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@Kelli Ryan Consent is usually collected when you ask on your website or some other form if you are able to text the customer/user for whatever reason, i.e. Jury Duty, court dates, etc.
This form or documentation is what you would provide when registering with TCR.

As far as registration for your city numbers, focus on the main and support numbers.
We will move the numbers under your new TCR Brand ID.
The other pages, I think are just attempting to put urgency around the main numbers not being registered and losing access to SMS altogether.

For campaigns, this piece from the FAQ might be helpful:
A campaign lets us know how you're using your phone numbers to send SMS. A company will typically have only one brand ID but may have several campaign IDs, depending on its SMS usage. For example, if the medical facility Acme Healthcare wants to send appointment reminders to its end customers via SMS, the campaign ID for that usage would be “appointment reminders.”

I might suggest reviewing the FAQ to see if it can address any further questions.
And please share any additional questions here, if they should pop up or shoot us an email at Community.Support@RingCentral.com

Thank you for the response. I read through the FAQ's and any other documentation I've been able to find, which is what led to these questions.

Regarding the consent piece, I understand we need to obtain consent prior to sending SMS to customers, however, the language I referred to in the first message indicates we need consent before we can register or the application will be rejected, which doesn't make sense. If we can explain how we will be obtaining consent, shouldn't that be sufficient?

An additional question I have received from users recently regarding consent is if someone sends a message to one of our RingCentral numbers, expecting a response, is that considered consent? Or, do we need to obtain consent before we can respond to an SMS?

Another issue we have is that some users are simply sending updates to employees throughout the day who work in the field to their city-owned phones. Can the city provide consent for SMS to any of the mobile phones we own and assign for employee use? It seems ridiculous that we would have to obtain permission from employees to send them information for their jobs to our owned phones.

I don't know that we want to have all of our numbers registered for SMS, due to the potential for abuse. If I create a campaign for each user or group of users' needs and list their specific numbers, they will be the only ones able to send SMS going forward, correct?

@Kelli Ryan Your Question:
An additional question I have received from users recently regarding consent is if someone sends a message to one of our RingCentral numbers, expecting a response, is that considered consent? Or, do we need to obtain consent before we can respond to an SMS?

Yes, this falls under implied consent and you are allowed to respond, finish the conversation with them. However, it is not consent to add them to a list or send them updates/ marketing messages later in the future unless they request it.

Your Question:
Another issue we have is that some users are simply sending updates to employees throughout the day who work in the field to their city-owned phones. Can the city provide consent for SMS to any of the mobile phones we own and assign for employee use? It seems ridiculous that we would have to obtain permission from employees to send them information for their jobs to our owned phones.

I believe that the owner of the number needs to give consent, so if the business owns the phone, the business should be able to provide consent.

Thank you for the clarification thus far. I have one additional question: Being a city government, are we required to register? Our city attorney's opinion is that this does not apply to government. Is there anything I can reference/cite which indicates whether government is included or specifically not excluded? I'm receiving a lot of push back from users regarding the need to include opt-out language in messages that are in response to a text, particularly, and so the attorney is now involved. I have basically told our users that, in additional to registering:

1 - You must obtain consent prior to sending messages, unless a) they initiate the conversation and you only answer the question/request b) you are texting an employee who is using a city-owned phone, in which case we have provided the consent.

2 - You must keep records and ensure that any opt-out requests are honored

3 - You must include opt-out language at the end of every text message you send

Am I understanding the requirements incorrectly?

Unfortunately, because of the way SMS was reclassified, all RingCentral (and other "business providers") traffic is considered 10DLC A2P, and is subject to these policies. While there is currently a concept of "unregistered" traffic, my understanding is that mobile carriers may block this traffic at any time with little or no notice (as reflected by the March 31 date in our notices).

In order to ensure compliance with aggregator/ carrier policies and the rules surrounding 10DLC A2P, all RingCentral customers are required to register with TCR to continue using SMS. This includes government entities (note TCR lists "government" as a specific entity type to choose from). While I cannot provide legal advice, I can tell you that other government agencies have elected to complete TCR registration.

Again, if your TCR registration is not completed, carriers may block your SMS traffic at any time, with little or no notice.

While bullets one and two are required (bullet two states keeping records, this is more important for informational and promotional messages), opt-out language is only required on informational (as a reminder you have a court date scheduled... Reply STOP to end reminders) and marketing messages. You do not need to include opt-out language on conversational messages, but you do need to honor opt-out requests.

@Kelli Ryan My understanding is it depends if that will be sufficient.
You need to provide copy or screenshots of how that consent is obtained and it will be evaluated for compliance.

I'm looking into your other questions around consent via an initial SMS message and SMS messages to employees on company devices.
Give me some time to source an answer.

For your latter question, the numbers associated with the campaigns will be the ones that have access to the SMS.