Privacy Policy Disclosure Missing
Why This Rejection Happens
Unlike Code 30908 (Missing Policy), Code 851 usually indicates the policy exists but lacks specific disclosures required for SMS compliance. Carriers require you to explicitly state that you collect "mobile phone numbers" and use them for "SMS/text messaging." Generic terms like "contact information" or "communications" are insufficient.
Compliance Gap Analysis
A standard "GDPR" or "CCPA" privacy policy often groups all contact data together. For 10DLC carriers, this is a red flag. They need to see a distinct acknowledgment that phone numbers are being collected specifically for text messaging purposes.
Missing Elements Checklist
- Failure to list "mobile phone number" as a specific category of collected data
- No explanation of how mobile numbers are used (e.g., "for account alerts" or "for promotional offers")
- Missing contact information for users to exercise privacy rights
- Omission of data retention periods for SMS consent records
How to Fix Code 851
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Update "Information We Collect" Section
Edit your privacy policy to explicitly list mobile phone numbers as a collected data point.
Recommended Language
"We collect information you provide directly to us, such as your name, email address, and mobile phone number when you sign up for our text messaging program." -
Update "How We Use Information" Section
Clearly define the purpose of SMS messaging. Avoid vague terms like "to contact you."
Recommended Language
"We use your mobile phone number to send you account notifications, order updates, and promotional offers (if you have opted in). We do not share your mobile phone number with third parties for their marketing purposes." -
Verify Security & Retention
Ensure your policy includes a statement about data security and how long you retain consent records (typically 4 years for TCPA compliance).
Carrier Nuances
T-Mobile & AT&T
Strictly enforce the distinction between "contact info" and "mobile numbers." If your policy groups them, it will likely be rejected again.
Verizon
Looks for data sharing disclosures. Even if you fix the "Disclosure Missing" (851), ensure you also include the "No Sharing" clause to avoid triggering code 7103.
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