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Can I configure nudges for Career Development goals if we dont have Touchpoints?

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We would like to enable nudges to email the employee and manager with various Career Development goal activity (or lack of).

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I have read in the documentation for 23A that you need Touchpoints to use nudges for Development Goals, is that the case? or can we still use nudges sent via email for Development Goals.

We don't have the subscription for touchpoints.

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