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[Incident] Add disclosure to identified templates #3464

Description

@connorscarolyns

🔧 Incident Action Item

🎯 Action Required

Description of Action Item:

Add an appropriate data-rate disclosure "Data rates may apply. Frais de données peuvent s'appliquer." to all existing SMS templates identified during the incident review as containing links and failing current telecommunications requirements.

Where appropriate, services may use a disclosure matching the language of the message, provided it continues to meet the required standard.

Type of Action:

  • Fix / Remediation
  • Mitigation
  • Hardening / Resilience
  • Monitoring / Alerting
  • Documentation Update
  • Process / Governance
  • Other: ___

🧵 Incident References

Incident Slack Channel:
https://gcdigital.slack.com/archives/C0BSDQD86PR

Post-Mortem Document:
https://docs.google.com/document/d/1G1YGz72iwJC9h1BVWXpPFHDoHduvQr38j0AxvDXyp1g/edit?usp=sharing


🎛 Current Mitigations in Place and Risk Assessment

Templates identified through the audit have been reviewed, and disclosures can be added manually to bring affected templates into compliance.

This addresses the known affected templates but does not prevent users from creating or editing templates that introduce the same issue in future.

Risk of Recurrence:

  • High
  • Medium
  • Low

Potential Impact (if it happens again):

  • System stability
  • Notifications delivery
  • User experience
  • Security / privacy
  • Operational burden

✔️ Definition of Done

  • All identified non-compliant services have been notified of the change to come
  • All identified non-compliant templates have been updated with an appropriate disclosure
  • Risk owners confirm closure

📦 Additional Notes

This is remediation for templates already identified through the incident and audit. Preventing future non-compliant templates is covered through separate actions for content guidance, template validation, and send-time validation.

Link to draft communication:
https://docs.google.com/document/d/1G1YGz72iwJC9h1BVWXpPFHDoHduvQr38j0AxvDXyp1g/edit?tab=t.6m2neq5s5lxx

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