EXIM - append advert - and UK legal disclosure requirement

[Gary Stainburn]

Hi Alan.

On Wednesday 30 July 2008 10:10, you wrote:
> On Wed, 30 Jul 2008 09:53:37 +0100
>
> Gary Stainburn <gary.stainburn at ringways.co.uk> wrote:
> > Hi folks.
> >
> > I've been asked to add a gif containing an advert to all outgoing emails.
> >
> > Anyone got any ideas how to do this using Exim?
>
> Its not doable. You can botch it but it will cause badness. Technically
> it doesn't work out sanely, and you might want to seek legal advice on
> some other points...

I know, I know :)

I still have to do it.

I'm still working on writing a perl script to work on a transport_filter.  
Using an Exim FAQ I've added the code to the exim.conf so that the filter is 
only called in the remote_smtp_filter transport which is only called when 
emails from the ringways.co.uk  (we do host other domains on our work 
server).

The legal aspect is vague at best, and because it's an advert and not a 
disclaimer, much of the existing concerns don't count anyway.

>
> > I need to be able to add the gif reliably catering for plain text, HTML
> > and MIME.
>
> For the plain text case it isn't supported. For MIME you would need to
> decide what to add it to and for HTML you will need to parse the entire
> HTML document (remembering it may not be a fully valid SGML document),
> analyse it somehow to deduce where to place the image in the document
> validly so it will be seen and then add it. You'll then need to convert
> the mail to mime multipart and add the image section as mailers won't
> fetch images over the web.

This is my biggest concern and my biggest head-ache.  I'm having fun with this 
bit.

My choices for plain text were to 

1) just add a header and a URL to the same advert on our web site 
		http://www.ringways.co.uk/gotopless.php

2) Add the advert as a UUENCODED file and hope the mail client decodes it

3) Convert the email to MIME

None of the options are idea, but although being the harder (3) is probably 
going to be the more reliable option (Yes/No?????)

> As you are in the UK you also want to consider
> - That adverts in mail sent outgoing to people who are not currently in
> business with you with an existing relationship may contravene the
> regulations on e-commerce and email.

The advert and the promotion is open to anyone so this isn't an issue.

> - That if you mangle email you will break any digital signatures on
> emails.

Although a technical problem, we don't sign emails here, so not a real issue.

> - That adding your advert to a third party work may contravene the
> copyright act.

It would be appended to emails originated here, so even if replying for 
forwarding, I would be amending something created here.

> - That adding your advert to material you are forwarding which is for
> another bodies trademarked product may place you in conflict with
> trademark law.

Provided the advert was added appropriately, this should not be a problem for 
the same reason as above.

> - That some of your customers will probably drop all mail with images as
> spam

True, but I would imagine (based on nothing much really) that this would be a 
low percentage.

>
> > Also, I'd like to have a whitelist and add other filters so that it
> > doesn't get added to internal emails or existing business partners,
> > .vacation messages, Bulk emails (which we don't do, but would be nice to
> > cater for anyway) and mailing list stuff.
>
> I think you have it backwards. I do not believe you can generally
> advertise except in existing customer relationships without permission -
> but you should consult your company lawyer on that matter.

The company want to send this to everyone, but I want to try to eliminate 
emails that are obviously not appropriate, such as email to mailing lists (I 
don't want to send emails to here for example).  

>
> > The main question is does anyone have any good examples of how to mangle
> > outgoing emails - I figure it's going to be something to do with the smtp
> > transport as that would immediately ignore all local deliveries
>
> What you can do (and as a business may in some cases have a legal duty to
> do) is to add identifiers for the business - see the recommendations on
> the companies house site. Adding a new header such as Organization: is
> relatively easy to do.

This is something I have never considered. The section on Trading Disclosures 
on the page below is an interesting one, and could impact on a hell of a lot 
of postmasters.

http://www.companieshouse.gov.uk/companiesAct/implementations/oct2008.shtml

Would just adding the company registration and address to the headers suffice, 
or even easier, a link to the relevent page on our web site?

>
>
>
> Alan

-- 
Gary Stainburn
 
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