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Privacy and Security

Message Senders should address both privacy and security comprehensively in the

design and operation of messaging campaigns. Additional security guidelines and best

practices are described further in the Messaging Security Best Practices.4

5.2.1 Maintain and Conspicuously Display a Clear, Easy-to-Understand Privacy Policy

Message Senders should maintain and conspicuously display a privacy policy that is

easily accessed by the Consumer (e.g., through clearly labeled links) and that clearly

describes how the Message Sender may collect, use, and share information from

Consumers. All applicable privacy policies should be referenced in and accessible

from the initial call-to-action. Message Senders also should ensure that their privacy

policy is consistent with applicable privacy law and that their treatment of information is

consistent with their privacy policy.

5.2.2 Implement Reasonable Physical, Administrative, and Technical Security Controls

to Protect and Secure Consumer Information

Message Senders should implement reasonable security measures for messaging

campaigns that include technical, physical, and administrative safeguards. Such

safeguards should protect Consumer information from unauthorized access, use, and

disclosure. Message Senders should conduct regular testing and monitoring to ensure

such controls are functioning as intended.

5.2.3 Conduct Regular Security Audits

Message Senders should regularly conduct a comprehensive risk assessment of privacy

and security procedures for messaging campaigns on a regular basis and take

appropriate action to address any reasonably foreseeable vulnerabilities or risks.