Self-audit
Five questions, each a yes or a no. Answer them about the program you run today. The verdict is the count, and it is the same test the definition uses.
Does outbound run from its own subdomain, with its own mailboxes and DNS records, so nothing about it can touch the domain that carries your invoices?
Does every address carry how it was obtained, and do you send only to addresses published on the company's site or verified by its mail server?
Is each mailbox's daily volume set by a reading of where its mail actually lands, taken against real inboxes, rather than by a number someone chose?
Does the next message depend on what the person did, and does any reply stop the sequence at once?
Before a send, can you trace it to a written profile, a rubric score and a sourced address, and would the send be blocked if it could not?
Answer all five for a verdict. 0 of 5 so far.