Overview
If your business sends SMS messages to mobile phone subscribers in the US, recent critical changes in the industry will affect you.
In short: All business-related SMS/MMS messages sent by any 3rd party application, including 8x8 Work, are now classified as Application to Person (A2P) traffic. Mobile phone service providers (AT&T, T-Mobile, Verizon, etc) are taking strict action to control the type and quality of A2P messages that their subscribers receive.
This article provides key information and requirements of the CTIA guidelines that you as a sender of SMS/MMS messages (using your 8x8 service) should be aware of to ensure that your messages remain supported by wireless service providers.
Note: For the purpose of this article, we are using the term Consumer to mean mobile phone subscriber.
Applies To
- 8x8 SMS
- SMS Campaigns
Consumer Consent
As a sender of business SMS/MMS messages, 8x8 customers must obtain their customer’s consent to send such messages to them. Mobile phone service carriers can request an Opt-In audit – and could act on the results of that audit – so tracking and saving a record of your customer’s consent is very important.
There are different ways that you can manage and collect your customer’s consent to receiving SMS/MMS traffic.
Important: About Reply Automation
8x8's SMS service does not provide any message response automation.
This means that when 8x8 customer users receive SMS messages, including Opt-In or Opt-Out messages sent from consumers, 8x8 users must manually respond to those messages when needed.
Implied vs Express Consent
There are two types of methods for obtaining consent from your customers:
- Implied consent is when the consumer initiates the SMS conversation. Implied consent only applies to the topic the consumer is inquiring about when they initiated the SMS conversation.
- Example: If a consumer sends an SMS inquiring about the price of a specific product then the customer is able to respond to said inquiry by responding with the price for that specific product.
- Express consent is when the customer collects explicit permission from their consumer regarding receiving SMS communications.
- Example: When a consumer provides their phone number as a contact information, the customer should make sure to collect permission to send SMS if they plan to communicate with the consumer via SMS. This permission can be collected via paper form, web form, or over SMS Text.
Customers should ensure to keep a record of this consent in case a mobile carrier requests for proof consent. This usually will happen if the consumer reports incoming SMS text as SPAM and the customer can use this consent to prove that they did receive consent from the consumer to receive the SMS Texts.
Important: Customers should always make sure that consumers have the ability to revoke consent via some method of Opt-Out mechanic.
Consumer Opt-In
8x8 customers should provide their customers (consumers) with opt-in mechanisms, and messages should be sent to these customers only after they have opted-in to receive them.
- Opt-in procedures reduce the likelihood that a consumer will receive an unwanted message.
- They can also help prevent messages from being sent to a phone number that does not belong to the consumer who provided that phone number; for example, if a consumer purposefully or mistakenly provides an incorrect phone number to you, the Message Sender.
Opt-In Methods
Depending upon the circumstances, a consumer might demonstrate opt-in consent to receive messaging traffic through several different ways.
Important: 8x8 customers should make sure to explain all Opt-In methods in the Call-to-action workflow field of the 8x8 Admin Console SMS > Campaign form when they create their campaigns. At least one method must be employed.
Opt-In Data Retention
Regardless of the Opt-In method employed, 8x8 customers should also document opt-in consent by retaining the following data where applicable:
- Timestamp of consent acquisition
- Consent acquisition medium (e.g., cell-submit form, physical sign-up form, SMS keyword, etc.)
- Capture of experience (e.g., language and action) used to secure consent
- Specific campaign for which the opt-in was provided
- IP address used to grant consent (if using web medium)
- Consumer phone number for which consent to receive messaging was granted
- Identity of the individual who consented (name of the individual or other identifier (e.g., online user name, session ID, etc.)).
Consumer Opt-out
Opt-out mechanisms facilitate Consumer choice to terminate messaging communications, regardless of whether they have consented to receive the message previously.
8x8 customer should acknowledge and respect Consumers’ opt-out requests consistent with the following guidelines:
- Message Senders should ensure that Consumers have the ability to opt-out of receiving messages at any time.
- Message Senders should support multiple mechanisms of opt-out, including phone call, email, or text.
- Message Senders should acknowledge and honor all Consumer opt-out requests by sending one final opt-out confirmation message per campaign to notify the Consumer that they have opted-out successfully.
- No further messages should be sent following the confirmation message.
Opt-Out Content
Message Senders should state in the message how and what words affect an opt-out:
Standardized “STOP” wording should be used for opt-out instructions. However, opt-out requests with normal language (i.e., stop, end, unsubscribe, cancel, quit, “please opt me out”) should also be read and acted upon by a Message Sender except where a specific word can result in unintentional opt-out.
The validity of a Consumer opt-out should not be impacted by any de minimis variances in the Consumer opt-out response, such as capitalization, punctuation, or any letter-case sensitivities.
Inappropriate Use-Cases
Due to high volume of consumer complaints, messages containing the following content are considered as not appropriate by mobile service providers and may be blocked regardless of opt-in status.
If messaging traffic is identified by mobile service providers as associated with one of the following use cases, there is unfortunately nothing 8x8 can do to assist in the removal of blocking.
Category | Examples | Notes |
---|---|---|
High-risk financial services |
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“Third-party” means originating from any party other than the one which will service the loan. SMS messages featuring financial investment advice or tips, as well as information on loans and refinancing options, are prohibited. Carriers also prohibit messages with links to donation sites. |
Third-party lead generation services or affiliate services |
|
Buying, selling, or sharing of consumer data is strictly prohibited. The business that obtained consent is the only business authorized to send SMS. “Cold” outreach is the solicitation of business from potential customers who have had no prior contact with the business and is strictly prohibited. |
Debt collection or forgiveness |
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Almost all debt consolidation and forgiveness efforts are prohibited for SMS and MMS. Regarding debt collection, the business owed the debt can send payment reminders to late payers, personalized messages with account details, and follow up on payment confirmations. However, a third party cannot attempt to collect the debt for you via SMS and MMS. This also applies to financial services consultation companies that redirect their customers to other affiliate service providers for financial products. |
"Get rich quick” schemes or Multi-level marketing |
|
Multi-level marketing (MLM) products, services, or content commonly associated with unsolicited commercial messages (spam) are prohibited. This is different from outreach about employment as a result of compliant opt-in practices, messages from brokerages to their members, investment news alerts, or other investment-related messages. |
Illegal / Controlled substances |
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Cannabis is federally illegal in the United States. Cannabis businesses will not be permitted to use SMS/MMS messaging in the US, regardless of message content. CBD is federally legal, but is not legal in some US states, so US carriers do not permit messaging related to CBD. Offers for drugs that cannot be sold over-the-counter in the US/Canada are forbidden. |
Gambling |
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Approved at the carrier’s discretion. Strong Age-gating required. |
"S.H.A.F.T." use cases |
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Tobacco and Alcohol can be approved at the Carrier’s discretion. They do however require strong Age-gating in order to even be considered. Vaping-related traffic is prohibited. |
Job Postings |
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Third party job boards are disallowed. Only the hiring brand itself should be registered. This restriction is due to concerns about potential misuse, information sharing, and high rates of spam complaints associated with third-party job boards. As a result, carriers do not permit this use case on their networks. |
Campaign Registration
This section refers to the SMS campaign registration process, itself, in the 8x8 Admin Console > SMS form.
Important: All campaigns are vetted before they can be used to assign phone numbers!
Brand information and online presence
Brand must be verified before customers can register for a campaign. During Brand verification, make sure to provide a website URL that shows your company's online presence. This can be the company website or community URL that represents your business. E.g. Etsy storefront, Yelp business page, etc This will be used to validate your business and the type of communication you’re trying to send out.
Campaign Description & Use Case
The campaign description should clearly explain for what purpose the messaging is being used by the company.
For example: If being used for customer care/account notification:
- Description: Communication with customers for account updates, delivery notifications and issue resolution.
Call-to-action
This field should describe how a consumer opts-in to the campaign, therefore giving consent to the sender to receive their messages. The call-to-action must be explicitly clear and inform the consumer of the nature of the program. If multiple opt-in methods can be used for the same campaign, you must list them all. Opt-in methods include, but are not limited to:
- Entering a telephone number through a website
- Clicking a button on a mobile webpage
- Sending a message from the Consumer’s mobile device that contains an advertising keyword
- Initiating the text message exchange in which the Message Sender replies to the Consumer only with responsive information
- Signing up at a point-of-sale (POS) or other Message Sender on-site location
- Opting-in over the phone using interactive voice response (IVR) technology
Opt-In, Opt-Out, Help Keywords and Messages
8x8 SMS functionality does not automate any of the following.
Given the nature of our SMS use case, SMS users should be trained to respond appropriately, depending on which keywords are triggered by the consumer or your customer.
Keywords are generally standardized to the following. We recommend using these for most of the cases:
- START (Opt-In)
- STOP (Opt-Out)
- HELP (Help)
Keyword messages should be used by 8x8 customers to respond to their customer (consumers) when any of the keywords are triggered.
Below are some recommendations on how to make sure you have the proper messages templates:
- Opt-in (initial message): Program/brand name, msg frequency, pricing disclosure, help info, stop info
- Help response: Program/brand name, contact info (phone number, email and/or support website URL)
- Stop response: Program/brand name, confirmation that user has unsubscribed and will not receive any more messages
Sample Messages
The sample messages should be specific, detailed messages representing the type of messages that would be sent from the campaign. It should also include as much as possible of the following to help the consumer understand why they’re receiving an SMS:
- Brand name, website, call to action, opt-out/help language
- Confirming content does not fall into disallowed content
- Confirming HELP and STOP flow in template messages
For example, if being used for customer care:
- Sample Message 1: Thank you for contacting [Company Name]. We will get back to you as soon as possible. Reply STOP to opt-out.
- Sample Message 2: HI [name]. [Company Name], Just reaching out to remind you that your invoice payment due date is June 1. Reply STOP to opt-out.
- Sample Message 3: Hey [name], great news! Your [Company Name] order is on its way! Reply STOP to opt-out.
- Sample Message 4: Hi [name]. We are sorry to hear that you're having an issue with your [Company Name] product. Please respond with additional information for our service representatives to help resolve this for you. Reply STOP to opt-out.
Note: If your organization is collecting phone numbers, you will need to add disclaimers with a link to your Privacy Policy. Below are samples for both, with the wording the carriers expect to see:
Disclaimer Sample: "By providing my phone number to “Company Name”, I agree and acknowledge that “Company Name” may send text messages to my wireless phone number for any purpose. Message and data rates may apply.
Disclaimer Sample: "By providing my phone number to “Company Name”, I agree and acknowledge that “Company Name” may send text messages to my wireless phone number for any purpose. Message and data rates may apply.
Message frequency will vary, and you will be able to Opt-out by replying “STOP”. For more information on how your data will be handled please visit (PRIVACY POLICY) (LINK attached)."
Privacy Policy Sample: "No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."
Privacy Policy Sample: "No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."
Campaign Rejection Reasons
Rejection Code | Description | Recommendation |
---|---|---|
601 |
Campaign Attributes do not match website and/or sample message content/601 |
Make sure you’ve checked the correct content attribute in your campaign. Example, if your company is a mortgage company you should check off the Direct Lending and Loan arrangement option. Note: Due to TCR limitation these attributes are not editable post campaign creation. If you need to make a change on this, reach out to Support. |
602 |
Inaccurate Registration. Inconsistency between sample message and use-case/602 |
Review your sample messages and make sure they’re aligned with your campaign description on how you use your SMS. |
603 |
Inaccurate Registration. Inconsistency between website, brand name and/or sample messages or inconsistent sample messages./603 |
Carriers will check everything from your Brand and Campaign registration to make sure they’re aligned well. For example, if your website says you're a lawyer’s office, your sample message should reflect that and not that of a doctor’s appointment confirmation. |
701 |
Prohibited Content; Cannabis/701 |
Cannabis/CBD/Hemp is not allowed. Remove all references to it. Note: This includes your website as it is part of what carriers use to check and confirm your business registration. |
702 |
Prohibited Content; Guns/Ammo/Fireworks 702 |
Firearms and ammo is not allowed. Remove all references to it. Note: This includes your website as it is part of what carriers use to check and confirm your business registration. |
703 |
Prohibited Content; Explicit sexual/703 |
Sexual and explicit content is not allowed. Remove all references to it. Note: This includes your website as it is part of what carriers use to check and confirm your business registration. |
704 |
Prohibited Content; Gambling/704 |
Gambling is not allowed. Remove all references to it. Note: This includes your website as it is part of what carriers use to check and confirm your business registration. |
705 |
Prohibited Content; Hate/705 |
Hate content is not allowed. Remove all references to it. This includes but not limited to racism, sexism, xenophobia, etc. Note: This includes your website as it is part of what carriers use to check and confirm your business registration. |
706 |
Prohibited Content; Alcohol/706 (Failure to age gate} |
Campaign related to Alcohol content need to have Age-Gated content attribute selected and make sure proper age-gating process is in place. |
707 |
Prohibited Content; Tobacco / Vape/707 {Failure to age gate} |
Campaign related to Tobacco content need to have Age-Gated content attribute selected and make sure proper age-gating process is in place. |
708 |
Lead Gen/Affiliate Marketing prohibited; other/708 |
Remove any language that is lead-related or referral messaging to other third-party companies from your sample messages. |
709 |
Lead Gen/Affiliate Marketing prohibited; high risk financial services/709 |
You can’t use SMS messaging to generate leads for hedge funds, stock market investments, etc. Remove any mention of these from your sample messages. |
710 |
Reseller / Non-compliant KYC. Register the brand info, not the agency or software provider behind the brand |
Register the actual company that will be sending the SMS. Example, if you’re an IT company registering for your customer who is a doctor’s office, you need to register at the doctor’s office and not your IT company. |
711 |
Repeated use of same EIN for multiple different brands/711 |
One EIN can only be registered for one brand. If you have multiple brands they should each have their own EIN. |
712 |
Misleading Registration. Based on details submitted, Campaign appears to be Direct Lending Arrangement but appropriate Content Attribute was not selected./712 |
If you’re a direct lender, make sure to select Direct Lending or Loan Arrangement under the content attribute for your campaign. |
713 |
Appears to be a large company or company that would have an official email domain. Check for fraud, use official / working email domain./713 |
Email address used should be of the company domain. |
803 |
Opt-in language is required on website if used to collect mobile numbers./803 |
If your website collects phone numbers as part of a form or contact us page, make sure it includes the proper SMS consent language on the page. |
804 |
Unable to verify, need website / working website or complete CTA information if opt-in occurs outside of website/804 |
Re-review your website and Call to Action and make sure it’s clear how you’re collecting consent to send SMS to your customers. |
Additional Information
8x8 Knowledge Base
- SMS Campaign Registration and Impact
- SMS Campaign Registration Admin Console Configuration
- SMS Campaign Registration: Assign an SMS Campaign to a Phone Number
External