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.
• Proof of Consent: Documentation that shows students have given explicit consent to receive SMS messages (explained below).

Proof of Consent:

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: Requirements

The following information is required for submission and should be documented and reproducible in the event of an audit:

Requirement 1: Verify that recipients provided explicit consent to receive messages

1. Description and copy of the method of consent (this could be a webform, a signed communications policy, a paper form, or even a verbal script if it is documented thoroughly).
2. A compliant method of consent will be similar to the following and include all of the elements listed below: I consent/agree to receive SMS text messaging from [institution name] and approved vendors regarding important updates, valuable resources, and general information. Message frequency may vary. Msg & data rates may apply.
   1. Clear statement of consent to receive SMS messaging
   2. The sender of the messages (optional if the verbiage does not explicitly state the institution)
   3. High-level description of message content
   4. Message frequency
   5. Disclaimer that message and data rates may apply
   6. NOTE: If the method of consent is a webform with a checkbox, the checkbox cannot be pre-checked.
   7. The method for collecting the recipient’s mobile number (This should be apparent if the method of consent is a webform or a signed paper form but may not be obvious if the method of consent is verbal.)
   8. While not technically required, it is a good idea to also capture the contact’s name and the date of collection.

Requirement 2: A compliant publicly available Privacy Policy

A compliant privacy policy will clearly state that no mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

Options for Requesting Consent:

When considering how to gather consent, look for opportunities with high attendance or interaction:

• Application or document submissions
• Forms that ask for contact information
• Websites or student portals that provide opportunities for setting communication preferences
• Event registrations/sign ups
• Email messaging describing your texting program
• Appointment scheduling

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.

Fall Semester 2025

As we prepare for the Fall 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

If your students opt in to receive Ana text messages, please ensure that the student list has been filtered to include only those students who have opted in or otherwise indicate whether a student has consented. Doing so helps us comply with best practices and legal requirements while ensuring students only receive messages they have consented to.

If you do not currently require students to opt-in to receive text messages, we encourage your institution to consider receiving consent to comply with industry best practices. More information is available under the “Proof of Consent” section of this page.