Overview

As part of Upswing's commitment to compliance and effective communication, we require all partner institutions using Ana to adhere to certain messaging policies. These policies ensure that SMS messages sent through Ana are compliant with industry regulations and reach your students effectively. This article provides an overview of the required registration process, the rationale behind these policies, and the information required from our partners to meet these requirements.

Why is Registration Required?

To send SMS messages as Ana, Upswing uses 10DLC (or 10 digit long codes) phone numbers. In general, 10DLCs are used for Person-to-Person (P2P) communication. However, with Ana, we are using 10DLCs for Application-to-Person (A2P) communication. Because of this, we are required to complete the 10DLC A2P registration process to prevent our messages from getting filtered as spam messages by phone service providers. 

Applications sending text messages to people (A2P) have a high potential for abuse since high-volume messaging can be sent out easily to people who do not want to receive these messages. Therefore, we must comply with the Telephone Consumer Protection Act (TCPA) and the Cellular Telecommunications Industry Association's (CTIA) messaging principles and best practices in order to send text messages on behalf of our partners. Ultimately, the intent is to ensure that messages consumers receive are messages that they actually want to receive.

Requirements for Registration

To register, partner institutions must provide the following information:

• EIN (Employer Identification Number): A unique identifier for the institution required for the registration process.
• Legal Organization Name: The official name of the institution as it appears on tax or business registration documents.
• Organization Address: The physical address as recorded in official documents.

Additionally, our partners have to provide us with documentation showing that their students have given their explicit consent to receive SMS messages through Ana. This can typically be provided using your institution’s existing communications policy or by implementing an opt-in process, explained further below.

Ensuring Compliance: Opt-In Methods

Partners need to ensure that students are legally able to receive SMS messages. Here are some methods institutions can use to verify consent:

Option 1: With an Existing Communications Policy

If your institution already has a Communications Policy that includes SMS messaging and requires student consent, this policy can be used to meet compliance requirements. This is the best method for capturing consent because it is already in place and students are typically required to sign it during registration. Your HERO will work with you to review your existing Communications Policy to ensure it includes approved language around SMS messaging and that students are required to sign it. 

Example of an Existing Communications Policy:

"As a part of Smarter College advisory and student support services, Smarter College staff, volunteers, and approved vendors may communicate with students on their personal phones through texts and/or phone calls. I consent to have Smarter College staff, volunteers, and approved vendors communicate with me via text and/or phone calls."

Option 2: Opt-In Questionnaire or Form

If an existing Communications Policy or other document with approved language does not exist or does not cover SMS messaging from approved vendors, creating an opt-in process is an alternative. This could be a questionnaire or form that students sign, indicating their consent to receive messages from the institution and its approved vendors.

Example of an Opt-In Questionnaire or Form:

Option 3: Implementing a Sign-Up Form

If approved language does not exist, institutions can create a sign-up form on their website. However, this method is less effective, as there is no guarantee that the students will access this page or actively sign up. In order to make this method more effective, we recommend providing this form to students during a highly attended or required event such as orientation where students are already actively engaged.

Example of a Sign-Up Form:

A form on the institution's website where students can enter their phone number and consent to receive SMS updates. This should be promoted during high-attendance events for maximum engagement.

Next Steps for Partner Institutions

1. Review Existing Communications Policy:
   Verify if your institution’s current Communications Policy includes SMS messaging from approved vendors and that students have consented to receive these messages.
2. Implement an Opt-In Process:
   If your institution does not have an acceptable Communications Policy already in place, meet with your HERO to discuss the best option for an opt-in process for your institution.
3. Provide Required Information for Registration:
   Provide your HERO with the organizational information and student consent documentation so that we can complete the registration process for your institution.

By following these steps, we can ensure that our messaging practices are compliant, which will reduce the risk of message filtering and improve the reliability of communication through Ana.

For any questions or further assistance with the registration process, please contact your HERO.

Spring Semester 2025

As we prepare for the Spring Semester of 2025, we want to ensure that your use of Ana remains seamless and impactful. To that end, we kindly ask all partners to follow the updated guidance below:

Uploading Student Lists

When submitting a student list for Ana communications, please ensure that the list has been filtered to include only those students who have opted in to receive Ana communications. Providing a filtered list helps us comply with best practices and legal requirements while ensuring students only receive messages they have consented to. 

We still accept unfiltered student lists if necessary. However, it is important to note that, if a partner does not:

1. Have a communications policy on file with Upswing detailing how students opt-in to Ana communications, AND
2. Provide a student list filtered for students who opt in,

Then Ana services may be at risk of suspension. This is not a decision made by Upswing but a measure we may be required to take in the event of an audit to ensure compliance.