the use of a mailing list (see section 6, Rules for mailing lists). If a software limitation precludes the use of a mailing list, the BCC: field may be used to conceal the recipients' addresses instead; otherwise, use of the BCC: field to address mass email is prohibited.

5.5. Message must be clear and concise

The message must include a subject line that is relevant to the message's content, and the body text must be clear, concise and no longer than 500 words in length. Additional information, if needed, should be provided via a web link in the text.

5.6. No attachments

Accompanying files, if any, must be provided via a web link in the body text of the message, not attached to the message itself.

5.7. Message must be accessible

The message must be composed in either plain-text or multipart plain-text/HTML. All information conveyed by the message must be in the text, not embedded in images or other elements that are inaccessible by text-to-speech software. Any images in the message must include "alt" text describing the image for low-vision readers.

5.8. Recipients must be allowed to unsubscribe

Unless it has been classified as essential under the provisions of section 7, Essential communications, the message must include a valid option to unsubscribe from future mailings. This option must be clearly visible in the body text of the message, and requests to unsubscribe must be processed and honored within five business days.

6. Rules for mailing lists

Any use of a mailing list for mass email is subject to the following provisions:

6.1. Creation, use and ownership of mailing lists

Faculty, staff and students may request a mailing list as described in the Office of Information Technology's "Mailing Lists" policy. The owner of any list that is used to send mass email is responsible for ensuring that such use complies with this policy.

In addition, some units of the University have purchased software that includes mailing list capabilities. In such cases, the supervisor of the unit is considered the owner of all mailing lists managed by the software.

List owners should be aware that some mailing lists at the University may not provide a mechanism to unsubscribe (see 5.8). If membership in a list is managed manually, messages sent to the list must include simple instructions for requesting removal, and the owner must ensure that the list's membership is updated accordingly. If it is not possible to remove an address from a list (as in 6.2), then that list may only be used according to the provisions of section 7, Essential communications.

6.2. Use of broad distribution mailing lists

Mailing lists addressing all faculty, all staff or all students—as well as other broad categories, such as "all administrators" or "all chairs and directors"—are managed by the Office of Marketing and Strategic Communications. Because the recipients of these lists cannot unsubscribe, messages to these lists are subject to the provisions of section 7, Essential communications. If the sender does not have direct access to a list, a request should be submitted to the Office of Marketing and Strategic Communications, which will send the message on the requestor's behalf if it qualifies as an essential communication.

6.3. Use of mailing lists by collective bargaining units and professional organizations

Collective bargaining units and professional organizations—such as AAUP, APA and PSSO—may request the creation of a mailing list containing the email addresses of eligible members of their group in accordance with the Office of Information Technology's "Mailing Lists" policy. Any message to such a list must include a valid option to unsubscribe (see 5.8), and unsubscribed addresses may not be re-added to the list unless either (a) the recipient's membership status in the organization changes or (b) the recipient specifically asks to be re-added.

6.4. Use of external mass email services

Any use of an external mass email service—such as Exact Target, Constant Contact, Vertical Response, HubSpot or MailChimp—must fully comply with this policy and must provide recipients with a legitimate option to unsubscribe from future mailings. Units choosing to make use of such services should be aware that the University's anti-spam filters may prevent delivery of these messages to wmich.edu addresses.

6.5. Acquisition of email addresses

A mailing list containing email addresses acquired through sources external to the University may only be used to send mass email if the recipients were clearly informed before providing their email addresses that they were opting in to receive messages from third-parties.

6.6. Access to email addresses for research purposes

Access to WMU email addresses for survey research requires the approval of the chief information officer of the University and is limited to WMU students, faculty and staff only. In most cases, such access also requires the approval of the Human Subjects Institutional Review Board. Individuals should read and fully understand the University's "Rules on Use of Mass Email for Research" and "Data Collection Through Surveys Policy" before submitting a request to the chief information officer.

7. Essential communications

Any message that meets at least one of the following criteria may be classified as an essential communication and exempted from offering an unsubscribe option (see 5.8):

1. The message is essential to the mission or operations of the University.
2. The message is essential for student academic performance.
3. The message pertains to an urgent health or safety situation.
4. The message is required by law.

The Office of Marketing and Strategic Communications is charged with determining whether a given message qualifies under these criteria. In addition, certain messages shall automatically qualify as essential communications, as described in the subsections below, and do not require approval from the Office of Marketing and Strategic Communications before being sent.

7.1. Messages from senior officers

Any message approved by the president, senior academic officer, senior business officer, senior student affairs officer or chief information officer of the University is an essential communication.

7.2. Messages from the Office of the Vice President for Research

Any message to the faculty from the Office of the Vice President for Research is an essential communication.

7.3. Messages from deans

Any message to the faculty, staff or students of a college from the dean's office for that college is an essential communication.

7.4. Messages from department chairs

Any message to the faculty, staff or students of an academic department from the chair of that department is an essential communication.

7.5. Messages from supervisors

Any message to the staff of an administrative unit from the supervisor of that unit is an essential communication.

7.6. Messages from faculty and instructors

Any message to the students enrolled in a course from the faculty member or instructor teaching that course is an essential communication.

7.7. Messages from the Office of the Registrar

Any message to instructors-of-record from the Office of the Registrar is an essential communication.

7.8. Messages from the Haenicke Institute for Global Education

Any message to the faculty, staff or students of the Haenicke Institute for Global Education approved by the associate provost of the institute is an essential communication.

8. WMU Today and other alternatives to mass email

To reduce the number of separate mass email messages sent to faculty and staff, the Office of Marketing and Strategic Communications will regularly distribute a mass email compilation of campus announcements titled "WMU Today."

In addition, the University's intranet portal, GoWMU, may be used to broadcast messages to students, faculty, staff and others.

Senders are encouraged to consider using one of these channels before requesting a separate mass emailing. Requests to publish an announcement in WMU Today or GoWMU may be sent to marcom@wmich.edu.

9. Enforcement

Persons found in violation of this policy will be reported to the appropriate dean or vice president for corrective action. Violations may also result in the removal of mailing list or email access privileges, in accordance with the Office of Information Technology's "Email Address Use and Rules," "WMU Email Rules" and "Computing Resources Acceptable Use Policy."

10. Contacts for more information

For general mass email questions:

Office of Marketing and Strategic Communications
Western Michigan University
Kalamazoo MI 49008-5433
(269) 387-8400
Send an email

For research-related mass email questions or requests:

Andrew Holmes
Interim Chief Information Officer
Office of Information Technology
Western Michigan University
Kalamazoo MI 49008-5206
(269) 387-4198
Send an email

11. Adoption and revisions

These standards are based on best practices, applicable law and technical capabilities at the time of the latest revision and will be updated periodically as technology and other factors change. All of the standards presented here are consistent with those of the federal CAN-SPAM ("Controlling the Assault of Non-Solicited Pornography and Marketing") Act of 2003.

Approved: April 28, 2016 (version 2.0)
Last revised: Oct. 30, 2017 (version 2.2, revised contact information)
IT Executive Advisory Board