Consent must not be described as transferable or assignable
The requirementstatement
The policy and the SMS terms must not describe messaging consent as transferable or assignable between businesses.
- Severityseverity
- BlockingBLOCKINGBreaking this rule gets the submission rejected. There is no partial credit.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- privacy policy and SMS terms body
- Where it liveslayer
- Policy pagesPOLICY_PAGE
- How Ekas settles itdetectability
- AI · formAI_FORM
- A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
- 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
- CTIATwilio
- When it appliesapplicabilityText
- Applies to every 10DLC registration.
Why this rule existsrationale
CTIA states plainly that an opt-in should not be transferable or assignable, because the consumer agreed to hear from one named business and cannot be taken to have agreed to hear from its successors or affiliates. The wording usually arrives inside a boilerplate assignment clause covering the whole agreement, drafted with contracts in mind rather than consent.
How to fix itremediation
Exclude consent from the assignment clause explicitly, and state in the SMS terms that the opt-in applies to this brand alone. Done when no clause lets the consent travel with a sale of the business.
A compliant exampleexample
We may assign this agreement, but your text messaging consent applies only to Acme Coffee and is not transferred or assigned with it.
Provider rejection codescodes
The code you get back when this rule is what failed, and whether that provider lets you resubmit.
| Provider | Code | Resubmit |
|---|---|---|
| Twiliogen2 | 30932 | Yes |
Notesnotes
The positive form of the same requirement is POL-191, which asks the SMS terms to state that the opt-in is programme-specific. This one fails a document that says the opposite; that one fails a document that says nothing.
Rules you will hit next
Other policy pages rules at the same severity. A registration is judged as a whole, not rule by rule.
POL-001A privacy policy URL is required on the campaignBlockingBLOCKINGPOL-002A terms and conditions URL is required on the campaignBlockingBLOCKINGPOL-003An uploaded policy document must fit the provider file constraintsBlockingBLOCKINGPOL-005The terms and conditions attestation must be setBlockingBLOCKINGPOL-010Both policy URLs must resolve and return content anonymouslyBlockingBLOCKINGPOL-015The policy host must serve a valid certificate of its ownBlockingBLOCKING
POL-072 is one of 157 policy pages rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.