Opt-out records must not be shared onward
The requirementstatement
The published policy must not permit sharing or forwarding opt-out records to unaffiliated parties without the consumer's prior express permission.
- Severityseverity
- MediumMEDIUMUsually survives review, but lowers your trust score or invites a manual look you would rather avoid.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- privacy policy + SMS terms
- Where it liveslayer
- OperationalOPERATIONAL
- How Ekas settles itdetectability
- AI · crawlCRAWL
- Needs your live site or policy page fetched and read. Ekas crawls it the way a reviewer would.
- What the fix involvesfailureClass
- Fix the policyTERMINAL_POLICY
- The fix lives in your privacy policy or SMS terms. Ekas can generate the missing clauses.
- Who requires itauthorities
- FCCCTIA
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
A suppression list is a list of people who asked a specific sender to stop, and passing it on turns a refusal into a marketing asset — the consumer discovers that saying no put them on a new list. Policies allow it by accident: a general "we may share data with partners" clause written for analytics also covers the suppression file, because nobody carved it out.
How to fix itremediation
Add a sentence to the SMS section stating that opt-out and suppression records are used only to stop messages and are never sold, rented or shared. Done when a general sharing clause elsewhere in the policy no longer reads as covering them.
A compliant exampleexample
Opt-out requests are recorded and used solely to suppress further messages. We do not sell, rent or share opt-out records with any third party.
Common mistakespitfalls
- A carve-out in the SMS section does not help if a broader sharing clause earlier in the policy is unqualified — reviewers read the permissive clause as controlling.
Rules you will hit next
Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.
OPS-032A help request containing a stop-word is not an opt-outMediumMEDIUMOPS-042Somebody has to own revocations that arrive in conversationMediumMEDIUMOPS-050The opt-out confirmation is worth sending inside five minutesMediumMEDIUMOPS-051Only ask which messages to stop when there is more than one kindMediumMEDIUMOPS-057Log the sends you did not makeMediumMEDIUMOPS-062An opted-out consumer must be able to come backMediumMEDIUM
OPS-063 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.