Subject: Communications Policy | Number: COMM 101 |
Issued By: Executive Director, College Advancement & External Relations | Date Updated: March 14, 2017 |
Supersedes: New | Page(s): 1 of 10 |
Related Documents and Links |
1. Purpose
The purpose of this policy is to promote a positive image of the College by mandating a consistent and professional approach to College communications. It establishes guidelines around developing and distributing multimedia communications that effectively represent the College’s brand identity. The policy sets out procedures that apply to College email and other electronic communications to ensure they are in compliance with Canada’s anti-spam legislation (CASL), which came into effect in large part on July 1, 2014.
The College community connects daily with regional, provincial, national and international target markets on a wide range of subjects. In support of the College’s Strategic Enrolment Plan, staff and faculty regularly reach out to prospective students and their influencers — parents and families, high school teachers and guidance counsellors. Communications are delivered in person as well as through email, social media, postal mail, and phone. They cover everything from program-specific information to Open House and Career Fair details.
This Communications Policy establishes a framework for Loyalist employees to create and disseminate concise, welcoming messages that convey the College’s core strengths: outstanding faculty; personal attention in small classes; hands-on learning; and state-of-the-art facilities with current industry technology. Communications are shaped by the College’s strategic directions:
- Academic excellence
- Service and systems excellence
- Sustainability and capacity building
The College’s values help to inform caring communications, focused on the success of Loyalist learners, staff and community. To support our mission to offer career-oriented education and training opportunities that drive economic and social development, we communicate with:
- Respect
- Integrity
- Transparency
- Commitment to excellence
- Innovation
- Responsiveness
- Accountability
- Sustainable stewardship
Integrating these values into day-to-day College communications contributes to a positive corporate culture, which drives organizational excellence. The goal of this policy is to engage Loyalist stakeholders in extending the College’s mission, vision, values and strategic directions through succinct, credible and legal communications. It is in the interest of everyone associated with Loyalist that the College’s image be consistently projected in a positive manner.
2. Scope
The Communications Policy applies to the College’s employees, which in this policy means both staff and faculty, as well as agents, students, graduates or any other person who communicates in an official capacity on behalf of Loyalist. This policy will be updated and revised when appropriate.
3. Definitions
- Advertising is a form of communication intended to persuade a particular audience. Traditionally, advertising was a paid commodity or transaction. However, under current Ministry of Training Colleges and Universities guidelines, advertising is used synonymously with ‘promotion’ and does not have to include the exchange of money.
- Brand Identity Guidelines, available on the myLoyalist portal, provide a resource for producing consistent communications materials—everything from use of the College’s logo to staff signatures, and other visual factors associated with the College’s identity. Included are the management of the mission statement, vision statement and marketing messages conveyed through taglines, email signatures, photography and graphic representation in letterhead, program brochures etc. The objective of the Brand Identity Guidelines is to sharpen the Loyalist brand through consistent marketing and communications, a key goal for the College.
- College Communications are messages conveyed on behalf of the College to individuals and/or the external and internal community through everything from emails and social media to postal mail, phone and in-person conversations.
- Corporate Communications are the messages issued by Loyalist to its audiences, such as employees, students, prospective students, alumni, community partners and media, among others. Related activities involve managing internal and external communications, which showcase favourable points of view among stakeholders. This encompasses both proactive and reactive communications, as well as the public relations and promotional plans of the College.
- College Stakeholders are individuals who influence an organization’s actions and/or are affected by an organization’s performance.
- Canada’s anti-spam legislation (known as “CASL”) was introduced in July 2014 to increase the efficiency and productivity of Canadians online by reducing the flow of unsolicited email messages. CASL prohibits sending unsolicited commercial electronic messages (CEM). This applies to commercial electronic messages: (1) sent from a computer system in Canada, and (2) accessed by a computer system in Canada. This means that any College employee in Canada who sends commercial electronic messages, and College employees outside Canada who send commercial electronic messages to recipients in Canada, need to comply with CASL. Failure to comply with CASL could result in significant fines to the College and/or the employee.
- It does not matter whether the CEM is sent to a work or personal electronic address, or whether the CEM is a single email or text or “mass” mailing. CASL applies to CEMs, whether there is one recipient or 100. Examples of commercial electronic messages sent by the College and employees of the College include:
- Email advertising upcoming specials at the on-campus restaurant or fitness facility;
- Emails promoting a sale at the College Bookstore or advertising a discount with a third party; and
- Emails seeking donations to a third party (e.g. sponsoring a participant in a run for a charity other than the College).
- CASL has administrative monetary penalties of up to $1 million per violation (for individuals) and up to $10 million per violation (for organizations). If a College employee sends an email that contravenes CASL (such as an email without the necessary consent, or an email that does not have the requisite unsubscribe mechanism), the College could be held liable, if the employee was acting within the scope of his or her employment.
- It does not matter whether the CEM is sent to a work or personal electronic address, or whether the CEM is a single email or text or “mass” mailing. CASL applies to CEMs, whether there is one recipient or 100. Examples of commercial electronic messages sent by the College and employees of the College include:
- Commercial Electronic Message (CEM) is an electronic message that, having regard to the content of the message, it would be reasonable to conclude has as its purpose, or one of its purposes, to encourage participation in a commercial activity. The term includes messages that offer to sell, advertise or promote any product or service. “Electronic message” means a message sent by any means of telecommunication, and includes email, text messages and personal messages sent via social media. It does not include live two-way phone calls, faxes or “snail mail.” “Commercial activity” is broadly defined and means any transaction, act or conduct that is of a commercial character, whether or not there is an expectation of profit.
- Constant Contact is the email marketing service that Loyalist currently uses to create and distribute electronic group messages. Real-time reporting allows the College to track and manage opens, bounces, forwards, and unsubscribes in accordance with CASL. Loyalist uses this system as the definitive source for storing email addresses.
- Media Relations involves working with media for the purpose of informing the public of an organization’s mission, policies and practices in a positive, consistent and credible manner. Loyalist’s relationship with the community is affected in large part by its relationship with the news media. All employees and students share in contributing to good media relations; however, it is important that consistent protocols and procedures are followed in sharing newsworthy events with the media.
- Official Communications are messages conveyed on behalf of Loyalist to an intended audience by various means. Examples of official communications include publications, both electronic and print; media relations, ranging from news releases to advertisements; and multimedia messaging through the website, portal, social media channels, portals, videos, and broadcast, among others.
4. Policy
As communications span the entire range of Loyalist initiatives, they are an essential part of the planning and promotion of College programs and services. In order to produce the highest quality of communications, faculty and staff must recognize the role their communications play in conveying College values and advancing the College mission.
This policy is designed to increase employees’ awareness of their responsibility for maintaining good communication practices. In all communications, College employees have a responsibility to serve the interests of Loyalist by ensuring appropriate content and positioning at all times.
To ensure communications quality and consistency, Marketing & Communications Services provides centralized oversight and leadership in maintaining, developing and advancing the College’s brand identity and reputation. Internal and external communications are aligned to advance the College’s mission, vision, and values, highlighting strategic enablers.
5. Requirements for Electronic Communications
- 5.1 The basic rule of CASL is that: subject to a few exceptions, a commercial electronic message cannot be sent to an electronic address unless: (1) the sender has obtained consent from the recipient of the message (“Consent Requirement”) and (2) the message contains certain information about the sender and an unsubscribe mechanism (“Content Requirement”). CASL also prohibits fraudulent data collection, including altering transmission data; installing a computer program, or use of a computer program to send messages, without express consent; and collecting personal information from a computer using a computer program or unauthorized access. Before you send the commercial electronic message, consider:
- Do you have consent from the recipient to send the message?
- Does the message have the contact information (name of sender, mailing address, and telephone number, email or web address) and a way for the recipient to unsubscribe?
- If you receive a request to unsubscribe, the recipient must be removed from the College’s mailing lists within 10 business days of the request.
- 5.2 Assistance: If you have questions or are unsure whether the message you are sending is a CEM please contact Marketing & Communications Services at marcom@loyalistc.on.ca.
- 5.3 Confirming consent: Before you send the CEM, you must have consent from the recipient. Consent can be express or implied.
- Express consent: recipient has checked off the box on an email, sent in Constant Contact, or given express consent as indicated in Enrolment Services’ database.
- Implied consent: recipient falls into a category where the recipient’s consent to receive electronic messages can be implied. Some of the relevant examples of implied consent include when the recipient is one or more of the following:
- a student currently enrolled at the College;
- a current member of the alumni association or someone who was a member of the alumni association within the past 2 years;
- a person who made a donation to the College or volunteered for the College in the past two years;
- a person who made an inquiry or application to the College in the past 6 months; or
- a person who provided their email address to the College without prohibition on receiving CEMs, and the message relates to the recipient’s job, title or official capacity.
- 5.4 Centralize: For electronic communications intended for a group of recipients, contact Marketing & Communications Services for help developing the email in Constant Contact and distributing on your behalf to specified target audiences. Real-time reporting in Constant Contact allows the College to manage unsubscribes and segment lists by subject so the right people get the right messages. By consolidating group emails, Marketing & Communications Services can ensure recipients have expressed or implied consent. In addition, the team can track email opens, bounces and forwards in order to strengthen and refine lists.
- 5.5 Required Content: Ensure that the following required content is included in the CEM:
Loyalist College
376 Wallbridge-Loyalist Road
P.O. Box 4200
Belleville, Ontario
K8N 5B9
AND
Loyalistcollege.com
OR
Telephone number (613-969-1913 ext. 2100)
OR
Email address (info@loyalistcollege.com)
- The foregoing information needs to be valid for 60 days after the message is sent.
- As part of the brand identity process, Marketing & Communications and IT Services have created a College standard email footer for your external and internal communications. Click here for instructions on how to download, customize and save the template in Outlook. For IT support, please contact the Help Desk.
- 5.6 Unsubscribe Mechanism: CEMs must include an unsubscribe mechanism such as, “To manage communications with the College you can click [unsubscribe].” This option allows recipients to unsubscribe from some communications rather than all communications. Alternatively, the communication can provide a single option, “To withdraw your consent at any time click [unsubscribe]” or “To unsubscribe, please reply to the sender with “unsubscribe” in the subject line.”
- If you receive a request to unsubscribe, please contact Marketing & Communications Services at marcom@loyalistc.on.ca as soon as possible. CASL requires that requests to unsubscribe be implemented without delay, and no later than 10 business days after receipt. Unless the recipient has indicated otherwise, a recipient who clicks “Unsubscribe” should not receive further CEMs from the College.
6. Exemptions from Electronic Communications Requirements
- 6.1 If you do not have consent from the recipient, you may be permitted to send the CEM if you fall under one of the special circumstances listed below.
- CEM is sent by a registered charity, such as the Loyalist College Foundation, and has fundraising as its primary purpose;
- CEM is sent to an organization that the College has a relationship with (e.g. vendors and suppliers) and the message concerns the activities of the organization;
- CEM is sent via the College’s portal (a limited-access, secure and confidential account to which only the College may send messages);
- CEM is sent to recipients with a family or personal relationship (note that these are defined terms);
- CEM is sent by an employee or representative of the College to another employee or representative of the College;
- CEM is sent in response to a request, inquiry or complaint or is otherwise solicited by the recipient; and
- CEM is sent to satisfy legal obligations, or to provide notice or enforcement of a legal right or obligation.
- If your message falls under one of the above circumstances, you may send the CEM without complying with items 5.3 and 5.5.
- 6.2 If your message is a CEM that solely (a) facilitates, completes or confirms a commercial transaction that the recipient already agreed to enter into, or (b) provides notification of factual information about the ongoing use or purchase by the recipient of a product or service provided under a subscription, membership, account, loan or similar relationship, then you do not need consent to send the CEM, but you do need to comply with item 5.5. Examples include a CEM that confirms enrolment in a course or payment received.
- 6.3 While CASL prohibits sending unsolicited commercial electronic messages, meaning “cold emails” to new contacts with whom you have had no prior contact, there are some situations where you may send commercial electronic messages to new contacts:
- The recipient provided his or her email address to you (for example, by giving you a business card containing his/her email address) and did not indicate that he/she does not wish to receive commercial electronic messages, and provided the message is relevant to the contact’s business, role, functions or duties in a business or official capacity.
- The recipient’s email address is conspicuously published on his/her company’s website, and it is not accompanied by a statement that he/she does not wish to receive commercial electronic messages, and provided the message is relevant to the contact’s business, role, functions or duties in a business or official capacity.
- Since CASL does not apply to phone calls, you may call the contact and ask for consent over the phone. You should record the date and time the contact provided consent (and enter it into the database directly or via Marketing & Communications Services), and follow up with an email message to confirm.
- In each of these circumstances, you still must comply with item 5.5 (ensure that the Required Content is in the message). Please contact Marketing & Communications Services at marcom@loyalistcollege.com if you are uncertain about how to proceed or have any questions.
7. Communications Responsibilities of Faculty, Staff and Administration
- General
- 7.1 Maintaining professional boundaries in all forms of communications is vital to maintaining public trust and appropriate professional relationships with current and prospective students.
- 7.2 Communication is delivered on behalf of Loyalist, therefore is subject to the College’s values, including respect and integrity in all correspondence.
- 7.3 All staff and faculty must adhere to Canada’s anti-spam legislation (CASL) when communicating with stakeholders electronically.
- 7.4 All College communications and publications must follow College policy concerning the Accommodation of Ontarians with Disabilities Act with the objective of providing effective and useful communications with all persons.
- 7.5 To ensure that everyone understands the College’s messages, plain language should be used in all correspondence.
- 7.6 Communications will respectfully portray and address people of different ages, cultures, sexual orientation, beliefs and abilities.
- 7.7 College employees shall not use, or seek to use, their positions or employment with the College in communications to gain direct or indirect financial, political or material benefit for themselves or their immediate family.
- Official Statements
- 7.8 Authority to issue official statements rests with the office of the Chair of the Board of Governors, the President or her delegate.
- Emergencies
- 7.9 Any accident or incident on campus that results in serious injury to individuals, or property damage of significance, should be immediately reported to the Director – Facilities & Information Technology Services – day or night. It must also be relayed as soon as possible to the Executive Director of College Advancement & External Relations.
- 7.10 If incidents call for the intervention of municipal police or fire departments, the Chiefs of those respective forces will assume directional control of the situation and, depending on the circumstances and the severity of the incident, may assume authoritative control in regard to the handling of news media, responding to news media queries and the issuance of formal statements. In such an event, the College Advancement & External Relations department will maintain close liaison with those authorities and the President’s office in respect to dealing with news media and the release of information.
- 7.11 In the event of an incident involving Loyalist students, graduates or staff, regardless of location, it is important that individuals’ names and details not be released to the media or other general public sources until the information has been made public. The Executive Director of College Advancement & External Relations should be immediately informed of the details of the incident so that she can verify the accuracy of related information and withhold names until confirmation is received through official administrative sources. Only then may names and specifics be released to the news media by a delegated College spokesperson.
- Electronic Communication with Students and Staff
- 7.12 Mass communications are discouraged unless there is a real and specific need for the entire student and staff body to receive the information. Instead, communications should be forwarded directly to the intended recipient(s) or forwarded to Marketing & Communications Services for inclusion in the weekly student or staff electronic newsletters. Examples of information that is of interest to students and staff include deadlines, notification of key changes and event notices. Messages should be short, concise and accurately reflect the content and the owner of the message.
- 7.13 Emails related to student survey initiatives will be prepared and sent in consultation with Marketing & Communications Services.
- Marketing and Advertising
- 7.14 All advertising and promotional material is to be produced in coordination with Marketing & Communications Services based on the guidelines presented in the Brand Identity Guidelines. Designed to define the College brand, these guidelines outline the College logo, colour palettes and typography, as well as acceptable uses of these elements in corporate letterhead, business cards, advertising, primary publications, websites and other electronic communications. In all written communications, information is presented concisely and accurately, in a style that is friendly and approachable while remaining professional.
- 7.15 College communications activities and key messages shall be projected in a positive, coherent and consistent manner that supports the College’s Strategic Enrolment Plan and corporate marketing strategy, following procedures and protocols provided by Marketing & Communications Services.
- 7.16 Loyalist is committed to ensuring that all College marketing properties meet the information and communications standards as set out in the Integrated Accessibility Standards of the Accessibility for Ontarians with Disabilities Act, 2005.
- 7.17 Publications, both electronic and print, that are to be used for marketing or promotions are coordinated through Marketing & Communications Services and must follow Ministry guidelines for program promotions.
- 7.18 College advertising, in all formats, must be approved by Marketing & Communications Services prior to publication. Exceptions may be approved in advance.
- Media
- 7.19 All official communications with the media, on behalf of the College, shall be coordinated and supported by Marketing & Communications Services. Loyalist is committed to providing all reasonable cooperation with the media who visit the College to cover a specific event. Such media activity is encouraged and is arranged by Marketing & Communications Services. All employees share in contributing to good media relations, as Loyalist’s relations and brand in the community are affected in large part by media exposure. As such, it is important that consistent protocols and procedures are followed.
- 7.20 The President and CEO shall be the primary official spokesperson for the College. In the event of her absence, a substitute spokesperson will be appointed. For specific requests, subject matter experts may be called upon to interact with the media.
- 7.21 When an employee is contacted by a representative of external media who leaves a voice message or sends an email, the employee should discuss the opportunity with Marketing & Communications Services and receive approval to proceed with an interview.
- 7.22 Employees contacted directly by the media in relation to a specific event should redirect the media to Marketing & Communications Services.
- 7.23 When an employee is contacted directly by QNet student reporters, the employee is to exercise judgment in representing the College according to the College’s official position, and inform Marketing & Communications Services. It is preferable to discuss the opportunity before responding live to College media.
- 7.24 Although employees as private citizens are free to send “letters to the editor” of a newspaper or magazine, they should not do so using College stationery or express their College title or position without clearance from the Director, Marketing & Communications Services.
- 7.25 Every employee is responsible for informing Marketing & Communications Services immediately of any occurrence that could be interpreted by the news media to reflect negatively upon the College. The treatment of such an occurrence by Marketing & Communications will be based upon two principles: a) bad news cannot be concealed; and b) honesty prompts accurate reporting. ‘Bad news’ may develop from any occurrence or situation that reflects adversely upon an employee, a group or the College as a whole.
- 7.26 An occurrence or situation that reflects well upon an employee or a student should also be reported to Marketing & Communications Services as soon as possible. This division will determine if the report should be interpreted for, and communicated to the news media. In this regard, Marketing & Communications Services will expedite the flow of news to the community.
- Photography
- 7.27 Although photography is usually permissible, the following protocols must be observed:
- Anyone may decline an opportunity to be photographed for the media or College materials;
- The entry of a news photographer into the classroom requires the consent of the classroom instructor; and
- Participants must sign a release form giving permission to publish their photograph.
- 7.28 Photography used in College marketing materials is to be of a high quality, featuring Loyalist students, graduates and faculty in dynamic settings that highlight experiential learning. Stock photography illustrating post-secondary students, graduates, staff and faculty misrepresents the College and should be avoided.
- 7.27 Although photography is usually permissible, the following protocols must be observed:
- Student Government
- 7.29 Media questions concerning Student Government should be referred to an official of that body. Marketing & Communications Services requests to be made aware of the news media interest.
- Athletics
- 7.30 The Athletics Department may communicate with the media concerning athletic events. The Director of Marketing & Communications should be kept informed and be available to advise and assist on major events as required.
8. Responsibilities of Marketing & Communications Services
Marketing & Communications Services at Loyalist is committed to ensuring that all communications and related activities enhance Loyalist’s image and reputation and are supported with an effective, comprehensive and relevant communications plan.
- 8.1 Offer guidance and consultation to faculty and staff in maintaining good communications practices in accordance with this policy.
- 8.2 Advise staff and faculty on the scope of Canada’s anti-spam legislation (CASL) and the effect it may have on electronic communication.
- 8.3 Provide strategic planning advice and leadership on internal and external communications; assist in identifying key audiences; help to enhance communication with employees, stakeholders and the general public; and develop corporate messaging for distribution within the College community and beyond.
- 8.4 Review, top edit and approve requests for all communications and marketing materials, including course descriptions and other web updates, social media messages, media advisories and news releases, advertisements and promotional items (i.e. pens, magnets, etc.) in the interest of both budget considerations and maintaining a proper and consistent brand identity as identified in the Brand Identity Guidelines.
- 8.5 Develop and deliver key College messages to enhance and strengthen relationships with internal and external audiences through media relations, public relations, internal communications (i.e. staff, student and alumni newsletters) and the coordination and delivery of College publications (i.e. Lasting Connections).
- 8.6 Develop, coordinate and implement all advertising, promotional material, recruiting material, publications, social media messages and advertisements, web design and updates related to the marketing of Loyalist College.
- 8.7 Create and produce the annual publication of a post-secondary viewbook and other marketing and recruitment publications in consultation with Enrolment Services.
- 8.8 Manage the official corporate identity of the College, including the correct use of the College’s logo, fonts and design, etc.
- 8.9 Lead official media relations, including news releases, media interviews, and emergency communications. Where authorized by Marketing & Communications Services, staff and students may speak to the media about College events and information that reflect on the College.
- 8.10 Ensure College advertising conforms to Canadian advertising standards and complies with MTCU advertising guidelines. College advertising does not contain deceptive claims, statements, illustrations or representations either direct or implied, nor does it omit relevant information, the result of which would be deceptive.
- 8.11 Provide accountability for College website content, and in conjunction with Information Technology Services, portals/technical functionality.
- 8.12 Assume responsibility for official communications to current and prospective students with Enrolment Services, in consultation with other areas of the College as appropriate. Enrolment Services is responsible for maintaining the official record of program and course information, including credentials, admission requirements, fees etc.
- 8.13 Ensure official communications, including publications, memos and letters are free of gender bias terminology; written in plain language; and available in alternative formats.
- 8.14 Address any complaints or concerns regarding advertising or promotion by the College in a timely manner.
- 8.15 Communicate with the media concerning storm or emergency measures, cancellation of classes or the closing of campuses or the College. Decisions on cancellation or closure of campuses are made in accordance with Academic Operational Policy 202 Cancellation of Classes.
- 8.16 Responsible for monitoring compliance with this College Communications Policy and updating it as required.
9. Related Documents and Links
- Brand Identity Guidelines
- COMM 102 Web Site Policy
- COMM 103 Social Media Policy
- ITS 102 Email Use Policy
- ADMIN 107 Conflict of Interest Policy
- ITS 101 Acceptable Use of Computer Resources
- AOP 202 Cancellation of Classes Policy
- ADMIN 105 Suspension of Operations and Closing of the College Policy