{
  "id": "CON-017",
  "slug": "con-017",
  "title": "An offline opt-in still needs a findable business behind it",
  "statement": "A brand collecting consent entirely offline must still have a verifiable online presence a reviewer can find.",
  "rationale": "With no opt-in URL to inspect, the website is the only independent evidence that the business exists and does what the campaign says. A brand that is invisible online and collecting numbers on paper is indistinguishable, from a reviewer's side, from one that does not exist — which is why offline programmes are held to a higher bar on the brand record rather than a lower one.",
  "layer": "CONSENT_FLOW",
  "layerSlug": "consent-flow",
  "object": "brand website vs offline consent method",
  "severity": "HIGH",
  "detectability": [
    "CRAWL"
  ],
  "failureClass": "TERMINAL_WEBSITE",
  "authorities": [
    "TCR",
    "Twilio",
    "Bandwidth"
  ],
  "applicability": {
    "consentMethods": [
      "paper",
      "pos",
      "verbal_live",
      "verbal_ivr",
      "employer_hr"
    ]
  },
  "applicabilityText": "Applies when consent was collected by paper form, point of sale, live verbal, IVR and employer / HR.",
  "universal": false,
  "remediation": "Supply a website that names the business, describes what it does, and carries the SMS terms and privacy policy. Where the business genuinely has no site, a complete and consistent listing — a verified profile with the same name, address and phone as the brand record — is what a reviewer will look for instead. Done when the campaign can be corroborated without the opt-in surface.",
  "pitfalls": [
    "A social profile alone rarely satisfies this, because the policy pages have nowhere to live on it."
  ],
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/consent-flow/con-017/",
  "markdown": "https://ekas.io/rules/10dlc/consent-flow/con-017.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}