# Responsible commercial WhatsApp policy

An operational template from Makers Commercial Radar.

This file is a starting point for teams using WhatsApp for customer service, qualification, follow-up or conversational sales. It does not replace legal advice.

## 1. Principle

WhatsApp should only be used when there is context, a clear expectation, demonstrable consent where required, or a conversation initiated by the contact.

The team does not use WhatsApp as a shortcut to contact cold lists without context.

## 2. Permitted cases

- The contact started a conversation on WhatsApp.
- The contact asked to continue on WhatsApp.
- A form, advert, QR code or event identified WhatsApp as the channel.
- An existing customer or opportunity has an active relationship and a reasonable expectation.
- Follow-up was agreed during a previous call, meeting or email exchange.

## 3. Cases to avoid

- Initial cold contact to personal numbers.
- Bulk messages or automated sequences without supervision.
- Numbers obtained through scraping, purchased databases or an unverified source.
- Contact after an opt-out, block, refusal or prolonged silence.
- Requests for sensitive data in a conversation without a specific assessment.
- Messages without identification, a clear reason and an opt-out.

## 4. Minimum CRM record

- Source of the contact.
- Associated company and person.
- Channel used.
- Reason for the approach.
- Evidence/context of consent where applicable.
- Message sent.
- Response.
- Opt-out or stated preference.
- Next step.
- Internal owner.

## 5. Responsible message

Structure:

1. Identify the person and company.
2. Give the context for the contact.
3. Make a simple request.
4. Offer an alternative or an opt-out.

Example:

> Hello, I'm from Makers. We spoke today about organising the enquiries you receive on WhatsApp. May I send the summary of next steps here, or would you prefer to keep it on email?

## 6. Operational limits

- Define a maximum number of attempts.
- Do not apply pressure through email, calls and WhatsApp at the same time.
- Stop after a refusal or when there is no clear basis to continue.
- Hand sensitive conversations, complaints, significant commercial enquiries or topics outside the script to a person.
- Review negative responses, blocks and opt-outs weekly.

## 7. Pre-campaign review

Before activating a live campaign:

- validate the legal basis and consent;
- review Portuguese Law 41/2004 and the GDPR;
- validate WhatsApp/Meta policies;
- confirm retention and evidence of consent;
- test the opt-out;
- confirm the internal owner;
- simulate handover scenarios to a person.

## 8. Note

This is an operational template. Adapt it with support from legal counsel, a DPO or the person responsible for privacy where applicable.