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Incident and Crisis Management Framework. Appendix K. 2012 Text messaging policy 1. Background The increasing and almost universal use of mobile phones has opened up a new avenue of opportunity for communication between the University and its staff and students. This policy sets out the way in which the University will use Short Message Service (SMS) text messaging appropriately to pass on important information to staff and students. The use of SMS messaging is intended to sit alongside other existing forms of communication such as letters, email, social networking sites (Facebook and Twitter) and the University’s website. The immediate delivery of SMS messages gives it an advantage over other forms of communication: most students have their phones with them all the time and the message is likely to be received much sooner. Text messaging has wide accessibility. People who are blind or visually impaired can use mobile phones, and some mobile phones have text-to-speech capability, meaning that individuals can listen to text messages. Data Protection and privacy issues have been taken into account in preparing this policy. In some cases, people will be asked if they wish to 'opt-in' to receive particular types of messages. In others, for example where messages are sent for administrative purposes, people will be asked if they wish to ‘opt-out’. However, there may be emergency circumstances in which the University will need to contact as many staff and students as possible, ignoring personal preferences (which is permissible if it is in the 'vital interests of the data subject' – Data Protection Act Schedule 2(4)). Phone numbers may be stored by third parties for the purpose of sending messages, but names will not be stored. There may, very rarely, be the need to send a message for test purposes. There are a number of scenarios in which an SMS message could be very useful, e.g. Emergencies: o An outbreak of meningitis, mumps or measles amongst the student population o A fire, flood, or similar incident in a University building o Any serious crime or terrorism incidents Work-related incidents: o Messages to support staff about equipment/environment failures Other usage: o Lecture room changes. However, the usefulness of text messaging depends on having reliable data. The mobile numbers will be taken from the University's central staff and student databases (PIMS and SITS) so it is important that these are kept up to date. This will be achieved by means of email reminders or Portal announcements to staff and students to keep their details up to date and directions for how to do so. 2. Emergencies 2.1 Scope Incident and Crisis Management Framework. Appendix K. 2012 Messages whose content is deemed to be essential or urgent. 2.2 When is it appropriate? Incident and crisis management is handled by a team of senior managers. The team may decide a text message is appropriate whenever it is considered important to contact a group of people urgently for reasons of health or safety. It should be noted that there is no guarantee that text messages will be delivered promptly or at all by the mobile phone companies. In some types of emergency, e.g. a terrorist incident, the emergency services may commandeer the mobile phone network, so no messages will get through. Simultaneous, multiple approaches are essential. Text messages must be supplemented by other means of communication, such as emails, messages issued via Facebook or Twitter or information posted on the University website, to ensure that as many of the target audience as possible receive the message. 2.3 Approvers A request to send a message to one of the University-wide lists must be approved by one of the senior crisis team (this team includes the Vice-Chancellor, Deputy Vice-Chancellor, Registrar, Deputy Registrar (Education & Students), Director of Communications, Assistant Director of Communications (Head of Public Relations), Bursar & Director of Estates, Head of Planning, Senior Planning & Projects Officer, Human Resources Director and Deputy Human Resources Director). The Head of Security Services also has approver rights. Authorisation will be given for a message only if: it is considered that it is important to get the message to a significant number of the recipients as soon as possible; the content is both appropriate and factually correct; the message format meets the guidelines. 2.4 Target Groups It is possible to send messages to the following groups: All staff and students All staff All students All undergraduates All postgraduates. Further groupings (e.g. by faculty, by hall of residence) may be added in the future. 2.5 Format of message Messages should be no longer than 160 characters and should address the student or staff member directly, i.e. as 'you'. They should include essential points, and should avoid 'text speak', e.g. write 'you', not 'u'; and 'for', not '4'. Non-Latin alphabet characters should Incident and Crisis Management Framework. Appendix K. 2012 be avoided, as they may decrease the maximum message size to 140 or even 70 characters. 2.5.1 Sender All messages must start with the words 'UoB Alert:' so that the recipients of the text can see that it is an official message from the University requiring their attention. 2.5.2 Subject The message must clearly indicate what it concerns. 2.5.3 Where to get more information The message should indicate where more information can be sought, e.g. 'see www.bris.ac.uk' if the University website is operational, or 'check email for details'. 3. Work-related Incidents 3.1 Scope Messages that are sent to one or more staff members relating to incidents at work. These could include, for example, alerts or work instructions relating to maintenance or equipment failures. 3.2 When is it appropriate? A text message may be appropriate to communicate with a member of staff about matters relating to his or her job, where that person is likely to be moving around the campus, or 'on call'. It is impossible to give a definitive list of possible applications; the deciding factor has to be whether it is an effective means of communication. 3.3 Approvers The Head of a Department is responsible for deciding on suitable usages of text messaging within a department, and for delegating approval rights. Authorisation should be given for a particular message only if: the distribution list is appropriate, and the content is both appropriate and factually correct. 3.4 Recipients Departments should endeavour to ensure that lists of numbers are kept up to date and reviewed at least every six months. People issued with mobile phones by the University for work purposes may not opt-out of receiving text messages. 3.5 Format of message Messages should be no longer than 160 characters. The message must clearly indicate what it concerns. Incident and Crisis Management Framework. Appendix K. 2012 It should be clear who has sent the message. 4. Other uses (e.g. departmental) 4.1 Scope There are many other possible uses of text messaging. For example: administrative purposes: reminding students to register or select options, announcing room and timetable changes; coursework: announcements, essay deadline reminders, updating reading lists; events: seminar and lecture announcements, social events, concerts; marketing, fundraising and selling. 4.2 Opting in and opting out For administrative or coursework messages, message providers may choose to offer students the right to ‘opt-out’. Students could be notified at the start of an academic year. For other types of message, it makes sense to ask people whether they wish to opt-in to different classes of message, as asking them whether they wish to opt-in to 'all or none' is likely to result in a low take-up rate. Hence, it is recommended that message providers define the types of message that they will be sending and ask their target audience whether they wish to opt-in to each type. 4.3 Guidelines The following guidelines should be followed by message providers: 4.3.1 Administration The purpose and scope of the text messaging application should be defined. The application owner should be specified. A list of approvers of messages should be defined. Costs need to be carefully monitored and controlled. Messaging services should be procured with appropriate cost approval against an agreed budget. 4.3.2 Maintaining the list The intended recipients should be asked if they wish to receive messages. Lists of phone numbers should be reviewed regularly to keep them up to date. Recipients must be permitted to change their minds and rescind an opt-in. Opt-outs must be respected. Remember that personal data is being handled and this must be done in accordance with the principles of the Data Protection Act. 4.3.3 Sending messages Care must be taken not to send messages too frequently or frivolously, as this will probably result in fewer people opting-in. Incident and Crisis Management Framework. Appendix K. 2012 Text messaging must not be the sole means of communication. People who have opted-out should not be disadvantaged. There may be people who do not possess mobile phones, or have difficulties using them (e.g. visually impaired). Messages should be no longer than 160 characters. The sender of the message should be clearly identified. 5. Choosing a provider 5.1 Internal The University provides a text messaging service, run by Telephone Services. The service offers certain advantages over external suppliers in terms of flexibility, cost and billing arrangements. 5.2 External Sharing personal data, such as mobile phone numbers, with other organisations (either providing or receiving personal data) must be covered by a contract. Similarly, departments employing an external organisation (a data processor) to process personal data on their behalf must have a written contract requiring the data processor to agree to act only on the instructions of the Department/University and to abide by the provisions of the security principle in the Data Protection Principles. The University does not have a preferred external supplier for text messaging. Those known to specialise in the education sector include Janettxt, Txttools/ConnectTxt and Xlearn. Usually a block of a few thousand messages can be purchased up-front. These may have an expiry date, so it is important to consider how quickly the block is likely to be used. Expect to pay significantly more for two-way messaging facilities. The supplier will usually have a web-based interface for sending messages. Lists of numbers can be entered and stored manually, or uploaded from a spreadsheet or database. Suppliers may be able to interface to Virtual Learning Environments (VLEs), such as Blackboard or Moodle. 6. Further Advice Message senders need to be aware of: the principles of the Data Protection Act 1998 and the University’s guidance relating to security measures for safeguarding personal data. See http://www.bristol.ac.uk/secretary/dataprotection/depts/security.html. the Secretary's Office advice on direct marketing. See http://www.bris.ac.uk/secretary/dataprotection/depts/marketing.html. Further advice on text messaging can be obtained from firstname.lastname@example.org. Training and/or notes of guidance can be provided for new users, where appropriate. Policy approved by University Council in 2009 and updated in May 2012. Next review date: May 2014. Policy owner: Kevin Thomas.
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