Code of Conduct

Introduction

This Code of Conduct is drawn up under Article 5(4) of resolution 42/13/CIR of the Autorità Garante delle Comunicazioni ("AGCom", Italy's communications authority), "Rules for trialling alphanumeric indicators to identify the calling party in SMS/MMS used for business messaging services" ("the Resolution"), and its purpose is to govern the creation, assignment and use of Aliases within business messaging services and to set out rules to protect users of those services.

Messaging services are the services provided by an authorised provider under the Resolution for a Customer/Company, a natural or legal person, that wishes to reach its own End Customers through SMS or MMS messages communicating its own offers of products or services, or service information and, as the case may be, asking those End Customers for a reply to the communication sent.

Messaging services that involve sending a message to End Customers are commonly referred to as "MT" ("Mobile-Terminated") messaging services, while messaging services that involve a reply from End Customers are "MO" ("Mobile Originated") messaging services. MT services may be provided using Aliases as an alternative to using the CLI. This code deals exclusively with enterprise messaging services using Aliases.

1. Definitions  

For the purposes of this Code, in line with the resolution cited above, the following are defined:

a) Customer/Company: the natural or legal person who uses, or asks to use, a business messaging service by subscribing to an offer from a business messaging service provider;

b) End Customer: the natural or legal person who uses or requests to use a publicly available electronic communications service for purposes not related to the work, commercial or professional activity carried out;

c) Business messaging: SMS/MMS communications, sent individually or in bulk, to End Customers by a Customer/Company, such as businesses or bodies, for social, informational and advertising purposes;

d) Business messaging service provider: a legal entity authorised under Article 25 of the CCE which, on the basis of specific contracts with Customers/Companies, provides the business messaging service through the use of Aliases to End Customers (cf. Article 4(1));

e) Access service provider: legal entity authorised under Article 25 of the CCE that provides mobile services, including the messaging service, to the End Customer;

f) CLI - Calling line identification: identification of the calling line by means of the number defined by ITU-T Recommendation E.164 and nationally by the National Numbering Plan (Del. 52/12/CIR as amended) associated with that line;

g) Alias: a string of alphanumeric characters transmitted in the field used for sending the sender/CLI in SMS/MMS communications, no longer than 11 characters, as set out in Annex A to this Code;

2. Guiding principles of the Code

The Code aims to ensure the proper development of business messaging services, safeguarding the rights of Customers/Companies on one side and of End Customers on the other, and fair competition between players in the sector. In this context the players in the sector intend to give themselves common rules of conduct with the aim of growing the market through respect for the rights of the End Customers who receive the messages.

In this regard, the players in the sector will apply their best experience and diligence to ensure that Customers/Companies use the Aliases correctly.

3. Creation of Aliases 

Aliases consist of a set of alphanumeric strings no longer than 11 characters, the details of which are set out in Annex A to this code.

 4. Assignment of Aliases 

Aliases are assigned on the basis of the rules in force on trade marks. The business messaging service Provider will act with the utmost diligence to prevent parties holding no rights over a given Alias from using an Alias whose lawful use belongs to third parties under trade mark law. To that end, business messaging service Providers will first adopt procedures to authenticate the Client/Company through credentials, so as to ensure that the Client/Company that has signed up to a business messaging service offer is indeed the party accessing the message sending system and using the Aliases. In addition, business messaging service Providers will do their best to include in contracts with Clients/Companies specific clauses making Clients/Companies responsible for using only Aliases they are lawfully entitled to, and to that end they may also have the Client/Company sign a specific self-declaration. Clients/Companies found to have used Aliases unlawfully will be barred from using those Aliases.

5. Assignment of generic Aliases

The Resolution prohibits the use of Aliases already used for other Customers/Companies and of Aliases that do not differ significantly from Aliases already in use. In this context the assignment of generic Aliases is allowed provided that Customers/Companies undertake, in their contracts with business messaging service providers, to include in the message text a reference to their company name or to a trade mark they lawfully use, so as to remain recognisable to the End Customer.

 6. Assignment of Aliases referring to public bodies and institutions 

Aliases that refer to public bodies and institutions are reserved exclusively for those same bodies or institutions and may not be associated with other parties.

7. Uploading the Aliases to the database managed by AGCom

Before sending a message with an Alias, enterprise messaging service Providers shall upload to the database managed by AGCom (for brevity also the "Alias System") the Aliases used by their Customers/Companies. The following information will be entered in the database, indicatively:

• Alias and associated E.164 numbering;

• Client/company name, VAT number/tax code;

• Client/company contact details: a single contact detail among telephone number, fax number, email address;

• Stopping use of the Alias when it is no longer in use;

The name of the business messaging Service Provider as well as the date and time of the records are recorded automatically by the Alias System. The  actual  specific  information  to  be  linked  to  each  Alias  may  be  updated  following any changes to the technical”operational arrangements of the Alias System.

8. Use of Aliases by Customers/Company 

The use of Aliases is permitted to Customers/Companies that have signed up to an enterprise messaging services offer with enterprise messaging service Providers that have been assigned for use one or more E.164 numbers from the PNN to associate with the Aliases, in compliance with art. 3, paragraph 2 of the Resolution. Several different enterprise messaging service Providers may sign up to an enterprise messaging services offer with the same Customer/Company. Each Customer/Company must be associated with a unique number. More than one Alias may be associated with that number, provided they are used by the same Customer/Company.

9. Customers/Company ceasing to use Aliases

 A given Alias will remain active for as long as the contract between the business messaging service Provider and the Customer/Company is in force, except where, while the contract is in force, the Customer/Company itself tells the Provider that it no longer wishes to use a given Alias. Within 24 hours of the termination of the contract between the business messaging service Provider and the Customer Company, or of the business messaging service Provider receiving notice that a given Alias is no longer to be used, the Provider will notify the cessation of use of the Alias to the Alias System.

10. Protection of End Customers

An End Customer who receives an SMS/MMS message whose sender is an Alias considered unexpected, misleading or spam can contact the Customer Care of their mobile operator, reporting the case and giving the operator the following information necessary to carry out the required checks:

a) numbering of the end customer;

b) Alias shown in the sender of the message;

c) day, date and time of receipt;

Customer Care, by querying the database managed by AGCom, receives the following information about the Customer/Company that sent the message and passes it on to the End Customer:

• Client/Company name;

• Alias used;

• Client/Company contacts;

Should the competent Authorities request the tracking data of the message sent, the enterprise messaging service Provider shall deliver such data as quickly as possible so as to serve the purposes of justice.

11. Later versions of the Code 

The enterprise messaging service Provider reserves the right to prepare new and more advanced versions of this Code in future in order better to meet the business needs of the sector's players and to better protect the rights of End Customers, in step with the evolution of enterprise messaging services containing Aliases and of the relevant rules, which are currently still at an experimental stage.

Poppix Srl
PI/CF: 01213200072

Registered office: 

Piazza Chanoux 28/A
11100 Aosta – Italy

Attached to 

CHARACTER SET ALLOWED FOR CREATING ALIASES 

With reference to paragraph 6.2.1 "GSM 7bit Default & Alphabet" of the technical standard "Digital cellular telecommunications system (Phase 2+); Universal Mobile Telecommunications System (UMTS); LTE; Alphabets and language-specific information", 3GPP TS 23.038 version 11.0.0 (2012″ 10) Release 11, only the following is permitted for the creation of aliases.

1. the lower-case and upper-case letters of the international alphabet: 

• ABCDEFGHIJKLMNOPQRSTUVXYWZ (HEX codes from 41 to 5A respectively)

• abcdefghijklmnopqrstuvxywz (HEX codes from 61 to 6A respectively)

2. The accented lower-case letters on the Italian keyboard: 

• èéùìò (HEX codes from 04 to 08 respectively)

• à (HEX code 7F)

3. The digits 0 to 9 

• 0123456789 (HEX codes 30 to 39 respectively)

 4. Common punctuation marks:

• SP (space: HEX code 20)

• ! (exclamation mark: HEX code 21)

• ‘ (apostrophe: HEX code 27)

• , (comma: HEX code 2C)

• . (full stop: HEX code 2E)

• : (colon: HEX code 3A)

• ; (semicolon: HEX code 3B)

• ? (question mark: HEX code 3F)

NB: the characters above cannot be preceded by a space character.

Consecutive spaces are not allowed.

• “ (quotation marks, HEX code 22)

An Alias may contain only two quotation marks: one opening and one closing.

The first cannot precede a space and the second cannot follow a space.

5. Common currency symbols 

• € (euro: two-character HEX code 1B 65)

• £ (pound: HEX code 01)

• $ (dollar: HEX code 02)

6. Common mathematical symbols  

• % (per cent: HEX code 25)

• ( (open round bracket: HEX code 28)

• ) (closing round bracket: HEX code 29)

• + (plus: HEX code 2B)

• – (minus or hyphen: HEX code 2D)

• = (equals: HEX code 3D)

7. Symbols used on the internet:

• @ (at sign or “at” : HEX code 00)

• _ (underscore or “underscore” : HEX code 11)

• # (hash sign or “hash” : HEX code 23)

• & (and: HEX code 26)

• * (asterisk or “star” : HEX code 2A)

Ultimately, the list of permitted characters and the corresponding ETSI hexadecimal encodings to be used when transmitting SMS/MMS, as well as the corresponding UTF"8 hexadecimal encodings to be used in communications to the Authority's database, are as follows:

CharacterETSI encodingUTF-8 encodingCharacterETSI encodingUTF-8 encodingCharacterETSI encodingUTF-8 encoding
@04083838Z5A5A
£1C2 A393939a6161
$224:3A3Ab6262
è4C3 A8;3B3Bc6363
é5C3 A9=3D3Dd6464
ù6C3 B9?3F3Fe6565
ì7C3 ACA4141f6666
ò8C3 B2B4242g6767
_115FC4343h6868
SP2020D4444i6969
!2121E4545j6A6A
“2222F4646k6B6B
#2323G4747l6C6C
%2525H4848m6D6D
&2626I4949n6E6E
‘2727J4A4Ao6F6F
(2828K4B4Bp7070
)2929L4C4Cq7171
*2A2AM4D4Dr7272
+2B2BN4E4Es7373
,2C2CO4F4Ft7474
–2D2DP5050u7575
.2E2EQ5151v7676
03030R5252w7777
13131S5353x7878
23232T5454y7979
33333U5555z7A7A
43434V5656à7FC3 A0
53535W5757€1B 65E2 82 AC
63636X5858
73737Y5959

As a result, the table of usable characters organised according to the ETSI encoding is as follows.

b700001111
b600110011
b501010101
b4b3b2b1HEX01234567
00000@ 40SP 200 30P 50p 70
00011£ C2 A3_ 5F! 211 31A 41Q 51a 61q 71
00102$ 24” 222 32B 42R 52b 62r 72
00113# 233 33C 43S 53c 63s 73
01004è C3 A84 34D 44T 54d 64t 74
01015è C3 A9% 255 35E 45U 55e 65u 75
01106ù C3 B9& 266 36F 46V 56f 66v 76
01117ì C3 AC277 37G 47W 57g 67w 77
10008ò C3 B2( 288 38H 48X 58h 68x 78
10019) 299 39I 49Y 59i 69y 79
1010A* 2A: 3AJ 4AZ 5Aj 6Az 7A
1011B1)+ 2B; 3BK 4Bk 6B
1100C, 2CL 4Cl 6C
1101D– 2D#NOME?M 4Dm 6D
1110E. 2EN 4En 6E
1111F? 3FO 4Fo 6Fà C3 A0

 SP corresponds to the space character

1) is not a character but indicates the code (HEX 1B) to be placed before it to indicate the characters in the Extension table. In particular, the encoding HEX 1B 65 corresponds to the character €, whose UTF"8 encoding is E2 82 AC. The character € is the only character in the Extension table that can be used.

In each cell the first line shows the character according to the encoding of the 3GPP TS 23.038 version 11.0.0 (2012″10) standard

 The second line shows the corresponding UTF"8 encoding to use in communications to the AGCOM database.

Updated version February 2020