When discussing mobile marketing basics, we must consider the Mobile Marketing Association’s (MMA’s) “Consumer Best Practices (CBP) Guidelines” (PDF download). I initially wrote about the “CBP Guidelines” in May. The guidelines were updated in November, so let’s review the areas of significant change.
“CBP Guidelines” has become the baseline for cross-carrier mobile marketing initiatives in the U.S. The document compiles accepted industry practices and wireless carrier policies and is based on regulatory guidance given to representative members of the off-network ecosystem. While the guidelines committee strives to implement policies that encourage off-net industry growth, its primary focus is on consumer protection and privacy, as industry growth without consumer satisfaction isn’t sustainable. The guidelines have been integrated into carrier contractual agreements with aggregators and content providers and, as such, are enforced by all players. For those in mobile marketing, the “CBP Guidelines” are a must know.
According to David Oberholzer, associate director of content programming for Verizon Wireless and the guidelines committee chairman, “‘The Consumer Best Practices Guidelines’ continue to set the standard by which carriers, aggregators, and content providers offer services in our emerging mobile marketing industry. The MMA CBP Committee continues to stay abreast of issues that impact our industry and respond in a collaborative, consistent manner to ensure a positive consumer experience.”
The Committee comprises leading mobile marketing providers, including wireless carriers, aggregators, content providers, and agencies.
The guidelines are published every six months and highlight important areas to ensure a sustainable mobile channel. Highlights from the recent update include the key areas below.
Advertising and Promotion
The most significant modifications to advertising and promotion regard terms and conditions (T&Cs) language and the provision of adequate information to subscribers about the services. Highlights include:
- If the T&Cs materially change the consumer offer, the T&Cs must be highlighted and presented at front of offer.
- Prechecked T&Cs aren’t permissible. Consumers must indicate their acknowledgment by manually selecting the T&Cs.
Language about marketing to children was added. The guidelines state that all marketing campaigns targeted at children must comply with all state and federal regulations, including COPPA regulations.
Also added was language around the use of “free” terminology in advertising and promotional materials. Of particular note in this section are the following:
- A program isn’t to be promoted as “free'” when subscribers will pay premium fees with a reasonable level of participation in the program.
- If there are obligations associated with the term “free,” the full commercial offer should be disclosed in the same manner at point of the free promotion. The entire offer must be presented in same place (e.g., banner ad, top of ad, etc).
- Processing of recycled and deactivation files. These processes should ensure when a user is given a new phone number, he isn’t delivered or billed for mobile content programs subscribed to by the number’s previous holders. Content providers and aggregators should process deactivation information within three business days of receipt.
- Spending cap limits. The committee also set some guidelines around spending cap limits for both chat and non-chat services. Though the policies around spending cap limits are set by individual carriers, the guidelines recommend caps be per short code on a monthly basis and require consumers to opt in again when their specific carrier caps are reached. The caps will ultimately help protect the consumer experience with short code services.
- Bill face descriptions. Billing detail standardization will help provide subscribers with information on the programs they are subscribed to. It’s hoped greater bill information recognition will result in fewer billing disputes. The information to be provided on carrier bills now includes short code, brand name and/or brief program description, toll-free help number, and purchase type.
The guidelines now also define viral, or word-of-mouth, marketing and set out permissible and non-permissible campaign types. Viral marketing is communication via text message or other mobile content, including ring tones, games, and wallpaper. Consumer A receives the message, identifies consumer B as someone interested in the message, and initiates a process (e.g., inputting a phone number) through which consumer B automatically receives the message.
All participants in the ecosystem must adhere to all the latest updates to the CBP Guidelines within 90 days of release (in this case, by February 2007).
Each year, the MMA hosts a Consumer Best Practices Industry Forum, where industry leaders discuss the issues, challenges, and opportunities in creating a professional, sustainable mobile marketing industry. The topics discussed are considered for integration in future revisions of the CBP Guidelines. The next forum will be in Denver on January 11. Topics to be covered include interactive voice response (IVR), WAP (define) off-deck, mobile sweepstakes, and iTV. If you’re interested in helping define the guidelines for our mobile marketing industry, plan to attend.
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