Texting Onboarding: Opt-in Requirements from Twilio

Twilio, our texting partner for GC Outreach Texting, will need to review how your constituents opt in to receive messages before approving your application. Their reviewers will click on your links and follow the steps in your opt-in process. Please make sure the information and instructions you provide are clear and easy to follow, and that they are available through a publicly accessible link. If you don’t have these resources yet, you’ll need to create them to get started with GC Outreach Texting. If you’ve already collected consent from people in your community, Twilio will still need to see how you plan to collect consent going forward.

Here's an example from Twilio of the ideal message flow:

“Constituents opt in to receive marketing messages from (school name) by checking the SMS opt-in box while filling out the contact form at (direct link of form). The form displays: 'Check this box to receive (opportunities to give or similar language) via text. Up to (insert amount of messages) msgs/month. Message and data rates may apply. Reply STOP to opt out. Privacy Policy: (enter link to privacy policy). Terms and conditions: (enter link to terms and conditions)”

• If you're planning on sending informational texts (as well as marketing texts), you'll need an additional opt-in flow for that use case.

Here's what's required in a message flow:

• Description of the opt in method(s) with clear opt-in language that invites users to optionally sign up (no pre-checked boxes or required fields)
• Message frequency (x msgs/month)
• "Message and data rates may apply" disclosure
• Link(s) to opt in image/mockup
• Link(s) to privacy policy and terms and conditions

What you include in your message flow will depend on where your opt-in happens:

• Public website form: Include the URL to your sign-up page.
• Form behind a login or paywall: Take a screenshot of the opt-in form, upload it to Google Drive or OneDrive (make sure it's set to "anyone with link can view"), and include the public link in the field.
• Verbal or phone opt-in: Write out your full script in the field, including what you say and how the customer confirms their consent.
• Paper form: Scan or photograph the form, upload it publicly, and include the link.

Privacy policy and terms and conditions requirements:

Every registration needs to include both a privacy policy and terms and conditions, and they need to meet specific requirements that protect your team and keep you compliant with industry standards. Registrations that don't include them will be rejected.

• Your privacy policy must:
  • Disclose what data you collect and how it's used
  • Explain that mobile information won't be shared with third parties for marketing purposes (required by CTIA)
• Your terms and conditions should generally include:
  • School name
  • Program (texting campaign) description
  • Message and data rates may apply disclosure
  • Message frequency (or recurring message disclosure)
  • School contact information
  • Complete opt-out instructions (STOP), displayed in bold
  • Link to the privacy policy
  • Disclosure that states "Carriers are not liable for any delayed or undelivered messages"
     

We recommend consulting with your legal counsel to make sure that your terms and conditions and privacy policy are compliant with applicable laws and consistent with standards for your particular campaign and industry.

Additional Resources from Twilio:

• Twilio Campaign Approval Best Practices
• Twilio's Messaging Policy