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2024 - March - Privacy Policies and T-Mobile Outbound SMS

2024 - March - Privacy Policies and T-Mobile Outbound SMS

New Information for March 2024 for Sangoma UCaaS and SIPStation SIP Trunking Customers

In a Nutshell (tl;dr)

  1. The Campaign Registry is rejecting campaigns that point to a website that does not link to a Privacy Policy

  2. T-Mobile is no longer troubleshooting failed outbound SMS from their subscribers to SMS-enabled numbers that aren’t themselves registered for campaigns

Applicability

If you do not currently nor intend to ever send or receive any SMS/MMS traffic to a US-based mobile number using one of Sangoma’s UCaaS or CPaaS platforms or our SIPStation service, this message does not apply to you and you may ignore it.

If you have already registered your brand and campaign through Sangoma, you will need to take additional action if you receive a notification that your campaign has been rejected.

If you currently receive SMS from T-Mobile subscribers to DIDs that you purchase through Sangoma and you have not registered those DIDs, you should register those DIDs through Sangoma using Sangoma’s Campaign Registry tooling, otherwise Sangoma will be unable to assist you with failed receipt of messaging from T-Mobile subscribers.

Overview

Building on January’s enhanced enforcement of the “Call-to-Action” path, Sangoma is now seeing customers whose campaigns are being rejected because of a missing Privacy Policy on their company websites.

Further, Sangoma has also been informed that T-Mobile will no long assist in troubleshooting failed messages that originate from their subscribers and that are destined for SMS-capable DIDs, i.e. Sangoma or any other provider’s numbers, unless those DIDs are registered with an active campaign. This marks a change in enforcement, as previously, DIDs that only received messages did not have to be registered. Now, they do.

Users who have used our Campaign Registry tool website should check Sangoma’s Campaign Registry tool at Sangoma 10DLC Registration to see the status of their campaigns. 

Users of our Productivity Apps that have an embedded registration function should, if they receive a rejection notification, re-submit the campaign via the embedded registration capabilities.

These actions by The Campaign Registry are not within the control of Sangoma, or our carrier partners, and they apply to Sangoma and all other providers like Sangoma.

Frequently Asked Questions

Q: Is Sangoma responsible for this change?

A: No, we are not. We are subject to the same interoperability requirements as all other providers.

Q: Did Sangoma know about this in advance?

A: No. Sangoma discovered this at the same time as many others - when our customers began getting retroactive rejections. Sangoma is not manually pre-screening the information that our customers submit using our tooling.

Q: Is Sangoma profiting from these forced re-submissions of campaigns?

A: No. Sangoma collects a small fee on top of the actual Campaign Registry fees that covers our credit card processing fees associated with the transactions. The money collected is remitted to The Campaign Registry.

Q: Is there an alternative to The Campaign Registry for delivering SMS messages to subscribers of the major mobile carriers in The United States?

A: No. There is not. All providers, including Sangoma, must go through The Campaign Registry.

Q: If I’m using SMS in a way that doesn’t message customers, if I’m not trying to gather or sell business, am I still subject to the rules and regulations enforced by The Campaign Registry?

A: Yes. Everyone is subject to the rules and regulations enforced by The Campaign Registry. Neither you, nor anyone else is exempt. You still must adhere to the rules CTIA established by the CTIA (https://api.ctia.org/wp-content/uploads/2023/05/230523-CTIA-Messaging-Principles-and-Best-Practices-FINAL.pdf most recent copy). There’s no getting past this. The Campaign Registry is the gatekeeper for all A2P messaging to/from the mobile network operators / subscribers in the United States.

Q: Why is some SMS messaging inconsistent; for one user, e.g. Alice, messaging works both ways, and for another user, Bob, messages are received from Bob but not delivered to Bob?

A: We don’t know. The Mobile Network Operators require that campaigns be vetted and active in order to send messaging. Now, with this notice, we’re seeing that T-Mobile is also gate-keeping messaging received by providers as Sangoma from mobile subscribers. Unregistered campaigns from unvetted brands cannot be troubleshooted by Sangoma our partners, or any other provider.

Q: If my campaign has been rejected with something similar to the following “Unable to verify, needs compliant and accurate CTA information. (806)” what does that mean?

A: A message such as this will be seen whenever you don’t explicitly list the steps taken to opt-in or opt-out and if the person doing the vetting can’t follow the steps themselves. The Call to Action (CTA) steps should be specific enough such that anyone can follow them, e.g:

  • User browses to our website at https://www.example.com

  • User clicks on “Contact Us” in the footer of the website or in the main menu

  • User fills out the Contact Form with their information

  • User clicks a checkbox to indicate that they agree to receive SMS from our company

  • User submits form

When this kind of messaging is received, it’s likely because the steps that you provided were too ambiguous, e.g. “user goes to our website” but doesn’t list the website, is incorrect in its steps, or can’t be followed (e.g. there’s no actual “Contact Us” link).

If you see this message, you need to be looking at the “Call-to-Action / Message Flow” input box of the tool as well the functionality of your website and the availability of your website’s listed privacy policy.

 

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