Who or what is the CTIA?

The Cellular Telecommunications Industry Association is made up of representatives from major telecom, VoIP operators, and CPaaS companies. The CTIA creates guidelines for practices that are expected to be followed throughout the telecommunications industry. The CTIA created the short-code system that is widely used today and can suspend, or in some cases terminate, short-codes if regulations are violated. The CTIA helps the telecom industry self-regulate to provide maximum freedom for both the consumer and the provider. 

CTIA 2019 Guideline changes:

The CTIA (Cellular Telecommunications Industry Association) was created by major telecom companies to protect their consumers from spam, fraud, and other abuses. The following points are some updated / new guidelines to help your company remain compliant with the CTIA.

1.     The CTIA now uses a consent-based approach for A2P (Application to Person) messaging.
    a. Marketers must obtain the consumers express consent to receive messages
    b. Marketers must obtain written consent to receive marketing messages
    c. Marketers must ensure the consumer always can revoke consent at any time

2.    The CTIA recommends that marketers gain consumer consent via:
     a. Clicking a button on a mobile site
     b. Entering their phone number on a website
     c. The consumer sending a message to the marketer containing a keyword
     d. The consumer opts-in using interactive voice response (IVR) technology

3.    The CTIA requires opt-in consent to apply to the campaign(s) and specific message sender for which it was intended/obtained.
4.    An opt-in is achieved when a user texts into the marketer’s number
5.    Opt-out practices have remained the same: Provide the consumer the ability to opt-out at any time

If you have any questions about whether your practices violate the CTIA guidelines, refer to their “2019 Best Practices” report below.

  • Link to their 2019 Best practices report.

Examples for how to gain consumer consent for different message types:

  • Messages that will be used for conversation with the consumer: Mediums like websites, chat boxes, or inquiry messages can be started by the consumer. When conversation is initiated by the consumer there is implied consent and no further permission is required.

  • Messages used to convey non-promotional messages: Consent for this type of messaging can be gained when the consumer provides their phone number and asks to be contacted for information like appointments, alerts, reminders, etc. Consumers must give express consent when providing non-promotional information.

  • Messages used for promotions: Consumers must provide express written consent in order to receive promotions from the provider. 

Different types of consent:

  • Implied Consent: If the consumer initiates the text message exchange and the business only responds to each Consumer with relevant information, then no verbal or written permission is expected.

  • Express Consent: The Consumer should give express permission before a business sends them a text message. Consumers may give permission over text, on a form, on a website, or verbally. Consumers may also give written permission.

  • Express Written Consent: The Consumer should give express written permission before a business sends them a text message. Consumers may sign a form, check a box online, or otherwise provide consent to receive promotional text messages. 

Special note for political advertisers:

Many political advertisers operated under P2P messaging regulations but are now likely redefined as A2P messengers. To find out if this applies to you below are the guidelines for your traffic be considered P2P.

  • Throughput of no more than 15-60 messages per minute

  • Volume of no greater than 1,000 messages per day

  • Unique Sender with only one telephone number assigned to or utilized by a single Consumer—a new condition with this update

  • Unique Recipients with no more than 100 distinct recipients/telephone numbers per message—a reduction from 200 in the 2017 guideline.

  • Balance of roughly a 1:1 ratio of outgoing messages to incoming messages per telephone number

  • Repetition of 25 or more substantially repetitive messages is a new condition that would flag messages as A2P rather than P2P

Note: The CTIA’s Principles and Best Practices do not constitute or convey legal advice and should not be used as a substitute for obtaining legal advice from qualified counsel.

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