TRAI Digital Consent Acquisition System Complete Guide

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Unsolicited commercial messages (UCCs), also known as spam messages, have long plagued the Indian telecom landscape, causing frustration and inconvenience for users. To address this issue, the Telecom Regulatory Authority of India (TRAI) has introduced the Digital Consent Acquisition System (DCA System), marking a significant shift in how businesses engage with consumers through telecom channels. Digital Consent Acquisition (DCA) has become a crucial step for businesses seeking to engage with their customers through promotional and service-explicit communication via SMS.

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Introduction to Digital Consent Acquisition (DCA)

Digital Consent Acquisition (DCA) refers to the voluntary permission given digitally by customers to receive promotional or service-related communications from a sender or Principal Entity (PE). This process is governed by regulations such as the Telecom Commercial Communications Customer Preference Regulations (TCCCPR), which mandate the acquisition of digital consent for sending promotional messages to customers.

The DLT regime categorizes SMS’s into 4 types basis their content.

  1. Transactional SMS’s
  2. Service Implicit
  3. Service Explicit
  4. Promotional SMS’s

The DCA process applies only to Service Explicit and Promo SMS’s. If a PE sends a customer either of these types of SMS, they MUST have acquired consent from the recipient. If a PE sends a recipient such SMS without their consent, the recipient can file a formal complaint against the PE, with significant consequences. Consent can be acquired in multiple ways.

Here’s how it works:

  • Businesses must obtain explicit digital consent: Before sending promotional or service-explicit messages (e.g., offers, updates), businesses must acquire consent from each recipient through a transparent and verifiable digital process, as created by the DCA process.
  • Consent templates and categories: Businesses need to create pre-approved consent templates on the DLT platform outlining the scope of consent. These templates are linked to specific content categories (e.g., financial services, e-commerce) ensuring targeted communication.
  • Multi-channel consent acquisition: Businesses can acquire consent through various channels, including SMS, QR code scanning, and SMS API integration, offering flexibility to users.
  • DLT platform acts as a central hub: The DLT platform acts as a central repository for storing consent data, ensuring transparency and accountability.

Benefits of Digital Consent Acquisition (DCA)

  • Digital Recordkeeping: DCA enables businesses to capture and store customer consents digitally, ensuring a comprehensive record of consent transactions.
  • Overcoming DND Restrictions: Regardless of a customer’s Do Not Disturb (DND) preference, businesses can engage with them through promotional messages, provided explicit consent has been obtained digitally.
  • Compliance and Risk Management: By adhering to DCA regulations, businesses can mitigate the risk of consent-related complaints and penalties, ensuring compliance with regulatory standards.
  • Enhanced Marketing ROI: Leveraging digital consents allows businesses to target their marketing efforts more effectively, ultimately increasing the return on investment (ROI) for their SMS marketing activities.

Obtaining Digital Consent

Digital Consent Acquisition Methods

Businesses can acquire digital consent through various methods, including:

  1. POS Consent Upload on DLT Portal: Uploading customer consents available at points of sale (POS) through the DLT portal.
  2. QR Code Scanning: Generating QR codes for consent templates and enabling customers to provide consent by scanning the code.
  3. Consent Template SMS
  4. API Integration: To programmatically acquire consent from customers through custom applications instead of manually using the DLT portal.

Obtaining Consent through SMS

The most common form of acquiring consent involves sending a specialized SMS to the recipient, in which the recipient is asked for consent. The recipient can then accept or reject the request. If the recipient accepts the request, consent is recorded  the DLT platform.

A key component of this mode is the “Consent Template.” This is a template for a special type of SMS, which is sent to a recipient to acquire their consent. This template clearly outlines the purpose of the consent and details of the sender, ensuring transparency and compliance with regulatory requirements.

SMS Consent Template Message Samples:

  1. “Dear Customer, we are delighted that you signed up with <Brand Name> today. To receive exciting promotions and offers via SMS/Call, please provide your consent.”
  2. “Dear Customer, we wish to keep you informed about our latest launches, events, and promotions related to our product <Brand name>.”

The Consent SMS can only be sent through the DLT platforms. For this, the steps are as follows:

  1. PE logs into their DLT account on the DLT portal
  2. PE must have sufficient funds in their DLT Portal wallet. Each Consent SMS is charged by the DLT platform.
  3. PE creates relevant Consent Template, as illustrated above.
  4. PE sends the Consent Template to its list of recipients, which are uploaded into the DLT portal.

The DLT portal automatically acquires consent from the recipients if they provide it.

Subsequently, when the PE creates any SI or Promotional SMS, they can link it to a particular Consent Template where they have acquired Consent, and then send their SMS through any of their existing providers, including EnableX.

Important Points for SMS based DCA Process:

  • The consent message is sent to the subscriber three times: initially when the consent is initiated and then with two reminders on consecutive days.
  • If the subscriber responds with “Yes,” consent is granted for a duration of 12 months.
  • If the subscriber responds with “No,” the PE cannot send further consent-seeking messages to that subscriber for the next 90 days. However, the subscriber can initiate a request through QR code scanning.
  • If the subscriber does not respond even after receiving the reminders, the PE cannot send further consent-seeking messages for the next 90 days. However, the subscriber can still initiate a request through QR code scanning.
  • Customers have the right to revoke their digital consent at any time through 1909 (SMS/IVR/Calling).
  • Consent-seeking messages must clearly specify the scope and the PE/Brand name.
  • Do not include URLs or callback numbers in consent-seeking messages.
  • PEs must register consent templates on the DLT platform as these templates are used to acquire consent from customers.
  • DCA overrides the DND preference, allowing PEs to send promotional/Service Explicit messages to customers who have provided digital consent.
  • DCA does not affect Service Implicit/Transactional messages, which will continue as usual.

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Also Read: DLT Registration Charges in India: Complete guide for Sending Bulk SMS in India

Also Read: How to send bulk SMS using excel

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