European Communications
21 June, 2007 10:46 print this article email this article to a friend

MOBILE MARKETING - Playing by the rules

The mobile marketing industry is growing at a rapid rate with new innovations and business models being developed and deployed at an increasing pace. This makes for a dynamic and fast moving industry, says Laura Marriott, but also one that needs to adhere to a common set of best practice guidelines in order to grow responsibly and protect the consumer experience

MOBILE MARKETING - Playing by the rules

To ensure that as the mobile marketing industry develops, consumers not only have a positive mobile experience but are also treated fairly by all in the value chain, the Mobile Marketing Association (MMA) and the mobile industry, have developed and adhere to the MMA’s Consumer Best Practices (CBP) Guidelines.  Best practices also help to create simplicity and commonality for the industry and enable all players to operate according to a common set of criteria - ultimately, growing the mobile platform as a new business channel.
The CBP guidelines are published every six months and highlight important areas in regards to cross wireless carrier mobile content services to help ensure a sustainable mobile channel. The guidelines have been integrated into carrier and aggregator contractual agreements with brands and content providers and, as such, are adhered to by all players in the ecosystem.
The guidelines are built upon the MMA’s Code of Conduct for Mobile Marketing, which was first ratified by the MMA board in 2003. The code of conduct itself is organised around six main themes:
•    Choice. The consumer must “opt-in” to a mobile marketing programme
•    Control. Consumers must be allowed to easily terminate or “opt-out” of a programme
•    Customisation. Any data supplied by the consumer must be used to personalise content (e.g. restricting communications to those categories specifically requested by the consumer.)
•    Consideration. The consumer must receive or be offered something in return for receiving the communication (product and service enhancements, entry into competitions etc.)
•    Constraint. The marketer must effectively manage and limit mobile messaging programmes to a reasonable number of programmes - defaulted to a maximum of two new campaigns per week - unless the consumer opts in for further information. 
•    Confidentiality. Commitment to not sharing consumer information with non-affiliated third-parties (unless given permission to do so by consumer)

Best practice in action
The following demonstrates how the code of conduct principals are used in the ‘real-world’ by showing examples of shortcode programmes as defined in the best practice guidelines.  The over arching guideline is that the consumer is in control of their interaction with the programme.
There are basically two kinds of shortcode programmes: standard rate SMS and premium rate SMS, the former requiring single opt-in and the latter requiring double opt-in. Regardless of type, the goal is to ensure that the consumer opt in is clearly communicated to the subscriber, along with the obligation they will incur by participating in the programme.
For standard rate programmes, subscribers should indicate their willingness to participate in a programme and receive messages from the programme as follows:
 - Subscriber sends a Mobile Originated (MO) message to the shortcode.
 - Programme responds with pertinent phone, programme, and contact information via a Web/WAP/handset application-based form.  This opt-in applies only to the specific programme a consumer is subscribed to and should not be used as a blanket approval to promote other programmes, products, and services. However, after the subscriber has been given the complete details about the opt-in scope, the subscriber may specifically agree via their handset to receive other messages (this would be referred to as a double opt in).
The following table is an example of a standard rate mobile marketing campaign for “The Sandwich Shop Health Alerts.”
By contrast, premium subscribers must positively acknowledge the acceptance of a premium charge before premium charges are applied to their account. This is why the first time a subscriber participates in any premium programme, they will be asked to confirm their participation and accept the rate charges, hence the “double opt-in.”
This requirement should apply the first time a subscriber participates in a specific programme on a specific shortcode. Separate programmes, even if they are offered on the same shortcode, will require a separate opt-in and the content provider/aggregator is responsible for tracking the programme opt-in information by subscriber.
There are two mechanisms acceptable for opt-in activity: web-based, and handset-based. In all instances, however, the subscriber must take affirmative action to signify acceptance of the programme criteria. Within the double opt-in flow, the following information (at a minimum) must be provided to the subscriber:
•    Identity of programme sponsor: Defined as the organisation that markets the programme.
•    Contact details for the programme sponsor: Either a toll-free number or a website address.
•    Short description of the programme: e.g. “Fun Stuff”; “Premium Chat”.
•    Pricing terms for the programme: e.g. $0.99 per mobile originated message; $3.99 per month; whether standard messaging charges apply in addition to premium charges.
•    Notice that the charge will be billed on the subscriber’s postpaid phone bill or deducted from their prepaid balance.
•    Opt-out information
The following table is an example of a one-time premium weather message (transactional programme):
The following table is an example of charges the next time the same subscriber tries the same programme:
Many consumers prefer to provision and interact with SMS programmes from the Internet. If the second opt-in is from the Internet, the content provider must positively confirm that the authorised subscriber is acknowledging the opt-in. This can be done using a web-based PIN or phone MO message. This message must also include programme pricing and terms, and opt-out information. In addition, the content provider should use this channel to provide more detailed information about the programme. Regardless of the web opt-in details, the goal is that the entire terms of the offer must be clear to the subscriber throughout the process.
The following table is an example of a subscription programme with web sign-up:
It is important for subscribers to understand and be in control of their participation in shortcode programmes, and programme information should be easy to interpret. Regardless of manner of entry for a subscriber, help messaging commands, phone numbers, URLs, and e-mail addresses should result in the subscriber receiving help with their issue. Dead ends that do not result in the ability for subscribers to resolve their issues are not acceptable.
If the shortcode has multiple programmes (keywords) on the same code, the application should respond in one of two ways:
•    If the subscriber has opted in to only one programme, the application should supply the information for the programme the subscriber is opted-in to.
•    If the subscriber is opted-in to multiple programmes, the application should present a multiple-choice question asking the subscriber what programme they would like help on.
These messages should not result in premium charges to the subscriber’s bill and should be available to anyone who requests help information from the shortcode via SMS.
To help subscribers understand their participation, each programme should respond with the programme details listed earlier (contact details, description codes, opt-out information, pricing terms etc) when the subscriber sends the keyword HELP to the programme shortcode.
Should there be multiple programmes running on the shortcode, the subscriber can be directed to a Web site, WAP site, SMS quiz session, or toll-free number that provides an enhanced customer care experience, as long as basic information about the programme is in the help reply message.

Building on best practice
The above is just a sample of what is covered in the MMA’s Consumer Best Practices guidelines. Best practices are a first step in building an industry and reflect its sustainability and maturity. The industry must monitor and enforce against these best practices to ensure the success and integrity of the mobile content business - as well as adherence to the best practices guidelines. Most carriers and aggregators today perform a version of their own monitoring, with enforcement at the discretion of the carrier. Collectively, the industry will soon launch a new industry-wide monitoring initiative.
Best practices help ensure a level playing field and consistent consumer expectations in all mobile data services. Best practices are important not only to grow the industry but also to ensure a positive consumer experience. Understanding and adhering to industry best practices, therefore, are key to everyone's success. So make sure you understand the rules we play by!
Laura Marriott is president of the Mobile Marketing Association (MMA)

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