{
  "id": "POL-045",
  "slug": "pol-045",
  "title": "An offline opt-in does not relax the policy content requirements",
  "statement": "The policy pages must satisfy the full content requirements even where opt-in never happens on the web.",
  "rationale": "Programmes that collect consent on a call, on paper or at a counter tend to treat the website as decoration, so the policy is whatever was published years ago — and the reviewer applies exactly the same content checks to it as to an e-commerce brand. Nothing about collecting consent offline reduces what the consumer is entitled to read.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy body + terms body",
  "severity": "BLOCKING",
  "detectability": [
    "CRAWL"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "AWS",
    "Twilio",
    "Bandwidth"
  ],
  "applicability": {
    "consentMethods": [
      "verbal_live",
      "verbal_ivr",
      "paper",
      "pos",
      "imported"
    ]
  },
  "applicabilityText": "Applies when consent was collected by live verbal, IVR, paper form, point of sale and imported list.",
  "universal": false,
  "remediation": "Bring the published policy and SMS terms up to the same standard a web opt-in would need — the mobile non-sharing clause, the programme description, frequency, rates, STOP and HELP — before submitting the offline flow. Done when the documents would pass on their own, with the consent method left out of it.",
  "notes": "An anti-exemption rule: it exists to be applied to registrations that assume the requirements are lighter, and it points at the rest of the layer rather than adding a requirement of its own.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-045/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-045.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}