Hello David,

thanks for the welcome. :)
About your questions:

- Complaint policy: We distinct between two different types of complaints. 
First we have what we call a "spam click". That's basically FBL data. These are 
completely anonymous of course. We simply see "spam click rates" and act if the 
rate of spam clicks in comparison to the number of emails received exceeds a 
certain threshold.
The other kind of complaints are individual user complaints. This is a whole 
different topic, because if someone tells us "Hey, I just received an email 
from someone I never gave my consent to" that's way more serious than a simple 
click in a webinterface from my ISP which can happen by accident.
But in these cases, there are still "false positives", like people who forgot 
that they subscribed, people who received kind of embarrassing content, like 
the newsletter from a dating site, and get caught by somebody who shouldn't 
know it. So the complaint team checks these complaints and works with the 
complainant and the ESP (who did send the email in behalf of e.g. the dating 
site) to find out the exact cause of the problem so it can be fixed. Most of 
the time, if there is a real issue with the opt-in process of a sender the 
complaint team receives multiple complaints for the same sender in a short 
period of time. That's why not every complaint gets feedback but is still used 
and highly appreciated.
Anyway.. as we operate in Germany and take data protection very serious we ask 
the complainant for explicit consent to allow us to share his personal 
information (his email address) with the ESP who sent the email to work on the 
issue. So from a process perspective and a legal perspective, these individual 
user complaints can't be handled anonymously.

-Oversight: Yes, of course. We have people and tools who check that. But of 
course we never see the full picture of each and every single email sent by 
every certified sender. Hints from receivers are also highly appreciated.

-Unsubscribing: 
- Size of message: I'm not sure how we should handle this. The sender/ESP did 
send out a correct message, but Google decided to cut off content. Who's to 
blame? 
- List-Unsubscribe: Of course we check every ESP in the certification process. 
But we can't check and monitor every single sent message. This goes back to the 
"Oversight" question. If we see this in our monitoring, or if we get the hint 
by a receiver we can work on that. I'd like to contact you off-list about the 
samples you showed, so we can take actions against the responsible sender.

- Leadership: As you can see by Tobias reaction, the opinions around 
authentication differ. To make that clear: The CSA criteria are not made up by 
me and my colleagues, nor are they based on opinions. They are the results of 
the different needs and requirements by all participating ISPs and technology 
partners. We gather all the feedback, try to find the best possible solution 
and discuss them with our partners, again. Finally every change made to the 
admission criteria need to be approved by the CSA committee, who I mentioned 
early consists of two ISP partners and two ESPs. Right now SPF and DKIM are 
mandatory for CSA senders. DMARC, or DMARC-ish authentication by alignment 
might be in the criteria in the future, or it might not. It depends on the 
feedback by our ISP and technology partners.

Best
Alexander

> Am 02.11.2017 um 11:19 schrieb David Hofstee <opentext.dhofs...@gmail.com>:
> 
> Hi Alexander,
> 
> Welcome to Mailop. A few somewhat criticising questions on the CSA:
> - Complaint policy: What is the complaint policy for recipients? I tried to 
> find it, but could not. Is anonymity guaranteed? Also not available in the 
> data protection policy as found on the website. Please consider creating one.
> - Oversight: Do you have a group of people that monitor compliance of senders 
> (and not just complaints)?
> - Unsubscribing. I subscribed to a few newsletters but I seem to notice a 
> high "does not follow policy"-rate. Two examples (of 3 subscriptions, headers 
> provided below): 
>      - Size of message: Google clips large messages. This is often where the 
> unsubscribe link is. I did not see an unsubscribe link in this message.  
>      - List-Unsubscribe: Missing the required URL (requirement 2.21 of your 
> admission criteria, see 
> https://certified-senders.org/wp-content/uploads/2017/07/CSA_Admission_Criteria.pdf
>  
> <https://certified-senders.org/wp-content/uploads/2017/07/CSA_Admission_Criteria.pdf>
>  ). Were these not tested at admission?
> - Leadership: I think the authentication requirements in your policy are 
> outdated. An ESP does not even need to support DMARC-type authentication nor 
> is it a requirement for its customers to prove they are the real senders. Do 
> you agree? Do you think the CSA should lead in setting requirements on these 
> topics? Is the CSA able to change such requirements? Or is the CSA afraid of 
> the current customer base (who might protest to adding authentication)? I 
> would like to hear CSA's opinion on that.
> 
> Yours,
> 
> 
> David 
> 
> Example of message too large; the unsubscribe link is no longer visible in 
> Gmail:
> X-CSA-Complaints: whitelist-complai...@eco.de 
> <mailto:whitelist-complai...@eco.de>
> MIME-Version: 1.0
> Content-Type: multipart/mixed; boundary="----msg_border_bwvxxxxx"
> Date: Thu, 14 Sep 2017 22:01:07 -0700
> To: xyz
> From: HSE24 TV Programm <newslet...@angebote.hse24.de 
> <mailto:newslet...@angebote.hse24.de>>
> Reply-To: HSE24 TV Programm <serv...@hse24.de <mailto:serv...@hse24.de>>
> Subject: Hui...jetzt wird's richtig stylisch
> 
> Example of List-Unsubscribe not having URL:
> Date: Wed, 25 Oct 2017 15:01:33 +0000 (GMT)
> From: TUI <t...@email.tui.nl <mailto:t...@email.tui.nl>>
> Reply-To: t...@email.tui.nl <mailto:t...@email.tui.nl>
> To: xyz
> Message-ID: <43699742.JavaMail.app@rbg62.f2is>
> Subject: Welkom bij TUI
> MIME-Version: 1.0
> Content-Type: multipart/alternative; 
> boundary="----=_Part_334583_459599753.150234563453456"
> x-mid: 2369485
> X-CSA-Complaints: whitelist-complai...@eco.de 
> <mailto:whitelist-complai...@eco.de>
> x-rpcampaign: sp2375598
> Feedback-ID: pod6_15062_2375598_891291414:pod6_15062:ibmsilverpop
> x-job: 2375598
> x-orgId: 15062
> List-Unsubscribe: <mailto:v-removed-for-an...@bounce.email.tui.nl 
> <mailto:v-removed-for-an...@bounce.email.tui.nl>?subject=Unsubscribe>
> 
> 
> On 1 November 2017 at 17:33, Alexander Zeh <alexander....@eco.de 
> <mailto:alexander....@eco.de>> wrote:
> Hello everyone,
> 
> a friend informed me about a topic going on about the Certified Senders 
> Alliance on this mailing list. That’s why I joined it.
> I work for the CSA for many years now. 
> First and foremost of all: 
> It is definitely not true that a sender can join the CSA without any vetting. 
> That statement bothered me a lot, because it’s a plain lie. Maybe because 
> important information was lost in some communication between more than two 
> parties, I don’t want to assume ill intent by anybody. In fact from every 
> sender who wants to get certified and be whitelisted only about 10% make it 
> through the whole process and are approved. Btw: the certification needs to 
> be confirmed by the certification committee in which 2 seats out of 4 are 
> major ISP partners. 
> I totally agree that if you have delivery issues it shouldn’t be the first 
> step to reach out any certification program to fix it. And this is not how 
> CSA works. If a sender has delivery issues, in 99% these problems are 
> justified and self made. So what the CSA does is, that in the process we find 
> potential issues and help senders to align with current best practices aka. 
> the CSA admission criteria.  This whole process can take weeks and months and 
> still many senders don’t achieve a certification in the end, because we take 
> that very serious. 
> Anybody on this mailing list, please feel free to have a look at our criteria 
> and see for yourself if they are reasonable or not. As everything we do is 
> completely transparent, you can find them on 
> https://certified-senders.org/library <https://certified-senders.org/library> 
> either at the end, or you can select the type “CSA specific” to filter. 
> 
> Sorry about this rant-ish post, but we try our best to improve overall 
> quality of senders, so the initial post kind of annoyed me. 
> 
> Anyway. I am open for discussion either here, direct with me or for example 
> on the next M3AAWG meeting in person. 
> 
> Best
> Alex
> 
> -- 
> 
> Best regards
> 
> Alexander Zeh
> 
> Engineering Manager
> 
> ---------------------------------------------------
> 
> eco - Association of the Internet Industry
> Certified Senders Alliance
> 
> Lichtstrasse 43h
> 50825 Cologne
> Germany
> 
> phone: +49 (0) 221 - 70 00 48 - 171 <tel:+49%20221%20700048171>
> fax: +49 (0) 221 - 70 00 48 - 111 <tel:+49%20221%20700048111>
> mobile: +49 (0) 171 - 657 2628 <tel:+49%20171%206572628>
> e-mail: alexander....@eco.de <mailto:alexander....@eco.de>
> web: http://www.eco.de <http://www.eco.de/>
> 
> ---------------------------------------------------
> 
> eco - Association of the Internet Industry
> CEO: Harald A. Summa
> Executive board: Prof. Michael Rotert (Chairman), Oliver Süme (Deputy
> Chairman), Klaus Landefeld, Felix Höger, Prof. Dr. Norbert Pohlmann
> Register of Associations: District court (Amtsgericht) Cologne, VR 14478
> Registered office: Cologne
> 
> _______________________________________________
> mailop mailing list
> mailop@mailop.org <mailto:mailop@mailop.org>
> https://chilli.nosignal.org/cgi-bin/mailman/listinfo/mailop 
> <https://chilli.nosignal.org/cgi-bin/mailman/listinfo/mailop>
> 
> 
> 
> 
> -- 
> --
> My opinion is mine.

-- 
Best regards

Alexander Zeh

Engineering Manager

---------------------------------------------------

eco - Association of the Internet Industry
Certified Senders Alliance

Lichtstrasse 43h
50825 Cologne
Germany

phone:  +49 (0) 221 - 70 00 48 - 171
fax:    +49 (0) 221 - 70 00 48 - 111
mobile: +49 (0) 171 - 657 2628
e-mail: alexander....@eco.de
web:    http://www.eco.de

GPG fingerprint: ADEA 1BF7 1D2E 670B EB51  0C54 7A45 64E2 A167 37EF

---------------------------------------------------

eco  Association of the Internet Industry
CEO: Harald A. Summa
Executive board: Prof. Michael Rotert (Chairman), Oliver Süme (Deputy
Chairman), Klaus Landefeld, Felix Höger, Prof. Dr. Norbert Pohlmann
Register of Associations: District court (Amtsgericht) Cologne, VR 14478
Registered office: Cologne

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