{
  "id": "POL-062",
  "slug": "pol-062",
  "title": "A general permission to share data with other companies fails even where SMS is never named",
  "statement": "A policy permitting personal data to be shared with other companies is rejected whether or not it mentions SMS.",
  "rationale": "Naming SMS is what makes a non-sharing clause count in the brand's favour, but not naming it does not let a general sharing clause escape — the phone number is personal data, so a permission covering personal data covers it. Businesses reason the opposite way round, adding a careful SMS paragraph while leaving the general sharing section untouched because it says nothing about texting.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy body (whole document)",
  "severity": "BLOCKING",
  "detectability": [
    "AI_FORM"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "Bandwidth"
  ],
  "codes": [
    {
      "provider": "Bandwidth",
      "code": "7103",
      "remediable": true
    }
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Narrow the general sharing section to named categories of service providers acting for you, or exclude messaging data from it in the section itself. Done when no clause in the document permits personal data to reach another company for that company's own use.",
  "example": "We share personal information only with service providers acting on our behalf. We do not share personal information with other companies for their own purposes, and text messaging opt-in data and consent are excluded from all sharing.",
  "notes": "Fenced against its neighbours: POL-064 is about clauses permitting sharing FOR MARKETING, this one about a general permission with no purpose stated; POL-069 is the contradiction between such a clause and the SMS one, and POL-070 the same contradiction across two documents.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-062/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-062.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}