425 Broadcast Text Messaging

RATIONALE: Text messaging is a method of communication that Oakland University (University) may utilize to communicate with the University community. Messages may be delivered to broadcast distributions, targeted groups, or individuals. Authorized University Offices may use Broadcast Text Messaging after obtaining approval of a communications plan by University Communications and Marketing (UCM). Broadcast text communications must adhere to Federal Communications Commission regulations, industry standards, and campus protocols. This policy is intended to provide guidelines for the appropriate use of Broadcast Text Messaging.

POLICY:

1. An individual must "opt-in" (called "Prior Consent") to receive a Broadcast Text Message for each category of "message intent", (i.e., an individual cannot opt in for emergencies and get Broadcast Text Messages about registration). Providing a mobile number directly to the University is considered an implicit opt-in within its context (e.g. providing mobile number on admissions application provides implicit opt-in for enrollment-related messages).
2. Any Authorized University Office can send one text content Broadcast Text Message to a phone number for the specific message intent. If, after that communication, the University is notified that the individual no longer wishes to receive Broadcast Text Messages, the University office or department must remove the individual from all future Broadcast Text Message deliveries for that specific intent.
3. Any Authorized University Office must periodically check phone numbers designated to receive Broadcast Text Messages for validity to an individual. There are external services that can be purchased to check the numbers or senders can send requests asking individuals to verify that they wish to continue to receive messages. This step ensures that the number on record is still associated with the person on record. If the number on record is no longer registered to the person on record, the number must be removed from all future deliveries.
4. The individual receiving messages may be charged a fee to send or receive messages, based on the terms of the individual’s mobile service provider. The University is not responsible for any individual’s fees.
5. Broadcast Text Messages should generally be limited to a full message in a single text, typically no more than 160 characters.
6. The University is not liable for any delays in the receipt of any Broadcast Text Messages.
7. Broadcast Text Messages must not be used as the sole means of communicating an essential message or announcement. An essential message is defined as content that is urgent in nature or where time is of the essence.
8. OU AP&P Policy #880 System Administration Responsibilities must be followed for the acquisition of a service for Text Messages.

SCOPE AND APPLICABILITY: All Broadcast Text Messages originating from an Authorized University Office, or from any authorized University employee acting in a professional capacity on behalf of the University, are covered by this policy. Broadcast Text Messages are intended to provide an additional channel for desired communications. The purpose of sending Broadcast Text Messages should match the recipient’s expectations for the message content of the particular channel. For the purposes of this policy, texts sent as part of Oakland University's Comprehensive Emergency Response Plan are not considered Broadcast Text Messages.  

DEFINITIONS:

Broadcast Text Messaging and Broadcast Text Messages: Unidirectional Text Messages sent to a large audience, and not intended to be individual personal conversations. However, implemented systems may support subsequent conversations.

Prior Consent: Permission given in advance of broadcast text message being sent, with record of permission kept in a database. Within this policy, the term "opt-in" is synonymous with Prior Consent.

Message Intent: the general type of content a group of messages contain. Message intents may be further subdivided (e.g. enrollment may be subdivided into registration, billing, etc.) to allow individuals finer grain control.

Text Messages: Electronic messages sent through a messaging service, usually sent from one cell phone or a cell messaging service to another individual cell phone. Messages are usually text, but some technologies also support voice, image, and video messages. For the purpose of this policy, text, voice, image, and video messages are collectively called Text Messages.

Authorized University Office: Office and/or Department authorized by the Divisional Vice President.

PROCEDURES:

Authorized University Offices may use Broadcast Text Messaging after obtaining approval of a communications plan by University Communications and Marketing (UCM). Examples include but are not limited to relaying information about admissions, academic requirements or deadlines, registration information, course cancellation, billing, financial aid and other matters that are time sensitive and necessary for enrollment and student success.

Authorized University Offices, in collaboration with UCM, must appoint at least one official who will be responsible for monitoring and approving Broadcast Text Messaging requests on behalf of their department to ensure compliance with the following:

1. Individuals must provide Prior Consent to receive Broadcast Text Messages and ensure their contact information held by the University is current.
2. Authorized officials must abide by all other policies regarding content, as well as ensure the following:
   1. Content is accurate.
   2. Wording is appropriate.
   3. Tone is casual but professional and ends with a question when a response is desired.
   4. List of recipients is correct.
   5. Information within the Broadcast Text Message is directly related to the individual and/or their studies.
   6. Broadcast Text Message clearly states the action that the individual needs to take or how the information impacts the individual and who to contact for additional information.
   7. Number of Broadcast Text Messages received by an individual should be appropriate to ensure he/she will continue to regard the Broadcast Text Messages as important information.
   8. Broadcast Text Messages are sent with adequate time for the action or activity.
   9. Periodically verifying the phone numbers used for the delivery of Broadcast Text Messages.
   10. Immediate removal of individuals who remove Prior Consent by requesting removal or through delivery failure of a Broadcast Text Message.
3. Broadcast Text Messaging must not be used as the sole means of communicating an essential message or announcement. The Broadcast Text Message must be supplemented by some other means of communication, such as an email or paper notice, to ensure that all individuals, including those who have not opted-in, receive the message. Broadcast Text Messaging must NOT be used for the following:
   1. Sending general information to large populations (e.g., "Fall classes start Monday!").
   2. Personal matters (e.g., items for sale, farewell messages).
   3. Appeals on behalf of individuals or groups of students (e.g., to attend social, cultural or sporting events, unless the individual opted-in for text messages regarding these topics).
   4. Sending any social security numbers, passwords, payment card numbers, or other highly-sensitive information.
4. Use of Text Messaging must be consistent with the provisions of state and federal law, including the Family Education Rights and Privacy Act of 1974 (FERPA).
5. Users of Text Messaging must recognize that it is inherently insecure from send point to end-point, and as such, reasonable care should be taken not to disclose Confidential Data to unauthorized individuals.
6. All initial Broadcast Text Message conversations must be tagged with the appropriate identifier so recipients can immediately recognize the Broadcast Text Message sender.  For example, if an authorized official is sending an initial Broadcast Text Message, open with  "Hi, it's Chris Smith from OU Admissions."
7. Broadcast Text Messages should be as concise as possible (while still maintaining a conversational tone when appropriate) and should address the individual directly (e.g. "Your OU financial aid form is due on Friday," rather than, "Financial aid forms are due on Friday."). They should include essential points and, if needed, further instruction (e.g. "Check your OU email for full details.").
8. Abbreviations and common messaging lingo may be used as deemed appropriate for the audience or situation.
9. University Technology Services must approve all messaging services and all messaging software.

RELATED POLICIES AND FORMS:  

OU AP&P #860 Data Management and Information Security

OU AP&P #880 System Administration Responsibilities

APPENDIX: