UNO Campus Policies

Scope

This policy applies to all University of Nebraska at Omaha (UNO) affiliated people who use mass text messaging, defined as similar messages sent to more than 50 addresses in one or more batches, for an official, university purpose. This policy exists to establish guidelines and standards for the responsible and compliant of this type of messaging as a communication tool within our UNO community. This policy does not apply to emergency messages or for testing and exercises utilizing the emergency messaging system sent by UNO.

This policy applies to any UNO-affiliated person who communicates to large groups of people in the university community via text messaging for an official, university purpose. This includes text messages sent from a University-owned device, account, or office; text messages sent through third-party services on behalf of any unit of the University; and text messages from any authorized University employee or agent acting in their official capacity.

Policy Statement

The primary aim of this policy is to promote best practices and prevent excessive reliance on text messaging. The university may employ text messaging as a supplementary communication method alongside conventional channels, such as letters, email, social media platforms, and the University's website. It's essential to ensure that mass text messaging complements other communication avenues and does not replace them as the primary means of outreach.

Reason for Policy

This policy outlines UNO’s approach to using mass text messaging for efficient and responsible communication. It prioritizes safeguarding recipient information, respecting privacy preferences, and adhering to relevant state and federal regulations.

Procedures

This policy applies to any text messaging application or system purchased, administered, and/or created with UNO resources that sends batch messages to 50 or more recipients. No other system may use UNO’s name, logos, name plates, icons, branding or any other university indicia without written permission from the Office of Marketing and Strategic Communications (MarCOMM).

It must be clear from the content of the message being sent that the message is from UNO so that the recipients can see immediately from where it originated, e.g., “Student Success” or “MavCONNECT.”

All units that seek to send text messages under this policy must be approved by the Division of Institutional Effectiveness and Student Success (IESS) before sending such messages.

All units that seek to send text messages must have a written plan indicating the purpose, content, and frequency of text messages that will be sent. All text messages must also be sent through an approved gateway.

Non-Emergency Communications 

• UNO may send non-emergency messages that are closely related to UNO’s mission, if the recipient has previously given expressed consent when they provided their telephone number to UNO. These may include information about upcoming general school activities under an approved plan.
• UNO non-emergency text messages must, at a minimum, comply with the following:
  • Be only sent to those individuals who have opted-in;
  • Comply with applicable laws and regulations to reduce institutional risk;
  • Follow best practices outlined by professional organizations;
  • Meet parameters set forth by the Division of Institutional Effectiveness and Students Success and Strategic Marketing and Communications
  • Meet unit parameters for procedures and practices to support the text messaging communication efforts;
  • Allow subscribers to opt-out of receiving non-emergency messages at any time; and
  • Communicate that standard data and text messaging rates may apply.

• Each mass text message should include information on how to opt-out of future text communications.
• Mass text messaging must not be used to communicate:
  • General information to large populations, i.e., “Spring classes start Monday!”;
  • Repeat reminders of messages already circulated;
  • Personal matters, e.g., items for sale, farewell messages, etc.;
  • Advertising or other commercial purposes;
  • Content that is not sponsored by a UNO college, department, program, office, or registered organization, etc.; or
  • Personal or confidential information, including, but not limited to social security numbers, passwords, financial information, grades, NU ID, or NET ID..

Implementation/Communication

• Each unit that uses text communications must disseminate this policy and the procedures/parameters set forth by the Division of Institutional Effectiveness and Student Success and the Office of Strategic Marketing and Communication to its staff who will be sending text messages.  Each unit must also develop its own procedures and guidelines for implementation.
• At a minimum, those procedures and guidelines must accomplish the following: 
  • Identify a publisher or publishers. Ideally, these will be communications professionals;
  • Work with MarComm and IESS to create an annual plan that details the purpose, content, frequency, and audiences of text messages; as well as identify plans for the dissemination of the text message content through other channels such as the area’s website, news articles, calendar events, social media, emails, and more;
  • Receive approval;
  • Share the plan with the designated SIDA resource;
  • Execute the plan; and
  • Participate in an annual audit of all text messages sent

• System Administrators are responsible for configuring their platforms to comply with this policy.
• System Administrators must maintain an up-to-date list of those individuals who have opted-out of receiving non-emergency text messages.
• System Administrators must ensure that the Office of Marketing and Strategic Communications’ (MarCOMM) seed phone number is included on all text messages.
• System Administrators must develop a method for saving text messages and responses as necessary to comply with applicable document retention requirements

Designate Responsibility: To clarify the roles and responsibilities of designated officials, departments, and individuals responsible for overseeing and enforcing text messaging compliance within the university system.

SIDA will facilitate training and awareness programs for staff, senders, and the university community regarding the policy's provisions, legal requirements, and best practices in text messaging communication. All college representatives connected to texting will be required to attend training.

Ensure Compliance with Legal Requirements: To ensure that all text messaging activities conducted by UNO, its departments, staff, and affiliates comply with the regulations set forth by the TCPA, Federal Communications Commission (FCC) rules and Family Educational Rights and Privacy Act (FERPA). Compliance is vital to protect individuals' privacy rights and avoid potential legal consequences.

Accountability

By adhering to this policy, the University of Nebraska (NU) System aims to maintain the highest standards of communication ethics, protect individuals' privacy rights, and mitigate legal risks associated with text messaging while fostering a positive and responsible use of this communication channel within our academic community.

Failure to adhere to this policy could result in revocation of access to send text messages.  Additional consequences for non-compliance include discipline under applicable rules, policy, or contract up to and including termination of employment. 

To ensure that this policy remains current and adaptable to evolving regulatory requirements and technological advancements, an annual review will take place of the policy. 

Adapted from Western Michigan University: https://wmich.edu/policies/mass-texting-policy

References

FCC 2016 (FCC 16-88)

Federal Education Rights and Privacy Act of 1974 (FERPA)

Telephone Consumer Protection Act of 1991 (TCPA)

Western Michigan University Mass Texting Policy

Definitions

Emergency Purposes means communications made necessary in any situation affecting the health and safety of the University community.

Mass Text Message is defined as identical or substantially similar messages sent to more than 50 addresses in one or more batches.

Opt In is an action by which someone requests to receive UNO communications via text message. Only individuals who have opted-in to text messages will receive these types of text messages.

Opt Out is an action by which someone who receives UNO communications via text message indicates that they no longer want to receive text messages from UNO. Individuals who opt-out of a texting number will not receive text messages.

Gateway Number is a mobile phone number provided by and monitored in the Systems Intelligence and Data Analytics (SIDA) Office.  

System Administrator refers to UNO Software Specialists. 

Emergency Situation means any situation affecting the health and safety of members of the University community.  These include weather closures, fire, health risks, and threats.

Official University Purpose means the individual sending the text message is doing so for a purpose within the scope of their university employment.

History

New policy approved by Senior Executive Leadership on February 11, 2025.