Do Not Call List Scrubbing is one of the most important services to perform before calling consumers and businesses to ensure compliance with the various call prohibitions. “Scrubbing” means to identify and archive those numbers that are on these Do Not Call Lists, including the National Do Not Call Registry, various State Registries, the DMA wireless block, in-house company specific list and wireless portability list to be performed every 30 days for landlines, and every 15 days for wireless cell numbers. Wireless numbers tend to be prosecuted more, carry heavier fines and lawsuits are more prevalent, than with landlines. The 14 States with Do Not Call Lists and “mini TCPA” laws continue to enforce mobile prohibitions, and must be included in all scrubs. 5 States actually don’t allow wireless solicitation at all, even by hand, so these must be included when identifying numbers. And if you are using any kind of automated equipment when calling cells in particular, like auto-dialers, predictive dialers or equipment capable of storing and dialing numbers automatically, you can’t load your scrubbed cell records and dial freely here. DNC List Scrubbing on a bi-monthly (for cells) and monthly (for landlines) basis will always be the basis of a robust call protection program for any company, with records to be available in the timeframe and format that the FTC, FCC, State AG’s and private right of actions demand. “Safe Harbor” means if you have all your compliance policies, procedures and enforcements in place – and you make a mistake – you’re O.K. If the consumer is paying for the call, like on a Voice-Over-IP (VoIP) under the Telephone Consumer Protection Act, such calls are a punishable offense for an unsolicited telemarketing call. Identifying, archiving and dating your calling lists - collectively known as “scrubbing” - before picking up the phone, is the single most valuable procedure to perform to ensure against a lawsuit. To assist companies with List Scrubbing, I wrote a definitive 2015 Guide to DNC List Scrubbing.