SMS Program & Policy
About This Document
This SMS Policy contains the language and templates required to operate the SMS (text message) feature of the My Church Secretary Service in compliance with the Telephone Consumer Protection Act (TCPA), the CTIA Messaging Principles & Best Practices, and the rules of the United States wireless carriers and The Campaign Registry (TCR). It has three parts:
- Part A — SMS provider submission text. The exact strings of text that MCS submits to its SMS provider during A2P 10DLC campaign registration. These are not seen directly by church members, but they define what the messaging system replies with when a member texts HELP or STOP.
- Part B — For churches to use. Plug-and-play language that subscribing churches can copy onto their online sign-up forms, paper sign-up sheets, and member-facing notices (bulletin, website, narthex).
- Part C — Operational guidance. Recordkeeping, handling phone-number changes, and responding to member complaints.
Scope: This document provides templates and operational guidance. It is not legal advice and does not create an attorney-client relationship. Each subscribing Church remains responsible for its own TCPA, CTIA, and carrier compliance, including the accuracy of opt-in records and the timely handling of opt-outs. Churches with questions specific to their jurisdiction or circumstances should consult their own counsel.
Part A — SMS Provider Submission Text
The four strings below are submitted to MCS’s SMS provider as part of A2P 10DLC campaign registration. Submit the wording as written; do not paraphrase. Replace [Church Name] with a short, recognizable name of the subscribing Church (for example, “Trinity Lutheran” rather than the full legal name).
A.1 — Welcome / Confirmation Message
Sent as the first message after a new opt-in. Confirms enrollment and sets expectations. Keep under 160 characters so it fits in a single SMS segment.
A.2 — HELP Keyword Response
Sent automatically when a member texts HELP to the Church's number. Must identify the program and provide a way to reach a human.
A.3 — STOP Keyword Response
Sent automatically as the single final message after a member texts STOP (or STOPALL, END, QUIT, CANCEL, UNSUBSCRIBE, OPT OUT). Once this message is sent, no further marketing or informational messages will go to that member from that Church through the Service unless the member affirmatively opts back in. The Service will still respond to subsequent START or HELP messages from that number, as carriers require.
A.4 — START / Re-Subscribe Response
Sent when a previously opted-out member texts START, UNSTOP, or YES to resubscribe. Required by carriers so that opt-outs are reversible by the member at any time.
Part B — Opt-In Language for Churches
Before a Church may send SMS to a Member through the Service, the Member must give express written consent. The language below satisfies the consent requirements of the TCPA and CTIA Messaging Principles & Best Practices. Each version is calibrated for a different collection method.
B.1 — Required Elements (Reference)
Whatever the format, every opt-in must include:
- Clear identification of the sender (the Church).
- A description of the kinds of messages the Member will receive.
- Approximate message frequency (typically: “Msg freq varies”).
- A statement that message and data rates may apply (typically: “Msg&data rates may apply”).
- Instructions on how to opt out (Reply STOP) and how to get help (Reply HELP).
- A link to the Church’s privacy policy (or to MCS’s privacy policy if the Church does not maintain its own).
- An affirmative action by the Member: a deliberately-checked box, signature, or typed initials. Pre-checked boxes are not sufficient.
Consent cannot be a condition of membership, joining, or receiving services from the Church. The Member must be able to decline and still participate fully.
B.2 — Online Opt-In (Web Form)
Place this language adjacent to a checkbox on any web form that collects a phone number for messaging (member directory sign-up, event registration, prayer-list sign-up, etc.). The checkbox must not be pre-checked.
Optional shorter version, if space is tight:
B.3 — Paper Opt-In (Printed Sign-Up Sheet, Bulletin Insert, Card)
Use this version on paper directory forms, bulletin inserts, or a tear-off card in the narthex. The Member must initial or sign next to the consent statement; a name in the row of a roster is not enough. MCS provides a ready-to-print consent form: Download SMS Consent Form (PDF).
B.4 — Verbal Opt-In (Discouraged)
Verbal consent collected over the phone or in person is permitted by law in some circumstances but is difficult to document and defend. If a Church must rely on a verbal opt-in, the staff member taking the consent should send the Member a confirmation text immediately (using the welcome message in A.1) and record in the directory: (i) the date and time consent was given, (ii) the staff member who collected it, and (iii) the script that was read. Verbal opt-ins should be followed up with a paper or online form as soon as practicable, and in any case before the next non-confirmation message is sent. A verbal opt-in not memorialized in writing is the weakest form of consent and should be treated as a stopgap, not a permanent record.
B.5 — Member-Facing Notice (Bulletin, Website, Narthex)
Plain-language wording that a Church can post in the worship bulletin, on its website, or as a sign in the narthex to explain the program. Not a substitute for an opt-in form, but improves transparency and helps members understand why they’re being asked to sign up.
B.6 — Re-Confirmation for Existing Member Lists
Many Churches have an existing directory full of mobile numbers that were never formally documented with TCPA-compliant consent. Those numbers cannot lawfully be enrolled in a new SMS program without obtaining fresh consent. The following script is what a Church should use to invite existing Members to opt in (delivered by email, by paper mailing, or in a bulletin), not by sending an unsolicited SMS to the existing list. The reference to “the enclosed card” below refers to the printable SMS Consent Form (PDF).
Part C — Operational Guidance
C.1 — Recordkeeping
For each opt-in, the Service records (or the Church should record, in the case of paper forms uploaded to the directory):
- The Member’s name and mobile number.
- The date and time consent was given.
- The exact wording the Member agreed to.
- The mechanism (online form, paper form, verbal with confirmation text).
- The identity of the person collecting consent, where applicable.
These records must be retained for at least four (4) years following the last message sent or the date consent was withdrawn, whichever is later. The TCPA’s statute of limitations is generally four years, so this aligns the records-retention window with the period in which a claim could plausibly be brought.
C.2 — Phone Number Changes and Reassignment
A Member may change phone carriers, transfer a number, or give up a number that is later reassigned to a different person. The FCC maintains a Reassigned Numbers Database (administered by Somos) that messaging platforms can query to identify numbers that have been disconnected and may have been reassigned. The Service performs reasonable reassigned-number checks before delivering messages to inactive numbers, but Churches should also:
- Promptly update the directory when a Member reports a new number, and re-collect consent if the new number was not part of the original opt-in.
- Treat any “wrong number” reply or auto-reply (e.g., “This person no longer has this number”) as a request to stop messaging that number, and remove it from the active list.
C.3 — Complaints and Carrier Notices
If a Member complains about messages they did not consent to receive, the Church should: (a) immediately remove the Member from the active list and confirm in writing; (b) preserve the Member’s contact information and any communications about the complaint; (c) review the Member’s opt-in record (or absence of one); and (d) report the complaint to MCS at pastoralex@mychurchsecretary.com within five (5) business days so that we can investigate and, if necessary, notify its SMS provider and the relevant carriers. Churches should not delete consent or message records related to a complaint; doing so can be treated as spoliation if the matter escalates.
C.4 — Bulk Imports and List Hygiene
Before importing a list of mobile numbers into the Service for the first time, the Church should: (a) confirm that each number was collected with a documented, TCPA-compliant opt-in; (b) scrub the list for invalid numbers, landlines mis-coded as mobile, and known opt-outs; and (c) flag any numbers without a documented consent so that the Service will not include them in active messaging until consent has been refreshed using the language in Section B.6.
— End of SMS Program & Policy —