St. Cloud State University Text Messaging Procedure

St. Cloud State University (SCSU) ensures that all text messaging practices comply with applicable federal and state laws, including the Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, the Minnesota Government Data Practices Act, and Minnesota State policies.

Email remains the university's official method of communication with students, faculty, and staff. The use of text messaging is limited, must serve a specific business purpose, and requires approval through appropriate university channels before implementation.

Scope

This procedure applies to all text messaging applications, systems, services, vendors, and university employees conducting official university business on behalf of St. Cloud State University.

University employees include faculty, staff, administrators, student employees, graduate assistants, contractors, and vendors acting on behalf of the university.

This procedure applies regardless of whether messaging occurs on a university-owned device or a personally owned device used for university business.

Definitions

Call to Action
An invitation for an individual to opt in to receive text messages from the university. The call to action must clearly explain the purpose of the messages and obtain appropriate consent.

Consent
Permission granted by an individual to receive text messages. Consent requirements vary based on the type of message being sent.

Conversational Message
A back-and-forth exchange between university personnel and an individual recipient.

Emergency Message
A message relating to the immediate health, safety, or security of the campus community.

Informational Message
A non-emergency message related to university business, such as advising, reminders, or student support communication.

Promotional Message
A message that promotes an event, service, program, fundraising activity, or marketing initiative.

Mass Text Message
An identical or substantially similar message sent to more than ten recipients.

Opt-In
An action through which an individual provides consent to receive text messages.

Opt-Out
An action through which an individual withdraws consent and stops receiving messages.

Official University Purpose
Communication conducted in support of the university’s educational, operational, or administrative functions.

Privacy and Data Practices

  • Employee personal cellular telephone numbers are private and may only be used with employee consent.
  • Student cellular telephone numbers are limited directory data and may only be used for legitimate university business purposes.
  • Text messages related to university business are government data subject to the Minnesota Government Data Practices Act and records retention requirements.
  • Devices used for university text messaging must comply with Minnesota State technology use and information security requirements.

Only university-approved text messaging platforms, applications, systems, and vendors may be used to conduct university business. The use of unapproved messaging services or applications is prohibited unless specifically approved through appropriate university processes.

Employees using personal devices for approved university text messaging activities must comply with all applicable university and Minnesota State policies and procedures, including information security requirements, technology procurement requirements, records retention obligations, and Minnesota State Procedure 5.22.2, Cellular and Other Mobile Computing Devices.

Consent Requirements

Conversational Messages

  • If an individual initiates the conversation, consent is implied.
  • If the university initiates the conversation, prior consent must be obtained.

Informational Messages

  • Require express consent.
  • Consent may be obtained through forms, websites, applications, registration processes, email, verbal agreement, or text opt-in.
  • Consent applies only to the stated purpose.

Promotional Messages

  • Require express written consent.
  • Consent must be documented and clearly tied to the promotional purpose.

Emergency Messages

  • May be sent without prior consent when necessary for health or safety.
  • Must follow university emergency communication procedures.

Requirements for University Text Messaging

All text messages must:

  • Support an official university purpose
  • Identify St. Cloud State University or the sending department
  • Be sent only to individuals with appropriate consent (except in emergencies)
  • Comply with all applicable laws and policies
  • Include opt-out instructions when applicable
  • Inform recipients that standard messaging and data rates may apply
  • Use approved platforms for mass or automated messaging
  • Be retained according to records retention requirements

All text messaging systems, applications, services, and vendors used for university business must be reviewed and approved through appropriate university processes prior to implementation.

Employees may not use personal messaging accounts, unapproved applications, or third-party messaging services to circumvent university approval, security, procurement, records retention, or data privacy requirements.

Important: Email is the university's official method of communication. Text messaging must not be the sole means of communicating essential information.

Prohibited Uses

Text messaging may not be used to communicate:

  • Social Security numbers
  • StarID credentials or passwords
  • Financial account information
  • Student grades or protected educational records
  • Private personnel information
  • Personal matters unrelated to university business
  • Commercial advertising unrelated to the university mission
  • Any content prohibited by law or university policy

Oversight and Approval

Mass text messaging platforms, automated messaging systems, and vendors must be reviewed and approved through appropriate university processes, including Information Technology Services.

Departments are responsible for maintaining consent records, honoring opt-out requests, and ensuring compliance.

Compliance

Failure to comply with this procedure may result in suspension of text messaging privileges and additional corrective actions consistent with university policy, collective bargaining agreements, and applicable law.