CITIA Short Code Monitoring Program Short Code Monitoring Handbook Version 1.7 Effective Date March 27, 2017 INTRODUCTION CTIA and its member companies work to protect consumers while fostering a competitive environment for shortcode programs. We aim to ■ Provide consumers the best possible user experience; ■ Honor consumer choices and prevent abuse of messaging platforms; ■ Deliver flexible guidelines that communicate compliance values clearly; ■ Enable the short code industry to self-regulate; and ■ Facilitate enforcement measures, if necessary, to protect consumers quickly and consistently. The Short Code Compliance Handbook (Handbook) guidelines lay the framework for achieving these goals, butCTIA reserves the right to take action against any short code program deemed to cause consumer harm. The Handbook is not intended as a comprehensive guide to compliance with laws and regulations that apply toshort code programs. Service providers are responsible for meeting legal requirements that apply to short codeprograms they offer, and CTIA and its members make no representation that meeting the guidelines in this Handbook is sufficient to assure legal compliance. Consultation with legal counsel is recommended stronglly. ABOUT THIS HANDBOOK This Handbook describes best practices for standard rate messaging services (SMS), multimedia messagingservices (MMS), and free-to-end user (FTEU) short code programs with the primary goal of providing the best customer experience for users. Handbook guidelines do not define rules for programs that bill consumers. Guidelines are organized according to use cases that apply. Examples of compliant programs are organized byuse case in the appendice Carriers reserve the right to implement their own short code program requirements beyond the scope of this Handbook. However, all carriers have reviewed and accepted the Handbook’s content. This Handbook is divided into the following sections: Compliance Framework, In-Market Monitoring Guide, Audit Standards Guide, and Audit Standards. In addition, Appendix A and Appendix B detail sample compliant programs, and Appendix C describes common terms. REFERENCES Drawing from experience working with short code programs, the guidelines evolve continually. Handbook vl .7 is based on the following: ■ Mobile Marketing Association’s Consumer Best Practices v7.0, ■ CTIA Mobile Compliance Assurance Handbook vl .3, ■ California Attorney General Kamala D. Harris’s “Privacy on the Go: Recommendations for the Mobile Ecosystem” best practices, ■ Telephone Consumer Protection Act (TCPA),2 ■ Florida Attorney General’s requirements for mobile content, ■ A2P (application-to-person) community feedback, and ■ Carrier requirements COMPLIANCE FRAMEWORK This section offers direction regarding compliance of short code programs, including guidelines and requirements. Nonetheless, following this handbook is no guarantee that a short code program is compliant. Short code programs might also need to comply with individual carrier requirements. UNIVERSAL COMPLIANCE PRINCIPLES CTIA requires all short code programs to comply with a basic code of conduct that promotes the best possible user experience. As new uses for short codes emerge, the guiding principles in section A.1 should be considered when defining applicable rules. Short code programs that comply technically with the letter of a specific rule but violate the letter or spirit of these principles might be subject to enforcement action. A.1 GUIDING PRINCIPLES Four principles provide the baseline for all requirements listed below 1. Display clear calls-to-action. All programs must display a clear call-to-action. Customers must be made aware of what exactly they are signing up to receive. 2. Offer clear opt-in mechanisms. Customers must consent clearly to opt into all recurring-messages programs. Requiring a customer to enter a mobile phone number does not constitute a compliant opt-in. Instead, customers must understand they will receive messages and consent to receive them. 3. Send opt-in confirmation messages. A confirmation message must be sent to customers always. For recurring-messages programs, confirmation messages must include clear opt-out instructions. 4. Acknowledge opt-out requests. Short code service providers must acknowledge and act on all opt-out requests. Monitoring procedures confirm successful opt-out. A.2 CHOICE AND CONSENT Short code programs are expected to deliver sufficient value so consumers elect to participate with full transparency into the delivery conditions. A.2.01 UNSOLICITED MESSAGES Unsolicited messages may not be transmitted using short codes. Unsolicited messages are defined as follows: ■ Messages delivered without prior express consent from the user or account holder, and ■ Messages sent after a user has opted out. A.2.02 MARKETING CONTEXT No component of program advertising or messaging may be deceptive about the underlying program’s functionality, features, or content. All disclosures present in pre-purchase calls-to-action, advertisements, terms and conditions, and messages must remain clear and consistent throughout the user experience. A.2.03 OPT-IN Messages must be delivered to a consumer’s mobile device only after the user has opted in to receive them. A user might indicate interest in a program in several ways. For example, a user might ■ Enter a phone number online, ■ Click a button on a mobile webpage, ■ Send an MO message containing an advertising keyword, 3 Sending the user a single opt-out message acknowledging the opt-out request is the only exception to this rule. ■ Sign up at a point-of-sale (POS) location, or ■ Opt in over the phone using interactive voice response (IVR) technology. Calls-to-action must be clear and accurate; consent must not be obtained through deceptive means. For example, opt-in details cannot be displayed obscurely in terms and conditions related to other services. Enrolling a user in multiple short code programs based on a single in is prohibited, even when all programs operate on the same short code. Recurring-messages short code programs should send a single opt-in confirmation message that displays information verifying the customer’s enrollment in the identified program. The opt-in confirmation message must be delivered immediately after the customer opts into the program. For POS and hardcopy opt-ins, the opt-in confirmation message must be delivered as soon as is reasonably possible after the customer opts into the […]
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