Use of University Text Messaging Services
Sponsor: |
Vice President for Enrollment Management and Marketing |
|---|---|
Contact: |
CRM Operations Manager |
Category: |
Information Security and Technology |
Number: |
1000.013 |
Effective Date: |
2024/02/07 |
Implementation History: |
First draft 7/1/2021, second draft 5/12/2022 third draft 1/2/2024 |
Keywords: |
Text, Mobile Phone, SMS, Short Code, Long Code |
Background Information: |
Purpose
This policy establishes how Empire State University (SUNY Empire) uses SMS/text messages to communicate with prospective and current students in compliance with internal and external regulations and policies.
This policy respects and maintains individuals’ rights and privacy, while maximizing efficiency and effectiveness of communications that align with SUNY Empire’s mission, values, and marketing strategy.
Definitions
Proxy number: Texting that originates from an individual at the university, even though the number displayed to the recipient is not the sender’s phone number. The sender may be using an application to send the message to an individual or group of individuals.
Statements
Scope
The scope of this policy is limited to application-to-person texting (A2P). This includes texting that originates with an individual at the university using a proxy number.
Anyone wishing to send SMS/text messages to prospects (inquiries), applicants, or students to conduct university business, will do so through one of the university’s approved customer relationship management (CRM) applications or student information systems (SIS).
Authority
To ensure messages align with SUNY Empire branding, marketing strategy, and values, and to ensure compliance, all SMS/text messages must be approved by the appropriate individual as follows:
- The vice president for enrollment management and marketing will oversee texts sent to prospects and applicants.
- The associate provost for student success will oversee texts sent to students.
- The assistant vice president of operations will approve text messages sent for emergency purposes and information technology updates.
Each approver may assign a designee. Approvers and designees are encouraged to ensure message frequency, format, and intent align with the university’s communication plan. Approvers and designees have the authority to review all SMS/text messages within the scope of this policy, including but not limited to the content, target audience, purpose, and timing of messages. Approvers and designees have the right to request revisions and/or deny proposed SMS/text messages. All outgoing text messages will be recorded in the CRM.
At the point of initial contact with the student or prospective student, the individual will be asked to provide a mobile number for receipt of text messages. The university will inform the student that by providing a mobile number, he/she/they are opting into receiving text messages for marketing, enrollment, and other university-related purposes. The individual will also be informed of the right to opt out of receiving such messages.
The format of this notice will be as follows (this may change slightly in form, but not substantive content):
Please provide a mobile telephone number for receipt of SMS/text messages from the university.
Mobile Number: ______________________
By providing my mobile telephone number, I agree to receive text messages from Empire State University. Messaging and data rates may apply. You may opt out of text messaging below.
__ I do NOT wish to receive text messages from Empire State University. Please remove my number from the list.
The first text message sent to students and prospective students will also include the following language (or similar language) and will be included at least once a year:
Empire State University uses text messaging to communicate important information with students and prospective students. If you do not wish to receive text messages from us, reply STOP to opt out. For more information, reply HELP.
No SMS/text message will be sent to an individual who has opted out of receipt of such messages.
Requests for opt-in/opt-out will be processed as they are received.
Content
All SMS/text messages will advance the university’s mission in accordance with the university’s core values. SMS/text messages will be used to communicate important information and enhance existing communications.
Sending
All text messages will:
- Display appropriate keywords, messages, descriptions, and disclosures as applicable
- Return a message with instructions on how to contact Empire State University for assistance when the recipient responds with the keyword “HELP”
- Follow Contact Center Compliance guidelines, which can be found at dnc.com
- Not be sent during a declared emergency unless the text relates specifically to the emergency and benefits the individual's safety and/or promotes student success
Data privacy
SUNY Empire is a good steward of information, respecting the privacy of our prospective, current, and graduated students, as well as employees. Information security policies can be found on the university’s webpage for policies at www.esc.edu/policies. The privacy of all students is protected by the Family Educational Rights and Privacy Act of 1974 (FERPA). The use of the university’s SMS/texting services requires the university to collect and share directory information as defined by the university’s policy “Adherence to Family Educational Rights and Privacy Act of 1974.” For additional information on FERPA, and to prevent disclosure of directory information, visit the university’s FERPA information webpage.
More information about data security, including information for prospective students and employees, can be found in the university’s policy for “Enterprise Data Classification” and the “General Data Protection and Regulations Privacy Policy” for students in countries that are members of the European Union.
To facilitate text messaging services, SUNY Empire contracts with a third-party vendor. Directory information, as defined by the university's FERPA policy, is shared with the vendor. SMS/text messages are not student records and are not retained in accordance with the university’s Record Retention Policy.
Texting SUNY Empire may result in an unintended sharing of personal data. As such, if a student initiates a text conversation with SUNY Empire that contains sensitive information, the student will be reminded of their information security rights and provided the option to continue the conversation in another format, such as email or the telephone. SMS/text messages are sent using a proxy number.
Employees who send and/or receive text messages or A2P text messages on behalf of Empire State University are required to affirm their compliance with this policy.
Procedures
Requests to have a SMS/text message sent on behalf of the university to current students can be submitted to the appropriate approver or designee, as determined by the audience, via request to the Office of Academic Affairs. Be prepared to state the intended target audience, intended message, purpose, frequency of text messaging, and the timing and execution of such messages.
Related References, Policies, Forms and Appendices
Related References
CTIA: https://www.ctia.org/
TCPA: https://www.fcc.gov/document/telephone-consumer-protection-act-1991
Related Policies
Adherence to the Family Educational Rights Privacy Act
General Data Protections Regulations
Use of University Name and Wordmark Policy
Aggressive Recruitment