In an effort to reduce spam and tackle fraud, mobile carriers require businesses that send SMS messages to register their toll free numbers. Verified toll free numbers have a Verified tag that accompanies the message along its way to the recipient.  Messaging traffic that does not have an accompanying Verified tag are not delivered.

The mobile carriers have total control over the messages they deliver to their cell phone customers.  They simply will not deliver any messages from a toll free phone number that has not been verified.

Submitting your number for the Toll Free Verification (TFV) process does not guarantee that your business won’t experience any blocking.  Your message content and practices must be aligned with industry guidelines, and you must message within the use case that you defined during your verification process.  Mobile carriers are using AI to help filter Severity Zero (Sev-0) content like SHAFT-C, high risk financial services, get-rich-quick schemes, etc. that are prohibited in business messaging.  Businesses are expected to message their end users within the operating guidelines of their business.

To avoid message blocking, you will need to submit your toll free numbers for verification.   You may only verify one toll free number per use case.

Once your toll free number is verified, you are approved for messaging to the US and Canada.

Messaging from Local Numbers has a different compliance mechanism. To learn more, visit our article 10DLC Messaging Compliance.

Website Pre-Requisites

To receive approval for your toll free verification, your website must pass the messaging aggregator’s compliance review.  You will need to make sure your website contains the following recommendations.  We know it is no small request to make changes to your website.  There are expected declarations that you must publicly state regarding how you protect the information that you collect.  You must implement these website changes before you submit your campaign.

1. Privacy Policy Requirements

A privacy policy is a statement that describes how a website collects, uses, and manages the personal data of consumers. This type of policy will be specific to your business industry and include detailed descriptions regarding your data collection process.  You may call this statement on your website a Privacy Policy, Terms of Use, or Terms of Service.  Regardless what you name your policy, make sure you implement the following requirements.

Easy -To-Find: The messaging industry requires that your website have an easy-to-find Privacy Policy.  Most websites have a link in the footer so that it is displayed at the bottom of every page. Sometimes in on a Legal page with other declarations.  Make sure your placement of the link is intuitive and visible.

Mobile Data Statement:  Your policy must explain how you protect the mobile information that you collect.  You also cannot share the consent that you obtain. Please add the following statement to your Privacy Policy.

By providing your wireless phone number to [insert your company name], you agree and acknowledge that [insert your company name] may send text messages to your wireless phone number. Message and data rates may apply. Message frequency may vary. You may opt-out at any time by replying “Stop”.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Notwithstanding any other statement within this privacy policy, originator opt-in data and consent will never be shared with any third parties.

2. Webforms

If you collect a phone number on a contact form, quote request, point of sale, etc. on your website, your form must contain consent language.  Here is an example of a webform consent statement with a checkbox:

▢ I consent to receive text messages and voice calls. Frequency may vary. Mobile message and data rates from your cell phone carrier may apply. I understand I can opt-out at any time by texting Stop.

You may state this differently according to your messaging use case. Consider what else you are gathering on your webform and what you may need consent for.  Note that our example also says ‘and voice calls’.  There may be other declarations you must state here.  Just looking through the lens of business messaging, the following consent elements are required:

Consent:  You must ask for consent.

Frequency:  You must state how often you will message, like once daily, once a week, or variable due to conversational messaging.

Messaging and Data Rates:  You must inform that costs may be involved.  This specifically refers to costs charged by their mobile carrier.

Opt-Out:  You must remind them that they can opt out at any time and how to do it.

We recommend that you make your webform consent mandatory.  To do this, you would disable the submit button on the form until the consent checkbox has been checked.  This ensures that you always know the individual who contacted you has consented to messaging.

You should always track the consent you are granted in their customer, employee or prospect CRM record.

No Website?

If your business operates without a website, you must still have an online presence for your business.  TCR requires that you provide a URL to a platform where you have a business profile.  For example, you might have a business profile on a social media platform like LinkedIn, Instagram, YouTube, Facebook, etc.  On that platform, you must implement all their website requirements.

1. Your profile must demonstrate to TCR the legitimacy of your business. It must clearly explain the products and services you provide.
2. You must have a Privacy Policy either in a post you pin to the top, or in your profile’s About section. It must contain the two paragraphs of legal language provided above.
3. You must have consent language in place anywhere you collect a mobile number.

Prohibited Content

The following types of content are prohibited for business messaging:  Sex, Hate, Alcohol, Firearms, Tobacco, and Cannabis –otherwise knows as SHAFT-C.  Not only is this content prohibited from the messages that you send, it is also prohibited on your website.  During campaign review, if any content is found in these categories, the campaign will be rejected.  One of our carriers describes it this way:  If a chiropractor’s office has CBD oils on its website, the campaign will be denied even if not directly related to CBD marketing.  SHAFT-C is not allowed to be on the business website at all.  However, Alcohol and Tobacco can be supported if there is robust age-gating and proper opt-in.

Filling out the Verification Form

During your email-texting onboarding, you will be sent the verification form with instructions.  We will submit your verification on your behalf where it will undergo a review. Upon submission, the messaging aggregator will review your campaign information as well as your website to make sure everything is in compliance with industry standards. Anything found out of order will result in a rejection. Here are a few tips to help you get a quick approval.

Use Case Summary

Explain in detail the type of messaging communication that you send, who you will be sending messages to, and what you intend to accomplish in this communication.

Opt-In Process

You will need to describe in detail your opt-in process for every method by which you collect a phone number.

Consent: Your message recipients must opt-in to receive your business messages.  Consider who you will be messaging, how you will obtain their phone number, and how you will gain consent to message them.  You are expected to describe this opt-in process on your submission.

Consent cannot be shared, sold/bought, or transferred to additional services or senders. In other words, you can buy a list of phone numbers that you’d like to message but any consent they gave to the other entity doesn’t transfer to you.  You will need to implement an approved method for gaining your own consent from those you wish to message.

Approved Methods:  Most businesses typically collect their prospects, customers, or patients’ mobile numbers in a variety of ways, so make sure you clearly explain each method you use and how you gain consent for each one.   This consent explanation goes in the Call To Action & Message Flow section on your campaign form.

The following list are the approved methods for obtaining a mobile number and requesting messaging consent:

Voice/IVR Opt-In	You may collect a phone number and consent to send messages verbally over the phone or by IVR.  You must record this consent in their CRM record.
Keyword or QR Code Opt-in	Explain where prospects might find your Keyword or QR Code.
POS (Point of Sale)	Explain how the phone number and consent is granted and recorded at POS.
Paper form	This includes hiring paperwork, patient intake form, services contract, etc. Explain how you use a paper form to gain consent.
Webform	If you collect consent via any type of webform (like a Contact Us form), you must provide a consent statement on the form.  We recommend that you obtain express consent on your webforms.  To accomplish this, you would disable the submission button until they check the consent checkbox. This ensures that they know they are consenting to receive text messages.  Make sure your consent statement clearly states message frequency and a way to opt out. Please see the example given in the Website section below.

Screenshot of a Consent Example

You must provide a URL to a screenshot or image showing one of the ways you gain consent.

Sample Messages

Provide sample messages that demonstrate your most common message you will send, a message demonstrating how you send a link or a phone number, or any other message that would substantiate your use case or a consent method.

Form Submission

Once your website pre-requisites are completed and we receive your verification form, we will turn in your verification on your behalf.   We typically receive a response in 2 – 3 business days–either approved or rejected.  If rejected, we will be given a reason why.  You can work to correct the issue and then we will resubmit your verification again.

Messaging Compliance Support

Please contact our team if you have any questions at support@email-texting.com or 866-923-5290.  We know this is a lot to digest and we are here to help!

Messaging Industry Resources

If you would like to learn more about the messaging industry’s expectations for business messaging, The Campaign Registry, or best practices for your business to adopt, please refer to the following resources:

The Campaign Registry
https:/www.campaignregistry.com/

CTIA Messaging Principles and Best Practices
https://api.ctia.org/docs/default-source/default-document-library/170119-ctia-messaging-principles-and-best-practices.pdf

MMA Best Practices
https://www.mmaglobal.com/files/bestpractices.pdf

M3AAWG Best Practices
https://www.m3aawg.org/sites/default/files/m3aawg-mobile-messaging-best-practices-service-providers-2015-08_0.pdf

Telephone Consumer Protection Act (TCPA) Omnibus Declaratory Ruling (FCC 15-72)
https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-72A1.pdf

FTC Truth in Advertising
https://www.ftc.gov/news-events/media-resources/truth-advertising