On 2020-06-05 10:09 a.m., Atro Tossavainen via mailop wrote:
Furthermore, I explicitly indicated that it was the consensus that the
GDPR makes it effectively impossible for them to do what you believe I
said, which I did not. It has been discussed in so many M3AAWG meetings
and between meetings, and Simon McGarr's talk "So you want to be a data
controller" was more or less on this subject.
I don't know how you have managed to read exactly the opposite of my
intentions into my words, I can only conclude that it must have to do
with my awkward non-native use of the language because all other
explanations seem so futile. Here is what I said, for a recap.
Most ESPs want to remain as data processors under GDPR and do not want
to be put in a position of being a data controller. Utilizing data
across multiple accounts has some very interesting impacts in regards to
the responsibility of the controller/processor or controller/controller
relationships of data.
As for ESPs and the emails that they process on behalf of their clients,
bounces are processed and removed but each ESPs has different thresholds
for how this should be done - business logic and all.
* ESP1 - might remove from an individual list, but nothing stops a
client from uploading a new list every time they mail. Thus giving
the appearance of neglecting bounces.
* ESP2 - might remove only after a third consecutive 5.x.x where it is
clear the user is unknown - This addresses Luke's comments on
bounces for things like account disablement/re-activation for
billing issues
* ESP3 - Might bounce an address at the client level, but allow a
brand to over write that flag with a new upload
* ESP 4 - might not allow people to re-enable bounces ever...
* ESP5 - might suppress multiple bounces from multiple clients across
the board for all accounts <<< This has significant GDPR
implications that the individual client suppression doens't.
* ESP x - might do some or all of the above...
I've seen all of these scenarios over the years, each has a different
benefit/risk - but what I can say is that every ESP I've ever worked
for/with had a different way of doing this. But they all processed
bounces as best they could and updated their rules on regular timelines.
Why? Because the standards for bounces get applied in wonky ways at each
ISP - so really the standard is non-standard.
This is as much a client education piece as it is an industry
implementation piece. If every ESP knew that 5.5.1 meant the exact same
thing then they could treat them all the same, but having seen '4.5.1
Unknown user', and '5.5.0 - Try again later' errors over the years ESPs
work with the data they are given to the best of their abilities and
within the laws that are applicable to them and their clients.
I recommend you try working with them vs calling them out as being bad
actors - These teams (especially the Mailchimp team) works very hard,
harder than most hosting companies i would imagine, to stop abusive
behaviour from their networks sending billions of emails around the
world. From stopping fraudulent sign-ups to, stopping the use of
purchased lists, to shutting down accounts that get complaints - mind
you much faster than many other companies that might be part of the same
abusive message on the content hosting or domain hosting side of the house.
--
~
MATT
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