Mongoose_Careers

Texting Compliance

All of Your Compliance Questions, Answered.


Protecting Your Ability to Text

 

Telecommunications carriers have made efforts to ensure that text messages sent by higher education institutions are relevant and valuable. To help students and other constituents communicate better, we need to do our best to  be good citizens of the SMS world and comply with best practices.

"So What Do I Need to Do?"

We all want to do our part to protect the medium and take reasonable measures to make sure we are not blocked or filtered by carriers.

 

Use this page as a resource to ensure that you're texting as effectively as possible and reducing any risk with telecommunications carriers. Visit a specific section with the links below. Happy texting!

 

See FAQS  |  View Resources  |  See Consent Examples

Resources & Frequently Asked Questions

  • Summary of Compliance Guidelines

    The TCPA (Telephone Consumer Protection Act) is a federal law that limits how consumers can be contacted via phone, text, and fax.  Tax-exempt, non-profit organizations (so, most of higher ed and our clients) are not required to comply with many of the rules in the TCPA - but we recommend that they do as a best practice.  

    In 2019, the CTIA (Cellular Telecommunications and Internet Association Trade Association), a consortium across the entire wireless industry, including all carriers, released a set of guidelines that are the foundation for the current state of compliance and acceptable use rules from telecommunications providers.

    The CTIA guidelines are not legally binding, as the TCPA is, but express the desires of the carriers when it comes to the behavior of those who are sending messages across their networks.  These guidelines, around clear consent and opt-out messaging, form the basis of the Twilio Messaging Policy that we are bound to as texting institutions.


    While individual state laws and the TCPA may be more permissible than the guidelines expressed by the CTIA, we are responsible for ensuring our clients’ usage of Cadence is consistent with Twilio’s Acceptable Use and Messaging Policies.  The carriers, via the CTIA, and Twilio directly have the ability to audit traffic and will ask us for proof of compliance in the event of violations.  The inability to provide this proof could result in the removal of specific numbers or entire sub-accounts.

  • Mongoose’s Recommendations for Obtaining Consent

    Compliance guidelines contain a fair amount of nuance which allows for a range of interpretations.

    Ideally, consent to text should be established before texting contacts. In order to obtain consent, the collection method should include the following:
     
    ✅ An explanation of what types of messages the recipient–if agreeing to opt-in–can expect to receive
    ✅ An indication of the planned frequency of messages
    ✅ A place to provide a valid mobile number
     
    An example of acceptable consent language and data collection would be:
     

    Student Life Example

    ---

    Blanket or vague opt-in statements such as “provide your mobile number to receive text messages” may not be specific enough to be considered acceptable examples of consent in the most strict interpretations of the guidelines.

    Consent cannot be obtained through the following avenues: 

    ❌ By purchase, sale, or in exchange for something else. For example, you cannot obtain consent by purchasing a list of phone numbers from another party.
    ❌ Through a smart message. The initial message must include a carrier trigger word. 
    ❌ Via a phone call, unless the call is recorded. Either a recorded phone call or a physical piece of paper where they have signed off on consent is proof of opt-in.
  • Mongoose’s Recommendation For Collection Methods

    Methods for obtaining consent should be documented and provable in the event that your institution’s messaging activity leads to large spikes in opt-out rates or spam complaints.

    Places to ask for consent (opt-in) include:
    • Application or document submissions ​​(example: contacts could check a box that indicates that phone number can be used for outreach for X purposes)
    • Forms that ask for contact information
    • Websites or student portals that provide opportunities for setting communication preferences
    • Event registrations/sign ups
    • Appointment scheduling

    The real objective is to reduce opt-out percentages, So, while the guidelines do not technically allow for the use of texting as a means for soliciting or collecting consent- it could be a good way to reduce the number of opt-outs.

    See specific consent examples based on your audience including prospective students, current students, alumni, or all (Enterprise).

  • Storing Texting/Communication Preferences

    As a goal, we want to limit the number of text opt-outs as much as possible.

    To that end, if the communication would not be appropriate semester to semester or year to year - make sure your segments and contact imports are current.  If you are not sure based on your data, you should offer contacts opportunities to opt-into texting for that team.

    A single opt-in is allowed to provide consent for multiple teams as long as the use cases and consent provided makes sense for those teams.

    Data fields associated with texting preferences should include:

    • Contact name
    • Contact mobile number
    • Opt-in status/preference (opted in or opted out)
    • BONUS: the Date/Time that the status was last updated

    If your institution is utilizing other messaging services not associated with Cadence such as short codes or emergency alerts, there should be a separate consent process and data point for each of those methods.

  • Recommendations for Re-Establishing Consent

    Obtaining consent to text an individual does not mean that consent is provided indefinitely. Your institution’s texting policy should take into account when consent to text was last established and apply that to your institution’s texting best practices. Storing a date/time stamp along with a contact’s opt-in status/preference is the best way to track this information.

    Consent and opt-in should be re-established if a reasonable enough time has passed without any messages being sent to the contact. There are no specific time-based guidelines, so it is up to the discretion of the institution to make this decision. 

    We recommend admissions cycles, academic years, or annual giving drives as examples of opportunities to re-establish consent - if a contact has not been in active communication since the previous interaction.

  • Managing Opt-Outs

    There are a few possible ways that a contact may opt-out of receiving text messages:opt out

    • By texting a keyword to one of your Cadence numbers (STOP, CANCEL, END, QUIT, UNSUBSCRIBE, etc.) and triggering an automatic opt-out; this will opt the contact out from receiving text messages from the corresponding team in Cadence
    • By texting an opt-out statement to one of your Cadence numbers (“please stop texting me”, “leave me alone”, etc.); Cadence users should click the opt-out toggle on the contact’s record to complete the opt-out
    • By indicating a desire to opt-out or remain opted out via a form, document, email, telephone/remote meeting/in person conversation, etc.

    With regard to keyword-triggered opt-outs in Cadence, when an individual sends in a valid keyword, one final message to confirm the opt-out will be delivered. The only way that the contact can be opted back in is if the contact sends an opt-in keyword to the same number (UNSTOP, START, YES, etc.).

    Remember that in Cadence, contacts have a separate opt-out status per team/department. There are a few different ways that you can track opt-out statuses:

    • By exporting an opt-out Changes report
    • By utilizing an integration (FTP, API, or select native integrations) that automatically provides updates when a contact’s opt-out status changes
    • By setting up email alerts to notify one or more individuals at your institution every time any contact’s opt-out status changes. A separate alert can be set up per team/department in Cadence (can only be set up by Admin users).
  • Best Practices & Tips for Outgoing Messages

    In addition to other best practices that your Cadence Client Success Lead will provide to your institution, there are recommendations to help you make sure your messages are clear as to who you are, and what the recipient could do to let you know they would no longer like to receive messages on that topic.

    • Best practices suggest that every message should include clear identification of who the sender is. If you identify yourself each time, the repetition may make for some awkward conversations. Just be clear as to who you are - especially in the initial message to a contact.
    • Don’t forget information on how to opt out - especially in the initial message. Examples of opt-out instruction language include “Reply STOP to unsubscribe” or “To opt-out of these messages, please respond with UNSUBSCRIBE.” Optionally, you could substitute in other acceptable opt-out keywords such as STOPALL, CANCEL, END, and QUIT.
    • If an individual sends an incoming message to one of your Cadence numbers, you are free to respond to that individual. For example, if someone asks a question about your department, you can answer it. In this case, the incoming message counts as both consent to text (opt-in) and proof of consent for the conversation that is taking place.  If the institution wishes to text the student about other situations, they should still obtain consent for those additional uses.
    • If you have already had a prior relationship communicating with a contact (provided that the contact gave you a mobile number and took some kind of action to trigger the communication) you may text that contact. Acceptable forms of triggering “actions” include opting in via button press on a website, alert set up for appointments, etc. Examples of acceptable messages in these scenarios include appointment reminders, receipts, one-time passwords, confirming support/help desk call times, etc.
  • Does this effect High-Speed Messaging?

    For High Speed messaging pre-registration is required, but the same rules apply. The best practices from Twilio/ZipWhip have been largely consistent already, and it seems like this only going to continue as they merge.
  • How does this apply to Canadian schools?

    If a Canadian school is texting to US recipients, it's definitely the same.  If it's CA to CA handsets, assume it's the same for the sake of clarity.
  • When is the deadline for meeting compliance recommendations?

    At this time, there is no hard and fast deadline, but we recommend making changes sooner rather than later to protect your institution's ability to text. Your initial adjustment could simply include updating your texting policy or including stop to opt-out messaging in each of your outgoing messages to new contacts. 
  • What is going to happen if we don't do this?

     As telecommunications providers roll out these best practices, we anticipate the enforcement of requirements to tighten up over time. We strongly advise that you embrace these recommendations and work to implement them within a reasonable timeframe. 
  • Do these policies have anything to do with A2P registration?

    These compliance guidelines are totally separate from the A2P registration requirements. However, in a similar fashion, these policies are coming from the carriers themselves and represent an industry-wide shift. There's no situation where text message traffic will be exempt from A2P registration.
  • But I've already texted these contacts but haven’t formally gained consent?

    We still recommend you send an email to all contacts before texting them again and confirming their opt-in status and then only text those contacts if you have documented consent from them. If you do have consent but haven't texted the contact in a while, it wouldn't hurt to ask for consent. If for any reason you are unable to do this (and even if you do) the next best thing would be to make sure they introduce themselves in the first text and include the opt-out language.
  • Who is making the rules here?

    It’s not Mongoose and ultimately it’s not Twilio - the guidance is coming from the CTIA, a group that represents the entirety of the U.S. wireless communication industry, including all carriers. Their best practices and principles can be found here. Twilio’s policies are based entirely on this guidance, as it guarantees they will continue to have access to the carriers’ networks and provide service to us and others. If any vendor or SMS provider/gateway is not following this guidance, they run the risk of compliance violations and denial of service.
  • Have there been any current issues with consent?

    We’ve experienced two issues to date, where texting activity has caused the carriers and Twilio to investigate potential compliance violations. In one case, the issue was related to a higher than normal opt-out rate over a 7-day period, across the usage of an entire team. In the second situation, a specific recipient filed a spam complaint due to receiving a message for which they had never provided consent. In both these cases, we were required to provide evidence as to how consent was collected, and provide assurances that best practices regarding opt-out communication were being followed.
 

Our philosophy

“Client Love.” It’s a phrase that you’ll hear around the office over and over. It’s our core philosophy that is embraced by our entire team. We even have a giant poster to remind us.  Why? Because we do love our clients. We go the extra mile to support them. And we truly feel that our success is only realized when our clients learn from our insights, get extraordinary results with our products, and excel at their jobs.

This Client Love seeps into every aspect of who we are and what we do – our client communications, our support processes, our publications, our products, our people. Everything.

ClientLove_vertical-01

Examples of Consent

  • Consent with Prospective Students

    Opportunities to ask prospective students for consent 
    • Start with your inquiry form and include language such as, “By checking this box, I consent to receive no more than bi-monthly texts regarding application deadlines and/or events from Mongoose Admissions. I may opt out at any time by texting-in the word “STOP".

    • You may even consider advertising a shared inbox number and encouraging applicants to text in to aid in collecting consent. For example, “Text 'Join' to 716-222-2222 for monthly Mongoose University application deadlines.” You could also promote this on your social media accounts as well.

      Opt in Form (1)
    • Remember you can ask for consent through multiple communication outlets. This could include email, inquiry cards, website forms, etc. As long as you include the information above, you are set to text.

    • Including consent language in your online application is a great way to re-establish consent throughout the lifecycle as well.

    • 💡Bonus Tip: You worked hard to recruit students and get them to this stage. Once students matriculate, your colleagues can take proactive steps to retain them with continued personal texting conversations in areas including Orientation, TRIO, Student Success etc. Communicate and share your texting success with departments who are continuing the relationship beyond Admissions. See current student consent section for more examples.

     
    Examples for asking prospective students to opt-in 

     

    Email Example to Prospective Students

    “Hi <FirstName>, 
    The Admissions team at Mongoose University is excited to connect with you! We would love to send you information via text messages about upcoming events, application deadlines, and general information regarding our institution. We promise not to spam you! You can expect to receive texts no more than once per week. You can also reply to texts to get a response from our Admissions staff. We recommend that you do not include sensitive personal information (e.g. your Social Security number) in your texts. You can unsubscribe from receiving text messages at any time by replying to a text with the word "STOP". 
    Please fill out the information below to opt into our texting program. Thanks!”

     

    Initial Text Examples to Prospective Students

    “Hi <FirstName>, this is Mongoose University’s Admissions office! We can’t wait to connect with you and answer any questions you may have. We will be sending you event reminders throughout the next month. You may opt-out at any time by texting in the word, STOP.”
  • Consent with Current Students

     
    OPPORTUNITIES TO ASK CURRENT STUDENTS FOR CONSENT

     

    Look at all of the areas your current students release their contact information over the academic year:

    • Financial: Fin Aid/Bursar/Student Accounts/Student Employment
    • Academics, Supports: Registrar/Student Success/TRIO/Advisement/Library
    • Student Affairs, Supports: Housing and Residence Life/Student Activities/Student Conduct/Health Services/Counseling Services/Career Services
    Is the information collected what you use to gather students’ mobile numbers? Is this the best way to collect student data? Is there a way to collect their data in a simpler way?

     

    After asking these questions, think of all of the student touch points throughout an academic year and what areas you could utilize to collect updated contact information or consent:

    • Appointments with Staff: Semester registration (drop/add), Counseling/Wellness Center visits, Academic Support/Tutoring, Librarian/Research assistance, Accessibility Services, Office Hours with faculty, ect.
    • Campus-Wide Events: Orientation, Move-In, Homecoming, Graduation
    • Funds Disbursement, Tuition+Housing Bills and Payments: Financial Services - Student Accounts/Bursar 
    • Reapplying for Aid/Services - Academic Based: Class Registration, Financial Aid, TRiO/SSS/HEOP, Work Study/Student Employment, Accessibility
    • In-Person or Virtual Fairs: MassEvents Crowdsourcing Interests: Club/Org/Engagement Fairs, Career/Internship Fairs, Graduation Fairs
    • Student Softwares/Self Service Student Portals: Student Engagement websites/apps, Web-based Virtual Learning Environment/Learning Management Systems, IT Support Help Desk/Password Resets
    • Reapplying for Engagement/Aux. Services - Student Affairs Based: Housing Selection, Club/Org Sign Ups, Study Abroad Applications, Student Government
    • Course Syllabi (if faculty are texting)
    • Post-Assessments: Course Surveys, Post Events, Post 1:1 Meetings
    • Athletics: Sporting Events, Ticket Sales, Advertisements
    • Admissions, Current Student Touches: Tour Guides, Ambassador Programs, Graduate School Outreach
    • Graduate Assistants
    • Diversity, Equity, and Inclusion: Identity Centers, Campus Pantry, Emergency Assistance Services (CARE Funds)
    • Campus Safety - Non-Emergency Alert System Based: Unlocks, Transportation, Lost & Found
    • Dining Services: Dining Plans, Adding Dining Dollars
    • Social Media Platforms / Weekly Scheduled Emails: Routine Scheduled Outreach, Including options in platform biographies, email footers, etc. 

     

    EXAMPLES FOR ASKING CURRENT STUDENTS TO OPT-IN

     

    Advertisement Examples

    “Text ‘MongooseLife’ to 716-222-2222 to enroll in monthly text messaging from the Mongoose Student Activities team about campus-wide events or important real-time event updates.”
     
    “Thanks for opting in to monthly MongooseLife Student Activities texts and important real-time event updates. Please reply with your preferred name and MU email address to update our information. You may opt-out at any time by texting in the word, 'STOP'.”
     

    Email Example

     

    💡Bonus Tip: Try a Division or Campus Wide Email that could be sent to current students explaining the texting policy, list example use cases, where they can update their contact information/communication preferences, and explain opting-out.


    *Is this something the Dean of Students or Provost could send once a semester or once an academic year as an official notice to students?


    Division-Wide Email Example:

    Hello Mongoose University Students,
     
    This email  serves as a notice and reminder to our student community of our intentional communication efforts, specifically regarding text messages.
     
    MU is committed to texting students on individual personalized outreach, for time-sensitive updates, and/or in instances where an individual’s immediate action is required/requested. MU promises to not spam students with information that could be better communicated over email, phone call, or other communication platforms.
    Students can expect messages from the following campus offices: [List Offices Here]
    You can read the full text-messaging policy here [Link or Insert Policy].
     
    You are encouraged to routinely update your mobile number and texting preferences on your MUStudentPortal [Insert Link].
    Students can also opt-out of text-messages at anytime by replying "STOP" to any unwanted communications.
     
    Here at MU we want to respect our students’ preferred methods of communication, but we also want to ensure the communication is received, read, and responded to in an appropriate way.
     
    Thank you,
    <Sender's Signature>
  • Consent with Alumni

     

    OPPORTUNITIES TO ASK ALUMNI FOR CONSENT

     

    • You may initiate receiving consent through multiple communication channels such as email, printed forms, alumni website/ portal, social media etc, as long as you include the following:
       
      • Who the texts will be from
      • How frequently they can expect the
      • What the texts will be concerning
      • How to opt out

    • On your alumni-update, donation, and event registration forms, and alumni portal where applicable, include language such as:
      • By checking this box, I consent to receive no more than bi-monthly texts regarding events and/or philanthropic initiatives from The MU Foundation. I may opt out at any time by texting-in the word “STOP''

        Alumni Opt in Form
    • Consider encouraging alumni, friends, and donors to text in to collect consent. Host a giveaway or other contest to inspire opt-in leading up to giving day, graduation week, athletic events and more. For example:
      • "Text 'GO MONGOOSE' to 716-222-2222 and follow the prompts for no more than bi-monthly MU Foundation event and philanthropic updates."

        The confirmation text should include language such as:


        "Thanks for opting in to bi-monthly Mongoose University Foundation updates. Please reply with your name, graduation year where applicable, and email address so we may update our records. You may opt-out at any time by texting in the word, 'STOP'."

    • Don’t forget about your “Alumni in Residence” as we say!  Collaborate with Registrar, Career Services, Commencement Services and any department interacting with graduating seniors to obtain consent (Graduation communications, outcome surveys, etc.).

    Sample Language : Stay in touch with your Mongoose Alumni Community!  By providing your mobile number, you will receive no more than bi-monthly texts regarding alumni events, networking opportunities, and philanthropic initiatives. You may reply "STOP" to remove yourself from text messages at any time.

     

    MORE EXAMPLES FOR ASKING ALUMNI TO OPT-IN

    Email Example for Alumni

    Hi <FirstName>,

    The Mongoose University Office of Institutional Advancement is excited to offer a new way of keeping in touch! Now you may receive information via text regarding upcoming events, alumni perks, reunions, philanthropic opportunities and gift confirmations.

    We promise never to spam you! You can expect to receive un-prompted texts no more than bi-monthly. You may also initiate or reply to texts to engage with our staff.

    Coming to campus and want a tour? Let us know. At the bookstore and want a coupon to purchase the latest fan gear? Send us a text!

    To opt-in and/or update your contact information at any time, please visit (link) or text "GO MONGOOSE" to 716-123-4567 and follow the prompts.

    Please do not include sensitive personal information (e.g. your Credit Card number) in your texts. You can unsubscribe from receiving text messages at any time by replying to a text with the word "STOP".

  • Consent Across the Enterprise

     

    OPPORTUNITIES TO ASK FOR CONSENT ACROSS THE ENTERPRISE

    Enterprise licenses have several opportunities to collect consent. While institutions can group opt in’s together (as long as they list all departments and use cases and expected frequency) we recommend reconfirming opt in status and updating students' mobile numbers. Appropriate times to do this are through inquiry forms, applications, enrollment/registration, orientation, graduation, etc.)

     

    EXAMPLES FOR OPTING-IN ACROSS THE ENTERPRISE

     

    Form Verbiage Example

    By providing your mobile number, you will receive personal text updates about your enrollment status, financial aid, and relevant student resources from Mongoose University no more than twice per week. You can reply "STOP" to opt out at any time (No spam, we promise)."  

    View an example form from a Cadence client.

     

    Email Example 

    Dear future students, parents, & visitors,

    Welcome to Mongoose University! We are pleased to offer a variety of ways to serve our students and their families. For your convenience, we’ve added mobile messaging to supplement communication for those who prefer this method of engagement. 

    What you can expect: All text updates will be personal and relevant to your interests and future success at Mongoose University. You can unsubscribe at any time, by texting-in the key word "STOP". If you have any questions or wish to update your communication preferences, please contact <Department Name> at mongoose.edu. 

    Please check all areas you'd like to receive text messages from:

    🔳 Content 1 
    🔳 Content 2 
    🔳 Content 3 
    🔳 Content 4 
    🔳 Content 5 

     

    We look forward to connecting! 

    Sincerely, 

    Mongoose University Marketing Team