Guide to getting your campaign approved
- Timothy Linn
Campaign and content attributes
Whenever registering an SMS campaign, there is a lot of information that is requested. This is an overview of what is expected in each of those attributes:
Subscriber Opt-in: Provide any applicable opt-in keywords (e.g., ‘START’). The opt-in message is required and must contain the following information: Brand Name, Message Frequency, “Message and data rates may apply” disclosure, HELP information, STOP/UNSUBSCRIBE information
Example: “Thank you for opting in to receive order update messages from [Brand Name]. Message frequency will vary. Message and Data rates may apply. Reply HELP for support. Reply STOP to opt-out”
Subscriber Opt-out: Provide opt-out keywords (e.g., STOP, UNSUBSCRIBE, etc). Opt-out messages must contain the Brand Name and confirmation that no further messages will be sent
Example: “You have been opted out of messages from [Brand Name]. No further messages will be sent.”
Subscriber Help: Provide help keywords (e.g. HELP, SUPPORT, etc). The help message must contain Brand name and an email address, phone number, or website link the consumer can use for support.
Example: “Hello this is [Brand Name]. Please contact us at [email address] or [phone number] for support. Reply STOP to opt out.”
Direct Lending or Loan Arrangement: This must be “Yes” if the brand engages in any direct lending or loans, even if the messaging related to the campaign will not.
Embedded Link: This must be “Yes” if messages will contain any links. An example of a link must be included in at least one of the sample messages if this is “Yes.” URL Shorteners are not allowed and known prohibited URL shorteners are listed
Age-Gated Content: Must be checked “Yes” if the content includes any age-gated materials (e.g. Alcohol/Tobacco)
Terms and Conditions: Must be “yes” and a link to the Terms and Conditions must be provided.
Common rejection reasons
Call to Action
The most common campaign rejection reason is for an insufficient Call to Action/Message Flow (CTA) section. There are 2 different parts of the Call-to-Action when it comes to vetting for 10DLC
One of those parts the vetting company will review is the Call to Action/Message Flow field provided during the campaign registration. This section should contain a clear, concise, and specific description of how an end user signs up to receive messages. This Opt-in MUST be 1 to 1, the information given during the consent process cannot be shared with third parties, the information must be used specifically for text messaging, and it must be explicit (e.g. “By checking this you agree to receive text messages”) not implied. It must be clear and conspicuous and cannot be obscured within Terms and Conditions and/or other agreement(s).
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Examples of how to get users to opt in:
Entering a phone number through a website
Example: Customers opt-in by visiting http://www.the-website-for-your-brand.com , clicking on the menu and “contact us” and adding their phone number. They then check a box agreeing to receive text messages from the brand.
Note: If using a website to collect opt-in, please provide a direct link to the submission form in the CTA/Message Flow field. If this is missing, the campaign will be rejected.
Clicking a button on a mobile webpage
Note: Please provide a website link in the CTA/Message Flow field if this is where the opt-in is being collected.
Sending a message from the consumer’s mobile device that contains an advertising keyword
Example: Consumers opt-in by texting START to (222) 555-1111.
Important: In the Call-to-Action/Message Flow section, you will need to explain how the consumer/recipient is informed to text the keyword/initiate the text messaging conversation. Acceptable explanations of how the consumer is informed include:
a link to a webpage where the keyword opt-in is advertised
an attached screenshot of the keyword opt-in advertisement
Signing up at a point of sale (POS) or another message sender on-site location
If the opt-in is collected verbally, you must provide a copy of the opt-in script read to the consumer
If opt-in is collected electronically, a screenshot and/or link to the opt-in form must be provided
Opting in over the phone using interactive voice response (IVR) technology
The phone number used to reach the IVR as well as the specific option(s) to reach the opt-in should be provided in the Call-to-Action/Message Flow section of the campaign registration form.
The other part of the Call-to-Action/Message Flow will be the vetting company will review the disclosure provided to the consumer/recipient during the opt-in collection process described. This disclosure is the language that you provide to the consumer/recipient informing them that they are opting in to receive messages. This disclosure must contain the following information:
Brand Name (must match the Brand name that the campaign is being registered under)
Type(s) of messages being sent
Message frequency disclosure (e.g. Msg frequency varies, 2 messages/week, etc)
“Message and data rates may apply” disclosure
HELP information (e.g. text HELP for help)
STOP/opt-out information (e.g. text STOP to stop)
Link to the Privacy Policy and Terms and Conditions
All of this information must be provided to the consumer/recipient at the time of opting in, regardless of the method used to opt-in. Examples of the inclusion of this disclosure for different opt-in methods are:
Website/Online opt-in: “By submitting this form and signing up for texts, you consent to receive marketing text messages (e.g.cart reminders, promotions, order updates) from [Brand Name] at the number provided, including messages sent by an automated system. Consent is not a condition of any purchase. Message and Data rates may apply. Messages frequency is approximately 2 messages per week. You can unsubscribe at any time by replying “STOP” or clicking the unsubscribe link (if applicable). Reply HELP for help. [Link to Privacy policy and Terms and Conditions]”
Keyword Opt-in: “By texting START to [number], you consent to receive marketing messages (e.g. promotions) from [Brand Name]. Consent is not a condition of purchase. Message and Data rates may apply. Messages frequency is approximately 2 messages per week. You can unsubscribe at any time by replying “STOP” or clicking the unsubscribe link (if applicable). Reply HELP for help. [Link to Privacy policy and Terms and Conditions]”
Consumer Initiated Messaging: “By starting a text conversation with [Brand Name] by texting [number], you are agreeing to receive conversational messages from [Brand Name]. Message frequency varies, message and data rates may apply. You can unsubscribe at any time by replying “STOP” or clicking the unsubscribe link (if applicable). Reply HELP for help. [Link to Privacy Policy and Terms and Conditions]”
Verbal opt-in: “[Brand Name] will be collecting opt-in verbally from customers. The customers will be able to opt in to receive messages in person at the brand’s physical location, over a phone call when speaking to an agent, or through interactive voice response (IVR) technology. When a customer initially registers, they are asked to provide their phone number and staff is trained to ask if the customer would like to opt in to SMS notifications. They will be verbally informed that “Message and data rates may apply” and “Message frequency may vary.” They also will be informed that they can text “HELP” at any time for help or “STOP” to unsubscribe from receiving any further messages. They will be informed that their phone number will not be shared with third parties for promotional or marketing purposes. The links to the Privacy Policy and Terms and Conditions will be provided to the customer and must be included in the Call-To-Action/Message Flow section of the campaign registration.
Additional notes/requirements about the Call-To-Action/Message Flow field:
All messaging traffic on behalf of an organization/entity/business must have prior, explicit opt-in/consent
If the Call-To-Action/Message Flow is collected on a website, the website and where to find the opt-in must be provided. If it is not provided, the campaign will be declined
If any donations are part of the campaign, the Call-To-Action disclosure shared to the person opting in must reflect that
Example: “By opting in to receive text messages from [Brand Name], you consent to receive marketing, donation asks, and information messages. Message and Data rates may apply. Messages frequency is approximately 2 messages per week. You can unsubscribe at any time by replying “STOP” or clicking the unsubscribe link (if applicable). Reply HELP for help. [Link to Privacy policy and Terms and Conditions]”
Opt-out message
Acceptable opt-out language must include one of the following words: STOP, UNSUBSCRIBE, CANCEL, END. If you are using an opt-out phrase, it must be separated by spaces (e.g. “STOPMESSAGES” is not acceptable, it should be “STOP MESSAGES”). Please make sure that one of your sample messages shows your opt-out.
Example: “[Brand Name]: Your order has been received and is being processed. Reply HELP for help. Reply STOP to unsubscribe.”
SHAFT-C(D) content
There is a list of prohibited content with 10DLC. This content is prohibited both in the content of the messages as well as the content of the Brand’s website. Even if the message content does not contain these things, if it exists on your website your campaign will be rejected:
Sex
Hate
Alcohol*
Firearms
Tobacco*
Cannabis/CBD
Debt Relief/High-risk financial content (e.g. Gambling)
*Alcohol and Tobacco can be supported with strict and robust age-gating and proper opt-in processes
Example: If a doctor's office has CBD oils on its website, the campaign will be denied even if it's not directly related to CBD marketing.
Prohibited URL Shorteners
Due to the possibility of abuse, l URL shorteners are generally prohibited from being used. This list is not comprehensive:
goo.gl (Google Drive links are also disallowed)
lc.chat
tiny.cc
Note: “Premium” or “paid-for” versions of these URL shorteners are also disallowed.
Lack of a website or online presence
Make sure to include any website or online presence the brand has (even if it is just a social media page). If no website/presence is shared, the vetting company will still search to see if there is one associated with them. If there is prohibited content (See SHAFT-C) on their website or if a website is found but was not included in the campaign registration, the campaign will be rejected.
If the brand does not have a website, please provide any form of online presence in the Brand Details (e.g. social media pages, Google search link, etc). If the Privacy Policy and Terms and Conditions are not found online, they will need to be provided in electronic document format.
Non-compliance with Know Your Customer guidelines
Following proper Know Your Customer (KYC) guidelines are necessary for campaigns. The “Brand Name” MUST reflect the company sending the messages to the customer, not software behind the delivery or other brands under a corporate umbrella.
The brand is the message sender. The Employer Identification Number (EIN) and company information should reflect the sender of the messages, not a reseller.
Privacy Policy
All message senders must have an acceptable Privacy Policy available when registering 10DLC campaigns. The most important aspect of a valid Privacy Policy would be a clear description of how consumer data will be used and shared and how consumers can contact the message sender. A compliant Privacy Policy should include the following points:
Consent - Explicit language within the Privacy Policy needs to state that the end-user data will not be shared with third parties for marketing purposes. It is possible that the information could be shared if it is essential for business operations, but sharing marketing leads to third parties is prohibited and will cause the campaign to be rejected. To ensure that campaigns are not rejected, the Privacy Policy should have language stating that consumer data will not be shared
Example - “Mobile contact information will not be shared with any third party or affiliates for marketing/promotional purposes. Any Privacy Policy sections discussing information sharing exclude messaging opt-in and consent, that information will not be shared with any third parties.”
Opt-out Instructions - Brands are required to acknowledge the customer’s right to opt out of receiving further messages from a campaign. The Privacy Policy must include instructions on how to properly opt out of future communications
Example - “If you wish to be removed from receiving messages, you can opt out at any time by texting STOP, QUIT, END, CANCEL, or UNSUBSCRIBE.”
Sangoma suggests making a personalized Privacy Policy with the SMS disclosures and requirements mentioned. The brand/message sender is responsible for researching and ensuring that Privacy Policy content complies with TCPA laws as well as any other compliance requirements.
Please also ensure you are linking to your privacy policy and terms and conditions in the Campaign Details section when registering your campaign. This will allow for quicker location of these items resulting in a more streamlined vetting process.
Terms & Conditions
All brands must have compliant Terms and Conditions made available to their consumers/recipients. These Terms and Conditions must be provided when registering their campaign and to any consumer that is opting in to receiving messages. Most brands have the Terms and Conditions on the brand’s website; If the brand does not have a website, a hard copy of the terms and conditions will need to be provided.
The Terms and Conditions must include the following:
Brand name (Must match the brand that the campaign is being registered under)
Types of messages the consumer will receive (e.g. order updates, new product advertisements, etc)
Message frequency (e.g. Message frequency varies)
“Message and data rates may apply” disclosure
Support contact information (e.g. Text HELP for help, contact [email] for support, etc)
Opt-out info (e.g. Text STOP to unsubscribe)
The Terms & Conditions page must contain the following details:
Brand name
Types of messages the consumer can expect to receive
Message frequency disclosure
"Message and data rates may apply" disclosure
Customer care contact information (Text HELP for help, contact [email address] for support, etc.)
Opt-out information (Text STOP to cancel)
Example:
"Messaging Terms & Conditions
By opting in, you agree to receive marketing messages (new products, sales, discounts, etc) from [Brand Name]. Message frequency varies. Message and data rates may apply. Text HELP or email us at [email] for support. You can opt out at any time by replying STOP.”