Another issue is that you cannot guarantee that you will be calling/texting 
a specific person.  While most callers realise that a land line may have 
multiple users, there is probably a tendency to assume that a mobile is 
always personal.  Although many mobile phones are used exclusively by one 
person, there are quite a few instances where people share a phone.  (This 
is a particular issue, for example, in a project I am involved with at the 
moment working with asylum seekers.)

If you send a text, there is no way of checking who is receiving it (unlike 
a voice call, where you can at least ask the person on the other end to 
identify themselves).  It would therefore be very unwise to send texts to a 
mobile number that was originally given to you as a contact phone number, 
without confirming that the texts will not risk a breach of confidentiality.

This requires some consideration: the full implications would need to be 
spelled out, in order to obtain consent.  You may also be creating a 
disadvantage for people without exclusive mobile phone access (which may or 
may not be a problem).

Paul Ticher
0116 273 8191
22 Stoughton Drive North, Leicester LE5 5UB


----- Original Message ----- 
From: "Simon Howarth" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Wednesday, October 28, 2009 11:52 AM
Subject: Re: SMS Texting - Policy/Procedures and Asking for Permission


Interesting. I suppose, so long as the individuals have consented and 
understand what information may be sent to them, then there should be no 
great issue for most things. A consideration would be the level of privacy 
that goes with (or not) having a mobile phone.



For each of your points my thoughts are:



1.       Confirming appointments is good. The NHS are using this to try and 
reduce no shows and I believe it is having a positive effect.

2.       Surveys – OK, but only if they have consented to be asked, I would 
say,

3.       Asking them to contact, I suppose is also good, assuming you have 
tried to call them first. I would be upset if everytime an organization 
wanted me to contact them they texted me to call them. Especially when a lot 
of organizations use 0844/0845/0800 numbers which generally cost mobile 
users and are rarely included in free minutes.

4.       Confirming balances is an interesting one. Privacy issues arise 
here, I would say, but having said that I have recently taken to using the 
new O2 money card, mainly to test it out as a possible way of providing my 
son’s allowance by this method, but more latterly because it is very good. 
Every time you use the card you receive a  text detailing what you have 
spent, where and what the remaining balance is. At one time I would have 
been concerned about possible privacy issues, but the benefits far outweigh 
the negatives.



I think, if carefully considered, then your proposals are doable, but your 
processes and consent mechanisms need to be whiter than white.



Simon Howarth.





From: This list is for those interested in Data Protection issues 
[mailto:[log in to unmask]] On Behalf Of Paula Tighe
Sent: 27 October 2009 14:08
To: [log in to unmask]
Subject: [data-protection] SMS Texting - Policy/Procedures and Asking for 
Permission



Dear members



I was hoping you could guide, supply and help me with a piece of work I am 
researching.



We are looking at engaging customers via sms-texting, the forms would take:



* Confirming a repairs/general appointment
* Asking them to take part in a survey
* Asking them to contact as we would like to discuss a matter
* Confirming the balance on their rent account/arrears etc *





I wanted to gather your experience to ensure I have covered everything in my 
tool-kit.



*I do not feel this is an option due to the sensitive nature of the data but 
my clients are wanting to use this mode of communication for this purpose.



I look forward to your response/debate



Kind Regards



Paula Tighe

Data Protection Compliance Coordinator

Risk & Compliance Directorate

OGL Services (part of Orbit Group Ltd)

Email:  [log in to unmask]

Tel:      024 7643 8312

Mobile: 07901510029



  _____


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