At Tatango we use the Mobile Marketing Association’s (MMA) U.S. Consumer Best Practices as any Christian would use the bible. This document guides every company’s decision in the world of mobile marketing and is looked to daily for both insight and resolution.
Have you ever read the full 165 pages of the MMA U.S. Consumer Best Practices? If you haven’t, you can download it here. Fair warning though, it reads like a technical manual so I would start off with a Red Bull before taking the plunge. Like any good technical manual, this document is extremely cut and dry, as it should be to protect consumers in what some are still calling the “wild west” of mobile marketing.Like the Christian Bible, there are parts of the MMA U.S. Consumer Best Practices that at times can be confusing to one that studies it as intimately as I have. Unlike the Christian Bible though, the authors are still alive and that’s why I write this open letter to you at the Mobile Marketing Association, to ask for a revision of this document.
Why do I ask for a revision of your best practices? In section 1.5-5 of the document you state:
“Subscriber may initiate opt-in from a paper-based consent form.”
In plain english, this means a customer can ask to receive SMS messages from a business by writing their mobile phone number down on some sort of paper form. The problem though is that in section 1.5-3 you state:
“When opt-in occurs via the web or other non-mobile point of origination, the content provider must obtain verification that the subscriber is in possession of the handset being opted-in to the service.”
In plain english, the business has to confirm that that the customer is writing down their own mobile phone number, not the mobile phone number of a friend, relative or a random combination of 7 digits. When trying to apply this to a paper-based consent form, I would have to quote the French: c’est impossible!
This verification process is possible with both a Web and mobile originated opt-in, but not with a paper-based consent form. With an opt-in from a web interface you recommend a “PIN code” be sent to the subscribers mobile phone, which then is entered back into the web interface to confirm possession of that mobile phone. With a mobile originated opt-in (i.e. Text PIZZA to 68398) the mobile originated message itself verifies mobile phone possession. As I see it, there is no possible way to obtain verification that the subscriber is in possession of the handset when opting into an SMS campaign from a paper-based consent form.
My solution, the phrase “Subscriber may initiate opt-in from a paper-based consent form” must be permanently removed from the Mobile Marketing Association U.S. Consumer Best Practices. By removing this phrase, you are not only making your document clearer to understand and implement, you will also be eliminating the majority of SMS spam. Without paper-based consent forms, SMS providers will no longer be able to use this loophole to justify letting their clients directly import mobile phone numbers into an SMS campaign. Once revised, all SMS providers will be required to use either a web interface or mobile originated opt-in, thus preventing the death of SMS marketing.
Derek Johnson, Founder & CEO of Tatango.com