POLICY: Student Protection Policies - Text Messaging to Students Policy POLICY URL: https://lsi-ac.uk/policy/afe6b4fd-f3c7-403d-af6d-34421ca98f05 POLICY STATEMENT: The School is committed to using text messaging as an efficient communication tool, ensuring all messages are relevant, respectful, and aligned with student preferences. Our 'Text Messaging to Students Policy' outlines strict guidelines for ensuring compliance with data protection laws and preventing misuse by any team or staff member involved. POLICY PRINCIPLES: ------------------ - Consent : Ensuring students have given explicit consent to receive text messages from the School; - Relevance : Sending messages that are relevant and provide important or beneficial information for the student; - Respect : Respecting students' time and attention by limiting the frequency of messages sent; - Privacy : Safeguarding students' contact information and privacy at all times; - Opt-out : Providing a clear and straightforward opt-out process for students who wish to discontinue receiving messages; - Clarity : Communicating in a clear and concise manner, making sure that the intent of the message is easily understood; - Timeliness : Ensuring messages are sent at appropriate times to avoid causing inconvenience; - Brevity : Keeping messages short and to the point, respecting the nature of the SMS format; - Accuracy : Maintaining the accuracy of information conveyed in text messages; - Transparency : Being transparent about the School’s identity and purpose when sending text messages; - Security : Protecting the transmission and storage of mobile numbers and any other personal data; - Monitoring : Regularly reviewing and evaluating the effectiveness and student reception of the text messaging service. REGULATORY CONTEXT: ------------------ This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following: R1. Quality Assurance Agency (QAA): Advice - Student Engagement - Guidance on student engagement in higher education, focusing on quality assurance and enhancement processes. R2. Information Commissioner's Office (ICO): Guide for higher education institutions - Provides guidance for higher education providers on their obligations under data protection law. R3. Quality Assurance Agency (QAA): Advice - Enabling Student Achievement - R4. Competition and Markets Authority (CMA): Higher education: guide to consumer rights for students - This guide outlines students' consumer rights and explains what higher education providers must do to meet their obligations under consumer protection law. R5. UK Government : Data Protection Act 2018 - Legislation aimed at controlling the processing of personal data, laying down principles with respect to the processing of personal data, and the rights of data subjects METRICS AND KPIS: ------------------ The following metrics will be measured and regularly reviewed as key performance indicators for the School to ensure the effectiveness of this policy and associated operations: M1. Effectiveness of Communication Channels: Comparison of student engagement rates across different communication channels, reviewed annually. Helps assess the relative effectiveness of text messaging compared to other channels, guiding future communication strategies. M2. Message Delivery Success Rate: Percentage of text messages successfully delivered to intended recipients, measured monthly. Indicates the reliability of the text messaging system and identifies potential technical issues. M3. Number of Text Messages Sent: Total number of text messages sent per month, tracked monthly. Provides insight into the volume of communication and helps manage messaging frequency and relevance. M4. Response Time to Text-Based Issues: Average time taken to resolve issues or complaints related to text messages, measured monthly. Ensures prompt action to address and rectify any issues, maintaining the effectiveness of the communication channel. M5. Student Satisfaction Score: Average satisfaction score from student surveys regarding text message communication. Measures the effectiveness and acceptability of text messaging as a communication method among students. SECTION 1: Usage Guidelines and Protocols ------------------ 1.1. Guidelines for Text Messaging Communications (by Marketing Team): Text messaging (SMS), which is limited to 160 characters, serves as a tool for urgent and time-sensitive notifications. It is used in conjunction with other communication methods such as email, the School website, and the student portal. The Marketing Team is responsible for informing students via email and text message about the purpose of SMS communications and will remind them to update their contact details; Text messages will be dispatched from a generic number listed as “SIT,” which is used by various UK services and is not affiliated with the School’s SMS system. Replies are not enabled for these messages; any responses should be directed through other communication channels such as email; Students will be notified of the sending number, “SIT,” and its association with other services. SMS will not be the sole means of communication. Preferred channels include announcements on the School’s website, emails, plasma screens on campus, the student news and events blog, and promotional banners; The Marketing Team will manage the texting service, with any additional messaging requests requiring approval from the Director of Operations or a delegated staff member. Mobile phone numbers are extracted from relevant systems, uploaded to the service provider’s platform, and are not accessible to individual staff. The handling of mobile phone number data adheres to the Data Protection Policy and is documented in the Student Privacy Notice. For additional uses of SMS, contact dataprotection@lsi.ac.uk; Roles and responsibilities for managing the texting system and this policy are outlined in Appendix 2; These guidelines ensure SMS is used effectively for urgent communications while respecting privacy and adhering to data protection regulations. They establish clear procedures and responsibilities, ensuring SMS is used appropriately and in conjunction with other communication methods. SECTION 2: Circumstances for Sending Text Messages ------------------ 2.1. Criteria for SMS Communication by the Marketing Team (by Marketing Team): Examples of when Marketing Team will send SMS text messages to students are detailed below but are not limited to this list; Purpose of the message; Authoriser for sending messages; Local non-emergency messages where access to a specific campus location is compromised – such as weather conditions/snowfall; Director of Operations; In the absence, her/his direct managerial reports; Local emergency messages – such as lab closed; Global emergency messages – such as campus-wide closures for COVID-19 infection or other reasons; The Marketing Team will respond to any student or staff feedback relating to the use of texting. Should the School or a team wish to use one of the services for a different purpose than those outlined above, this will need authorisation from the Director of Operations. As texting is to be used in exceptional circumstances, the School or team may be advised that other communication channels are more appropriate, depending on the circumstance; This rule ensures SMS is used appropriately for urgent and important messages, with clear authorisation processes and feedback management. It maintains the focus on exceptional use, aligning with overall communication strategies and ensuring effective use of messaging resources. SECTION 3: Standards for Message Formatting and Content ------------------ 3.1. Text Messaging Format and Guidelines (by Marketing Team): All text messages must adhere to the following format and guidelines:; Character Limit: Messages must not exceed 160 characters, including any stock text and web addresses. If additional information is needed, provide a URL to a webpage. Use only the specified URL shortener if required, which consumes 26 characters, leaving 144 for the main message; Sender Identification: Messages must clearly identify the School and display as “SIT”; Additional Information: If a detailed email follows the text message, include “check School email” in the message; Language and Style: Avoid colloquialisms, text speak, non-Latin characters, and personal information. Spell out numbers up to nine; use numerals for 10 and above. Format dates as 1 January 2023, and use simple ordinal numbers (1st, 2nd, 3rd). Do not use emoticons or redundant phrases like “FYI”; These guidelines ensure that text messages remain clear, concise, and within technical limits while maintaining a professional tone. They prevent miscommunication and ensure that all messages are easily understandable and consistent with the School’s standards. SECTION 4: Oversight and Administration of Text Messaging ------------------ 4.1. Text Messaging Management (by Marketing Team): The Marketing Team manages all text messaging on behalf of the School for urgent communications that complement other channels. This includes messages related to COVID-19 updates, emergencies affecting students or staff, and campus access issues (e.g., heavy snowfall); This ensures that text messaging is used effectively for timely communication in critical situations, supporting other communication methods and providing rapid updates as needed. SECTION 5: Appendix 1: Illustrative Examples of Text Message Content ------------------ 5.1. Example (by Marketing Team): Example One: Weather Closures:; “SIT – The campus is closed today, Wednesday 5 December due to snow. See the website for updates”; NB: all web addresses (URLs) will be shortened to using a unified format; This format ensures that messages are clear and concise, providing essential information while directing recipients to the website for further updates. The use of a unified URL format maintains consistency and saves character space. SECTION 6: Appendix 2: Roles and Duties in Text Messaging Administration ------------------ 6.1. Responsibilities for Managing Text Messaging System (by Marketing Team): The Marketing Team will:; Manage the technical aspects of the text messaging system, resolving issues according to standard practices; Audit the service output and ensure compliance with the policy; Update the policy with approval from the Director of Operations for any new uses; Follow data protection procedures, including legal bases for processing and reporting data security issues; Provide training and guidance for internal users and offer additional training as needed; Support the ongoing development of the text messaging channel; School and teams will:; Contact the Director of Operations for any inquiries regarding the need for a text message or to provide necessary information; These rules ensure efficient operation and oversight of the text messaging system, maintain compliance with data protection laws, and provide clear procedures for requesting and managing text messages.