Campaign Guidance - Ireland - DCB

Ireland – Guidance and Regulations – DCB – Header Enrichment

Please ensure that you review the Commission for Communications Regulation - Code of Practice.

Campaign

Price

  • This must be clearly displayed in a prominent and proximate position to the call to action, it must be listed on its own line and separate from the service description and terms.
  • The price must be directly above or below the call to action, e.g. payment button.
  • The currency symbol must be displayed, e.g. €2.50, along with the message breakdown if you are charging a higher amount e.g. €7.50 (sent as 3 x €2.50 messages).
  • It must be the same size as the call to action.
  • The price and description must be on a solid background, with a good level of contrast between the background and text, e.g. Grey on white will not be accepted.

Home page requirements

  • The service name must be visible on all marketing material, including banners that are used to advertise the service.
  • A clear service description must be included, explaining what the consumer is going to get when they sign up to the service.
  • If the content is delayed, or the consumer needs to complete further steps to gain access to the content, for example create a profile, this should be made clear to the consumer on the home page, prior to signing up, so they know what they will need to do, to gain access to the content.
  • The payment button must be clearly labelled with words that state an “unambiguous obligation to pay e.g. Buy Now.
  • Full Terms and Conditions link must be available on the home page, this should be detailed and include terms on all aspects of the website including mobile billing. There should also be a Privacy Policy section, or separate link.

Disclaimer Terms

  • The campaign must specify whether the service is aimed at a certain audience.
  • If applicable, specify how ‘data rates apply’ if the consumer needs internet access to view/access the content.
  • If the consumer can only access the content via the device that they paid on, this must be made clear on the home page.
  • A clear customer care helpline number must be displayed, which does not charge more than the basic rate.
  • The level 2 provider name must be clearly displayed, e.g. the name on your Comreg PRS license.


Message Flow

Billing messages:

  • You need to include the service name, price and support details in the first billed message.
  • Each message must include the campaign name.
  • Each message must be different e.g. You cannot send the same message multiple times; this creates confusion for users and complaints from the networks.
  • We recommend that you include a “sleep” between the billed welcome message and the rest of the billed messages, to ensure that the user is aware of the regulatory details and that the message is not lost in the middle of the other billed content messages.

Stop: This is not required for one-time services however, if you implement a free trial period, then the consumer can be given the option to opt-out during the free trial period.

  • FreeMsg: You have cancelled [name of service] and will not be charged. Helpline 0******* {no more than national rate}.


Marketing

There are several different marketing methods available in Ireland, however you must ensure that you do not mis-lead consumers, advertise a service using an unrelated banner or state that something is free, when that is not the case. If you implement a free trial, you will need to specify the length of this on your advertisements. 

You will need to provide our Compliance Team with information on your marketing plans, along with copies of any banners that you intend to use.

Please note that you can only use the Google Display Network and Facebook to advertise your campaign when using the Direct Carrier Billing (Header Enrichment) option in Ireland.

If you plan to use the customer's details to market to them in the future, you must gain permission from the user and ensure that you provide them with a clear and simple method to opt-out.


Commission for Communications Regulation (Comreg)

You must register with the Irish regulator, the Commission for Communications Regulation - Register here.

If you have already registered, please supply us with your registration number and ensure that txtNation is listed as your provider on the campaign license.

For further information, please view the Regulator website here.


Failed Delivery Messages / Retries

You cannot retry outstanding messages for the whole billing period. You can only re-attempt for 7 days. Please see an excerpt from the Comreg Code of Practice below, which outlines this:

5.23 - If a reverse-billed premium rate message fails to deliver to an end-user, irrespective of whether the message is related to a Subscription Service or not, the PRS Provider must not:

  • Charge the end-user for that failed message,
  • Attempt to deliver the failed message outside the original charge period if it is part of a Subscription Service, or
  • Attempt to deliver the failed message after seven days, if the message is not part of a Subscription Service.


Customer care / Refund Policy

All service providers must have a detailed customer care process and refund policy in place. Consumers need to know how to gain help should they require it and you need to confirm a refund policy for those that require one or are eligible for one.

This will be discussed in detail, to ensure that our customer care team can resolve any queries that are received from the networks or regulator. 

Question? Speak with our Compliance Team for any advice for this or any other market.