Guide to SMS Campaign Registration

Guide to SMS Campaign Registration

Effective as of March 26, 2024, regulations regarding Application to Person (A2P) or Bulk Texting have been implemented by the FCC to prevent spam. When purchasing an SMS number through an internet service such as Twilio or ClickSend, you will be required to register that number with the Campaign Registry.

This is not a trivial process, and we encourage you to read the documentation provided by your SMS service. The SMS companies and cell network carriers are looking for specific responses on the application, and giving an invalid response will cause your application to get rejected. You may also need to create new documents and/or procedures, particularly when it comes to fulfilling the opt-in requirement. The purpose of this article is to clarify exactly what you need in order to meet all of the requirements.

Key Terms

  1. Campaign - The overall scope of your automated SMS usage.
  2. Brand - Your company or organization. 
    1. Note: TopView is not the brand. It is the tool or method by which you are determining when and how to send SMS messages, but the actual content and frequency is determined by you/your organization.  

Alert
This article assumes that you are registering an SMS campaign for sending TopView notifications and information requests. These are considered transactional messages, as they are triggered by system events and by users. Marketing/promotional messages have different (and more strict) requirements. Do not try to register a number for both transactional and promotional use. This is considered Mixed use, and will likely cause your application to get rejected. 

What You need for Registration

In order to have an acceptable registration, you must have the following:
  1. A Company Website that is publicly accessible. 
    1. If you do not have a website, a public social media page will suffice.
  2. A Privacy Policy and SMS Terms and Conditions, publicly available on your website or social media page. See this article for more information. 
  3. Examples of messages.
    1. It is best to include actual messages that may be or have been sent by TopView. 
    2. Transactional messages do not need to include opt-out language, but it does not hurt to include it. 
  4. A Valid SMS Opt-in process.
    1. An insufficient or invalid opt-in process is the most common reason why registrations get rejected. Carriers require proof that message recipients have explicitly agreed to receive texts from your business, even if the recipient is an employee.
    2. You must include some way of tracking when and how recipients have given consent. For keyword opt-in, TopView stores a copy of all SMS messages it receives, but for other methods, you must have some form of tracking (e.g. spreadsheets, paper documents)
    3. See the following section for valid SMS opt-in methods.

Valid SMS Opt-In Procedures

Idea
Opt-in Do's and Don't's
Do: 
  1. Submit one of the suggested Opt-In procedures. You may submit more than one method if necessary, but they must all be valid.
  2. Have a way to record individuals who have opted-in to SMS messaging, such as a database, spreadsheet, or physical record.
  3. Provide proof that the opt-in procedure is in place (screenshots, documents, scripts, etc).
  4. Include a description of how to opt-out, and a procedure to promptly stop sending messages to recipients that opt-out. The most typical method can be texting the word STOP to the SMS number. Web SMS services will often have a feature to automatically blacklist contacts that include the word STOP in the message. 
Don't
  1. Include an opt-in procedure that is not one of the valid options listed below.
  2. Have any form of implicit or automatic opt-in (examples: employees are automatically opted-in; the operator with the on-call phone will receive messages).

Web Form

A web form can be the most convenient method to gather consent from your recipients, and this information can be automatically stored in a database of your choosing. If your organization does not have a website or infrastructure to create a web form, a Google Form or Microsoft Form can be used instead, and the responses stored in a corresponding Google/Excel spreadsheet.

The web form must contain the following items:
  1. Your organization's logo clearly visible at or near the top of the form.
  2. Name (or First Name/Last Name) and Email fields. These can be required. 
  3. A Phone Number field. This can not be required.
  4. A Checkbox that indicates the recipient's consent. The text should look like the example below. This must be unchecked by default and can not be required.
    1. [ ] By checking the box and providing your phone number, you agree to receive alarm notifications from [Brand Name]. Message frequency varies. Message and data
      rates may apply. Text STOP to [TFN] to cancel at any Time.
Do not provide a field to opt-out, or make the consent field anything other than a checkbox. 

You must be able to include a link to the web form. If the web form is accessible only on an internal network, indicate as such on the campaign registration and submit a screenshot of the form. 

Verbal

Recipients may consent verbally to a representative of your organization. A script must be used and submitted with your campaign. You must also have a method to track when and how recipients grant consent. We recommend using the provided script:
-----
      Store Representative: [Brand Name]. Message frequency varies. Message and data rates may apply. Text STOP to [TFN] to cancel. Would you like to receive alarm notfications from [Brand Name]? If so, please provide your phone number.

      Subscriber: Yes, my phone number is xxx-xxx-xxxx.

      Rep: Thanks for providing your phone number. We will send you a text confirming your opt in from [Brand Name].

      ** If Subscriber Says No:
      Subscriber: No

      Rep: You will not be opted into [Brand Name] notifications.
-----
Include your script in the campaign registration, along with a description of how consent records will be kept. 

Keyword

This method of obtaining opt-in consent involves having the recipient text a key word (such as ALARM or SUBSCRIBE) to the SMS phone number.

TopView does not currently support keyword opt-in tracking, however, both Twilio and Clicksend provide automation tools that can assist with tracking consent, such as blacklisting recipients that text the opt-out keyword. TopView also keeps a record of all messages it reads, and these can be accessed through Admin Tools.

Instructions on how to opt-in must be included in your application. In TopView 7.6,  we have added a tool which will generate opt-in instructions. (Tools > Support Apps > SMS Opt-In Instructions Generator). Make sure to include your organization's logo. Print or take a screenshot of these instructions to include in your application.


For earlier versions of TopView, you will need to create your own document, see this article for more examples.

Paper form

A paper form can be used for opt-in consent, and has the advantage of creating a physical record of the recipient's consent. All the requirements of a web form also apply to paper forms.

Include the document file that will be used to create the printouts in your campaign registration.

Sources and More Information