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1. Purpose of Policy 

The purpose of this Policy is to set forth how 51������ will use mass text messaging to disseminate information within and beyond the University community.

 51������ may text students or stakeholders regarding matters that affect health and safety, academic success, and other matters closely related to 51������’s mission. Text messaging is a supplemental means of communication rather than a primary communication tool.

 The Policy is designed to respect and maintain individuals’ rights to privacy, while maximizing efficiency and effectiveness in communicating with students and stakeholders about important matters relating to 51������’s mission.

2. Stakeholders Most Impacted by the Policy 

This Policy applies to any 51������-affiliated person who communicates to large groups of people in the University community via text messaging for an official, university purpose.  This includes text messages sent from a University-owned device, account, or office; text messages sent through third-party services on behalf of any unit of the University; and text messages from any authorized University employee or agent acting in their official capacity.

3. Key Definitions 

3.1. Emergency Purposes means communications made necessary in any situation affecting the health and safety of the University community.

3.2. Mass Text Message is defined as identical or substantially similar messages sent to more than 50 addresses in one or more batches.

3.3. Opt In is an action by which someone requests to receive 51������ communications via text message. Only individuals who have opted-in to text messages will receive texts.

3.4. Opt Out is an action by which someone who receives 51������ communications via text message indicates that they no longer want to receive text messages from 51������. Individuals who opt-out of a texting system will not receive text messages.

3.5. Seed Number is a mobile phone number provided by and monitored in the Office of Marketing and Communications.  

3.6. System Administrator refers to 51������ Software Specialists. 

3.7. Emergency Situation means any situation affecting the health and safety of members of the University community.  These include weather closures, fire, health risks, and threats.

3.8. Official University Purpose means the individual sending the text message is doing so for a purpose within the scope of their university employment.

3.9. Unit means a vice presidential division, college, academic department, or a part of the university determined by the cabinet member, dean, or associate vice president to which it reports to have a sufficiently discreet mission to warrant its own text messaging capability.

3.10. 51������ Mission means the mission set forth at /about/mission-history. 

4. Full Policy Details 

 4.1. 51������ seeks to effectively communicate with the University Community regarding emergencies, such as weather closures, fire, health risks, threats, and other matters that are closely related to 51������’s mission while being good stewards of personal information, respecting the privacy and wishes of the recipients, and adhering to applicable state and federal laws. 

4.2. This policy applies to any text messaging application or system purchased, administered, and/or created with 51������ resources that sends batch messages to 50 or more recipients. No other system may use Western Michigan University’s name, logos, name plates, icons, branding or any other university indicia without written permission from the Vice President of Marketing and Strategic Communications.

4.3. Except for emergency communications, only those individuals who have opted-in will receive text messages from the University.

4.4. Text messaging must not be used as the sole means of communicating an essential message or announcement.  The text message must be supplemented by some other means of communication, e.g. an email or paper notice to ensure that all individuals, including those without a mobile phone, receive the message.

4.5. It must be clear from the content of the message being sent that the message is from 51������ so that the recipients can see immediately from where it originated, e.g., “51������ Alert” or “51������ Admissions.”

4.6. All units that seek to send text messages under this Policy must be approved by, and in good standing regarding text messaging with, the Office of the Vice President for Marketing and Strategic Communications before sending such messages.

4.7. All units that seek to send text messages must have a written plan indicating the purpose, content, and frequency of text messages that will be sent. All text messages must also be sent to Marketing and Strategic Communications’ seed number.

4.8 Emergency Communications 

• 4.8.1. In Emergency Situations, 51������ may lawfully send automated texts to wireless phone numbers without consent.

• 4.8.2. 51������’s Department of Public Safety may automatically enroll students and employees in the emergency notification service, which may include text messages solely for use in Emergency Situations.

4.9 Non-Emergency Communications 

• 4.9.1. 51������ may send non-emergency messages that are closely related to 51������’s mission, if the recipient has previously given express consent when they provided their telephone number to 51������.  These may include information about upcoming general school activities.
• 4.9.2. 51������ non-emergency text messages must, at a minimum, comply with the following:

• Be only sent to those individuals who have opted-in;
• Comply with applicable laws and regulations to reduce institutional risk;
• Follow best practices outlined by professional organizations;
• Meet parameters set forth by the Office of the Vice President for Marketing and Communications;
• Meet unit parameters for procedures and practices to support the text messaging communication efforts;
• Allow subscribers to opt-out of receiving non-emergency messages at any time; and
• Communicate that standard data and text messaging rates may apply.
• 4.9.3. Each mass text message should include information on how to opt-out of future text communications.
• 4.9.4. Mass text messaging must not be used to communicate:
• General information to large populations, i.e., “Fall classes start Monday!”;
• Repeat reminders of messages already circulated;
• Personal matters, e.g., items for sale, farewell messages, etc.;
• Advertising or other commercial purposes; or
• Personal or confidential information, including, but not limited to social security numbers, passwords, financial information, or grades.

4.10 Faculty Mass Text Communication: faculty are encouraged to communicate effectively with their classes. Mass texting to large classes can be an effective means to do so. However, mass text messaging must be limited to students currently enrolled in the faculty members’ classes.

• 4.10.1. Faculty must follow the terms of this Policy when sending Mass Texts to students;
• 4.10.2. Student information will not be captured from mass texting message systems, for purposes not related to a class in which the student is currently enrolled.
• 4.10.3. Mass text messages from faculty to students must be class-related content.

4.11. Registered Student Organizations and Student Government: the Western Student Association, Graduate Student Association, and Registered Student Organizations (RSO’s) may send Mass text messages to their membership, with the members’ permission and if a method to unsubscribe is easily available to members. Such Mass emails should be limited to official business of the student group or student government.

4.12. Implementation/Communication

• 4.12.1. Each unit that uses text communications must disseminate this Policy and the procedures/parameters set forth by the Office of the Vice President for Marketing and Strategic Communications to its staff who will be sending text messages.  Each unit must also develop its own procedures and guidelines for implementation.
• 4.12.2. At a minimum, those procedures and guidelines must accomplish the following: 

1. Identify a system administrator;
2. Identify a publisher or publishers. Ideally, these will be communications professionals;
3. Work with the Office of Marketing and Strategic Communications to create an annual plan that details the purpose, content, frequency, and audiences of text messages;
4. Receive approval; and
5. Execute the plan.

• 4.12.3.  System Administrators are responsible for configuring their platforms to comply with this Policy.
• 4.12.4. System Administrators must maintain an up-to-date list of those individuals who have opted-out of receiving non-emergency text messages.
• 4.12.5. System Administrators must ensure that the Office of Marketing and Strategic Communications’ seed phone number is included on all text messages.
• 4.12.6.  System Administrators must develop a method for saving text messages and responses as necessary to comply with applicable document retention requirements.

5. Accountability 

Failure to adhere to this policy could result in revocation of access to send text messages.  Additional consequences for non-compliance include discipline under applicable rules, policy, or contract up to and including termination of employment. 

6. Related Procedures and Guidelines 

Links will be provided as procedures and guidelines are finalized.

7. Additional Information

N/A

8. FAQs

8.1 Whom may I contact to find out if my text message conforms to this Policy?

• Answer:  Your System Administrator or the Director of Electronic Communication, Office of Marketing and Strategic Communications

8.2. May I develop my own rules and guidelines for how to implement this Policy?

• Answer: Yes, as long as all elements of the Policy and the procedures/parameters set forth by the Office of the Vice President for Marketing and Strategic Communications are followed.

8.3.  What does "closely related to the school’s mission” mean?

• Answer: The FCC interprets “closely related to the school’s mission” narrowly.  It is a fact-specific determination.  Texts relating to 51������’s mission may consist of messages regarding admissions, events, advising, 51������ systems, classroom or other reminders or information. While this is not an exhaustive list, a 51������ stakeholder who opts in to texting could receive communication via text message regarding matters of health and safety, academic success and others. If in doubt, contact the REO or Office of General Counsel for additional guidance. 

8.4  If I opt-out of one system of text messages (e.g., from Admissions), will I automatically be opted out of others (e.g., from the Engineering Department)?

• Answer: No.  You must contact each System Administrator.

8.5.  How do I find out who my system administrator is?

• Answer: Call the IT Help Desk or your desktop support person. 

8.6.  What can I do if I’m receiving too many text messages?

• Answer:  Opt-out of the messaging through the text communication or directlycontact the           office that is sending the message and request that they stop.  If the texts continue, contact    the Office of the Vice President for Marketing and Communications.

8.7.  What are examples of acceptable text message content?

• Answer:

1. Housing contracts are due April 1. We have not yet received your application. 51������ Housing Reply STOP to Opt Out.
2. FAFSA’s are due at 51������ on March 1. We have not yet received your information. Visit wmich.edu/FAFSA for more information. Reply STOP to Opt Out.
3. A mass text from a faculty member to his or her class about an assignment.

8.8.  What is an example of unacceptable text message content?

• Answer:

1. Plan your campus visit to 51������ today. Wmich.edu/visit.
2. The 2019-20 Miller auditorium season goes on sale tomorrow.
3. A mass text from a faculty member to his class promoting his daughter’s band fundraiser.
4. A mass text from a faculty member to a student who is not enrolled in their course, even if that student was enrolled in their course previously.

8.9.  Do I have to follow this Policy if I break my recipient group up into, for example, two groups of 25 instead of one group of 50?

• Answer:  Yes.  If you are sending the same message to fifty or more people, regardless of whether you break it up into recipient lists of less than fifty, it is still covered by this Policy. See definition of Mass Text in Section 3.1, above.