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A2P SMS Consent Records: How to Keep Verifiable Evidence

A guide to identifying what can be claimed based on the available evidence and what should be verified before defining an A2P SMS consent record. The sources provided do not establish a universal template or mandatory procedures.

Illustration of an A2P SMS consent record kept separate from transport data

Evidence of authorization is not a transport log

The evidence provided does not define what each transport data point demonstrates about an authorization. It does not support concluding that a record of send requests, routing, or network statuses, by itself, documents the reason for or scope of an authorization.

As a practical step, before using transport data to document authorizations, verify its purpose and scope in primary technical documentation. Keep authorization data separate from transport data until sources justify linking them.

  • The available sources do not establish an authorization-record schema.
  • They also do not determine the universal evidentiary scope of transport data.
Evidence of authorization is not a transport log

There is no evidence of a universal record schema

The available evidence is not sufficient to establish which fields an SMS consent record must contain or to claim that a universal legal schema exists. The regulatory and technical pages provided are general and include no excerpts substantiating SMS-specific requirements or a particular template.

Before defining the record, consult the relevant official sources for each jurisdiction and use case. Verify which requirements apply rather than treating possible fields—such as person, number, brand, purpose, channel, or campaign—as obligations already established by these sources.

  • The sources provided do not establish mandatory fields for an SMS record.
  • They do not verify a required relationship between authorization, brand, purpose, channel, or campaign.
There is no evidence of a universal record schema

Verify how to preserve context and version

The sources provided do not allow verification of how to link an authorization to the version of the text shown to the user or how to preserve that version. They also do not support a specific recording or retention procedure.

As an unresolved issue, consult applicable official sources and, based on them, define how to identify and preserve the relevant text. The available evidence does not allow a technical format or retention period to be presented as universal.

  • The available sources do not establish how to identify form or text versions.
  • They do not determine a method or period for preserving the context.

Verify the relationship between authorization and message

The sources provided do not allow verification of how to link an authorization to a brand, purpose, channel, campaign, or sender. Nor do they support specific rules for deciding whether an authorization covers an intended message.

Before applying an authorization to a use case, verify the relevant rules in official sources for the jurisdiction and message type. The evidence provided does not determine when an authorization may be used for another use case or when a new interaction is needed.

  • No sources were provided that define rules for matching an authorization to a message.
  • Applicability to another use case requires verification in relevant sources.

Verify revocation, access, and retention rules

The evidence provided is insufficient to establish procedures for revocation, propagating changes, access control, retention, or deletion. It does not support stating time limits or describing a specific process as required or validated.

To determine what applies in each case, consult legal sources relevant to the jurisdiction and intended use. The general European Commission page provided offers information about data protection, but includes no excerpts substantiating SMS consent or record-specific requirements.

  • The sources do not establish a revocation procedure.
  • They do not determine access controls, retention periods, or deletion rules.

Specific record controls cannot be documented

The available sources are insufficient to document specific procedures for data minimization, access control, or change traceability applicable to an SMS consent record. They also do not determine fields, responsible parties, or time limits for these purposes.

Before adopting those controls as requirements, seek primary legal or technical sources that address the case. Based on the evidence provided, specific measures cannot be presented as verified.

  • No excerpts were provided to substantiate specific controls for the record.
  • The evidence does not determine access, minimization, or retention rules.

Check which sources support a pre-send review

The evidence provided does not establish a procedure for checking authorization before creating an SMS request. It does not define how to consult a record, determine whether it is current, compare its scope, or respond to ambiguous data.

If you want to implement a pre-send review, first verify its basis and criteria in relevant official or technical sources. The available sources do not allow it to be presented as a requirement or validated method.

  • The sources do not establish a pre-send check.
  • They also do not determine what to do when records conflict or are unavailable.

What the evidence allows us to say about HLR and DLR

The available evidence does not support the claim that a DLR or HLR lookup proves consent, identity, or ownership of a number. No excerpts from authoritative technical documentation were provided to define their evidentiary scope.

This means there is no basis in the sources provided for treating them as proof of authorization, identity, or ownership; it does not mean those sources establish a universal technical conclusion about all their uses. To determine their scope, consult relevant primary technical documentation and avoid attributing capabilities to them that are not documented.

  • There is no basis in the available sources for treating an HLR Lookup as proof of consent, identity, or ownership.
  • The sources provided do not define the universal evidentiary scope of a DLR.
  • Do not infer more from this evidence than it documents.
FAQ

Frequently asked questions

Is there a universal set of fields for an A2P SMS consent record?

The available evidence does not establish which fields a record must contain or support a claim that a universal legal schema exists. Consult official sources relevant to the jurisdiction and use case.

Does a DLR prove that the recipient authorized the SMS?

The sources provided do not support treating a DLR as proof of authorization or define its universal evidentiary scope. To assess what it indicates, consult relevant primary technical documentation.

Does an HLR lookup confirm the ownership or identity of the person who consented?

The available evidence does not support treating an HLR lookup as proof of ownership, identity, or consent. Nor does it establish a universal technical conclusion about its evidentiary scope.

How long must the evidence be retained?

The sources provided do not establish a retention period. Consult official sources applicable to the jurisdiction and use case.

Sources consulted

  1. Protección de datos: marco general de la UEComisión Europea
  2. Normas técnicas 3GPP3GPP
  3. Recomendación E.164Unión Internacional de Telecomunicaciones (UIT-T)
  4. Recursos sobre redes móvilesGSMA
  5. NIST SP 800-63-4: directrices de identidad digitalNIST