Overview
Watermark uses Twilio to send and receive SMS messages with students through the Student Success & Engagement (SS&E) platform. Watermark configures and manages the Twilio integration on your behalf.
Due to FCC regulations and carrier enforcement under A2P 10DLC, Twilio now requires detailed documentation showing how students explicitly consent to receive text messages. Twilio has been strictly enforcing these requirements, and Watermark cannot submit or activate a Twilio account without the information outlined below.
This article explains exactly what is required, why it’s required, and what you need to provide to Watermark to proceed.
What Twilio Requires
Twilio must be able to verify that:
- Students actively consent to receive SMS messages
- Consent is explicit, not implied
- Students know who is sending messages
- Students know how to opt out
- Privacy policies are clearly accessible
Most institutions satisfy these requirements within their application or enrollment workflow, which is where student phone numbers are typically collected.
Consent and Compliance Requirements
1. Phone Number Collection + Explicit Consent
You must be able to show where and how students provide their phone number and agree to receive text messages.
Required
- An explicit SMS consent statement
-
A selectable checkbox that:
- Is not pre-checked
- Requires an affirmative action by the student
- Consent cannot be implied by submitting the form alone
Flexibility
- The checkbox does not need to be on the same screen as the phone number field
- It must, however, clearly tie the student’s phone number submission to consent to receive SMS messages as part of the same application or enrollment flow
2. Required Opt-In Language (Sample)
You may adapt the wording below, but all concepts must be present.
“By providing my mobile number, I consent to receive informational text messages from [Institution Name] related to my enrollment, academic status, or account. Message frequency may vary. Message and data rates may apply. Reply STOP to opt out or HELP for help.”
Must include
- Clear consent to receive text messages
- Institution name (brand identification)
- Message frequency disclaimer
- Message/data rates disclaimer
- Opt-out instructions (STOP)
- Help instructions (HELP)
3. Privacy Policy & Terms of Service
Students must be able to easily access your Privacy Policy and Terms of Service during the same workflow.
Required
-
A direct, public link to your Privacy Policy
- Must not be behind a login
- The Privacy Policy must state that mobile information will not be shared with third parties for marketing or promotional purposes
- The policy must be clearly accessible somewhere in the flow where consent is collected
Flexibility
- The links do not need to be immediately adjacent to the phone number field
- They must be reasonably visible and accessible as part of the process
4. Twilio Opt-In Example (For Reference)
The image below shows Twilio’s ideal example of a compliant SMS opt-in, including phone number collection, explicit consent with an unchecked checkbox, opt-out instructions, and accessible Privacy Policy and Terms links.
Your form does not need to match this exact layout. Twilio simply needs to see that these elements are present somewhere within your application or enrollment flow.
What You Must Provide to Watermark
Watermark cannot proceed without all items below.
1. Evidence of Consent Collection
Provide one of the following:
- A public URL to the exact page where consent is collected, or
- Screenshots of the form (Google Drive, OneDrive, PDF, etc.)
Include:
- Where the phone number is collected
- The opt-in language
- The selectable consent checkbox
- Where the Privacy Policy / Terms links appear
Screenshots are completely acceptable and common for application workflows that are not public.
2. Workflow Explanation
A brief description of:
- How a student moves through the form
- When they provide their phone number
- When and how they consent to receive text messages
(Short paragraph or bullet points is sufficient.)
3. Privacy Policy & Terms URLs
- Direct link(s) to:
- Privacy Policy
- Terms of Service (if separate)
4. Institution Details
- Legal business name
- Business address
- Tax ID / EIN
Conclusion
- Watermark cannot submit your Twilio registration until all required materials are received
- Missing or unclear consent documentation will result in Twilio rejection or delays
- These requirements apply to SMS messaging only