Table of Contents
How do you do outreach in Canada as a political party, advocacy, or union? In Canada, telemarketing calls and commercial text messaging are regulated primarily at the federal level. Below, we outline how political entities, businesses, labor organizations, and charities are treated under Canada’s calling and texting regulations across various outreach purposes (informational, fundraising, telemarketing, etc.)
Specifically, we will be having an in-depth look at the following regulations for outreach in Canada:
- National ‘Do Not Call List’ (DNCL)
- Canada’s Anti-Spam Legislation (CASL)
- Personal Information Protection and Electronic Documents Act (PIPEDA)
- The Voter Contact Registry
- Canada Elections Act
But before we begin – let us look at the basic rules governing a fundamental bedrock of any modern outreach campaign – phone banking campaigns using call center software.
Using robocalls and automated dialers in Canada
An automatic dialing–announcing device (ADAD) is used to make what are commonly referred to as robocalls.
Political campaigns and charities may make solicitation calls (where you are selling merchandise, tickets for dinner, or asking for donations to a cause) using robocalls only if the consumer has given their express consent before the call.
| Express consent means the campaign/organization must be able to show that the consumer has provided authorization to receive calls from an ADAD to a specific number. |
In other words, a campaign cannot blast out pre-recorded fundraising appeals to everyone via voice broadcast. They may only use robocalls for fundraising if each recipient has explicitly agreed to receive such calls from that campaign.
However, robocalls for non-solicitation purposes are permitted (for example, a recorded message from a candidate reminding people to vote).
When using robocalls or voice broadcasts, campaigns must adhere to strict requirements:
- The recorded message must immediately identify the caller and the organization on whose behalf it’s made and state the purpose of the call.
- It also must provide contact information (phone number and mailing address or email) valid for 60 days.
- Automated calls can only be placed within regulated time windows – between 9:00 am and 9:30 pm on weekdays and 10:00 a.m. to 6:00 p.m. on weekends (with any stricter provincial time limits taking precedence).
| Remember: Sequential dialing (calling numbers in automatic sequence) is banned, and robocalls must never target emergency lines or healthcare facilities. |
Charities are not exempt. The constraints on ADAD calls also apply to solicitations made by or on behalf of charities.
Read Also: The Complete Guide to Creating an Effective Robocall Campaign (Best Practices Included)
National ‘Do Not Call List’ (DNCL)
The DNCL is administered by the Canadian Radio-television and Telecommunications Commission (CRTC) and is a way for consumers to stop getting unwanted calls from businesses.
However, charities, political parties, candidates, and campaign teams are notably exempt from DNCL restrictions. The exemptions include unsolicited calls made by or on behalf of:
- Canadian registered charities
- Political parties, riding associations, and candidates.
- Persons or entities collecting information for a survey
- Newspapers of general circulation to solicit subscriptions
However, exemption from the DNCL does not mean exemption from all rules. Charitable and non-profit callers must still follow the standard telemarketing rules about identification, hours, and internal opt-out lists.
| CRTC unsolicited telecommunications rules |
| The CRTC’s Unsolicited Telecommunication Rules set requirements for any person or organization making such calls in Canada. This includes adherence to the National DNCL (avoiding calls to registered numbers unless exempt), respecting calling-time restrictions and caller identification requirements, and maintaining internal do-not-call lists. |
The CRTC explicitly notes that even exempt organizations must maintain an internal do-not-call list and refrain from calling people who asked not to be called.
If a contact receives a phone call from a political party or candidate and they are soliciting (e.g., requesting campaign donations), the contact can ask to be added to the campaign’s internal do-not-call-list. All campaigns are obliged to do so within 14 days.
Unlike registered charities, unions are not exempt from the DNCL simply by virtue of being a nonprofit. They would need to scrub call lists against the DNCL (unless targeting only those with whom they have an existing relationship) and adhere to call time and identification rules just like any business caller.
| Contacts may continue to receive calls from organizations conducting market research, polls, or surveys even though they are registered on the National DNCL. These calls are exempt from the national DNCL. |
Canada’s Anti-Spam Legislation (CASL)
CASL regulates commercial electronic messages (CEMs), including emails and SMS texts, to prevent unsolicited communication.
CASL provides a notable exemption for registered charities: any electronic message sent by or on behalf of a registered charity to raise funds is exempt from CASL’s consent and content requirements.
This is very useful for charities’ email and SMS campaigns – a donation appeal email sent to a list of potential donors by a charity does not require prior consent under CASL, and it doesn’t need an unsubscribe link (though including one is still a best practice).
Political communication via text (SMS) or email is largely exempt from CASL’s consent requirements as long as they are purely political in nature.
Most political messages (e.g., asking for support or discussing issues) are not considered commercial activity.
Even fundraising solicitations by a political party or candidate are specifically excluded from CASL’s rules under a regulatory exemption, provided the message’s primary purpose is to solicit a political contribution as defined in the Canada Elections Act.
This means a campaign can send voters texts asking for support or donations without prior opt-in consent or requiring an unsubscribe mechanism by law.
However, if a text message involves marketing (e.g., a fundraising event with a fee), CASL’s rules apply.
| Political entities are advised that if a message’s primary purpose is something other than soliciting a contribution – for instance, promoting a fundraising dinner with paid tickets or selling campaign merchandise – they should err on the side of compliance by obtaining consent and including opt-out features. |
Now, even though political messages may be exempt, it’s prudent to obtain consent before sending SMS messages to avoid potential issues – since a campaign really should not be annoying potential voters.
It is also good for all messages to clearly identify the sender and provide a straightforward method for recipients to unsubscribe from future messages.
Text messaging also involves telecom carriers’ policies: the Canadian Wireless Telecommunications Association (CWTA) issues guidelines for SMS short codes, requiring explicit consumer consent and opt-out instructions for mass texting programs.
Read Also: The Ultimate Guide To Help You Send Text Blasts Effectively
Unions typically qualify as associations, so if a person is a union member, the union has implied consent to send them CEMs for the duration of membership and for two years after it ends.
This means a union can email or text its current members’ information about union services or even partner offers without express consent, under CASL’s implied consent, as long as an unsubscribe is provided.
| Interestingly, this means a union can send a message to all members asking them to donate to a political party or vote for an issue in a particular way. This would not be considered ‘commercial’ activity. |
Read Also: Mass Texting for Unions to Improve your CTR: A Complete Guide
Personal Information Protection and Electronic Documents Act (PIPEDA)
PIPEDA governs personal information collection, use, and disclosure during commercial activities. While political activities may not be strictly commercial, adhering to PIPEDA principles is advisable.
These principles include:
- Obtain explicit consent if you plan to share data with third parties (e.g., campaign partners, fundraising platforms).
- Collect only the data necessary for your purpose (e.g., voter outreach, donation processing, member communication).
- Individuals have the right to access their personal information and request corrections. Implement procedures to handle data access requests efficiently.
The CRTC can issue a ‘Notice of Violation’ within 3 years of a CASL violation and within 2 years of a telemarketing violation (Telecom Act). So compliance records should be kept accordingly (e.g., keep telemarketing call logs for 2+ years).
The Voter Contact Registry for outreach in Canada
The CRTC is responsible for establishing and maintaining the Voter Contact Registry, which was created to ensure that those who contact voters during an election do so transparently. The Voter Contact Registry ensures transparency and deter ‘rogue’ robocalls.
It logs who is calling voters and is enforced alongside telemarketing rules.
Certain entities calling Canadians during an election period for any purpose related to an election must register with the Registry within 48 hours of making the first call.
Information required typically includes the organization’s name, the type of calls (live or automated), and who is being called (e.g., general electors or just members).
Registration is only open during an election period (the CRTC opens the registry when an election is called) and closes shortly after. There is no fee for registering with the VCR, and the registrations are eventually made public on the CRTC’s site (after the election) for transparency.
The Voter Contact Registry helps protect Canadians by:
- Imposing greater transparency and accountability on those who contact voters during federal elections.
- Helping investigate cases where rules about voter contact during federal elections have been violated.
- Ensuring compliance through the ability to issue monetary penalties of up to $1,500 per violation for individuals and up to $15,000 per violation for corporations and other groups.
This applies to political parties, candidates, and third parties (like unions or advocacy groups) that make live or automated calls to voters.
If they use automated dialing (robocalls) or hire an external call center, a registration notice is required both from the party and the call service provider.
Failure to register can lead to penalties. Campaigns thus need to budget time and resources to file these registrations promptly for each election outreach in Canada. (The registry is temporary for each election and clears afterward, requiring re-registration in the next campaign).
Calls made by a union advocating for an issue (e.g., ‘support workers’ rights – vote for Party X) are considered third-party political calls. During an election period, such calls trigger the Voter Contact Registry requirements – the union must register with the CRTC as it makes calls for an election-related purpose.
| No explicit federal rule forbids calls on statutory holidays, but many organizations avoid calls on major holidays to prevent backlash. |
Read Also: Master Patch Through Calls: A Guide for Advocacy Campaigns
Canada Elections Act for outreach in Canada
If unions engage in public outreach, especially on political matters, they also must consider the Canada Elections Act rules on third-party communications.
For example, if a union spends above a certain threshold on activities that qualify as “election advertising” (which could include mass calling campaigns that promote or oppose a candidate/party during the election period), they must register as a third-party with Elections Canada and are subject to spending limits.
Read Also: Political Campaign Advertising: Navigating Election Messaging
In the 2019 and 2021 federal elections, third-party advertisers (including labor groups) had spending limits in the tens of thousands for local campaigns and around a half-million dollars nationally. This effectively caps how much outreach (calls, ads, etc.) they can do during the regulated period.
Though these are campaign finance rules rather than telemarketing regulations per se, they critically shape how labor organizations plan their outreach around elections.
FAQs for outreach in Canada
Canada is a thriving democracy where dialogue, outreach, and political campaigning are a long and healthy tradition. So, the rules are in place to make it easy to reach those who wish to participate. Do not look at these rules as restrictions but rather as narrowing the field to those who will truly be influenced by your message. Outreach in Canada can be easy and fruitful.
Let us end with a quick round-up of the things you need to keep in mind:
- A charity can call anyone for donations without prior consent (DNCL exempt) but must immediately take anyone off their list if they ask.
- Charities can email/text for fundraising without prior consent (CASL exempt), yet charities typically still provide an opt-out in communications. If the charity sends newsletters or other non-fundraising content by email, they need consent or an implied relationship.
- A political campaign doesn’t need consent to call or text voters in most cases, but ethically, they add opt-outs. By law, they must identify themselves. If the campaign sends a message subject to CASL (say a candidate email advertises a book for sale), they’d need consent and unsubscribe options.
- A union or non-profit without special status should generally follow the business rules for marketing-like messages – get consent for mass emails and always provide an opt-out. If they’re just mobilizing people for a cause and not selling anything, they might not require CASL consent, but they should still heed opt-out requests to avoid alienating their audience.
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