Ana SMS Text Messaging Approval Guidelines

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).
  • Privacy Policy: Publicly available web page that clearly indicates what and how data is used (explained below).
  • Terms and Conditions: Publicly available web page that outlines what subscribers can expect from SMS communication (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 could be included in a communications policy that the student signs, a webform that the student completes, or even verbal consent if it's thoroughly documented and contains the necessary verbiage.

What to Include

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

  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: 

    • Clear statement of consent to receive SMS messaging (e.g., "I consent to receive SMS text messages from [organization name] and approved vendors.")

    • Students can decline messaging consent and still take advantage of your organization's services.

    • Consent for messaging is separate from general Terms of Service or Privacy Policy.

    • High-level description of message content (e.g. "school resources, important reminders, and motivation throughout the semester")

    • Information about message frequency (e.g., 2 messages/week)

    • Disclosure of message and data rates (e.g., "Msg & data rates may apply")

    • How to opt-out (e.g. "Reply 'STOP' at any time to opt out of messages.")

    • The method for collecting the recipient's mobile number (usually apparent if method of consent is a webform or a signed paper form, but not obvious if method of consent is verbal).

    • While not technically required, it is a good idea to also capture the contact's name and the date of collection.

Opportunities 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

Privacy Policy

Your Privacy Policy must clearly indicate what student data is collected and how the student data will be used. Explicitly state that no mobile information will be shared with third parties for marketing or promotional purposes.

What to Include

  • Type of data collected

  • Data usage

  • Third-party data sharing policies

  • User rights regarding data 

Sample Content

Privacy Policy

Type of data collected: [Organization name] collects your mobile number and message engagement data. This information is used solely for the purposes outlined in this policy.

Data collection methods: We collect your phone number through our signup form (URL for signup form).

Data usage: We use data to send messages related to student support, encouragement, reminders, and other program-related updates. Your information helps us provide relevant, timely SMS communication.

Third-party data sharing policies: No mobile information will be shared with third parties for marketing or promotional purposes.

User rights regarding data: You can access, update, or delete your personal data by contacting us at [organization email address]. You can also opt out any time by replying STOP to any message.

SMS Terms and Conditions

SMS Terms and Conditions establishes the legal rules of engagement between your organization and its mobile subscribers. It outlines what subscribers can expect from your SMS program.

What to Include

  • SMS program description

  • Message frequency

  • Opt in method

  • Opt out method

  • Interruption disclaimer

  • Costs

  • Privacy

  • Help

Sample Content

[Organization name] SMS Terms and Conditions

SMS program description: By opting into our SMS messaging program, you agree to receive text messages related to student support, encouragement, reminders, and other program-related updates.

Message frequency: Message frequency is approximately 3-4 messages per month. Message and data rates may apply. Consent to receive messages is not a condition of participation in any [Organization name] program or service.

Opt in method: You can subscribe to receive messages by completing our signup form: [URL for signup form]

Opt out method: You may opt out at any time by replying STOP to any message.

Interruption: Carriers are not liable for any delayed or undelivered messages.

Costs: No additional fees are charged by [Organization name] for participation in this messaging program. Message and data rates may apply.

Privacy: If you have any questions regarding privacy, please read our Privacy Policy: [URL for Privacy Policy]

Help: If you have any questions about the SMS terms and Conditions, please contact us at [organization email address]

Fall Semester 2026 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.