Think you know how to stay compliant with the latest call prohibitions? Try doing it without scrubbing your calling lists every 30 days for landlines and 15 for cells. Imagine the Consumer Financial Protection Bureau auditing your call center without those records handy. Imagine surviving the Telephone Consumer Protection Act without scrubbing your wireless inventory against both Federal and State lists before each campaign. After over ten years of Telephone Sales Rule domination, Do-Not-Call list scrubbing is still the basis of individual and call center compliance. Here are a few tips to make sure you’ve got things buttoned up.
The best way to identify cells on call lists - Video
In case you’re not familiar with it, the term “scrub” means to track down and store certain phone numbers, and then don’t call them. Numbers that are on the various call prohibition lists: The National DNC Registry, State Lists, wireless block, and your own internal do not call list. And it’s critically important to make sure the new all-star on the block is under control – the wireless mobile number. Little did we know the cell phone would become our personal communication to the world. And to violate those new wireless telemarketing laws would incur costs we could never have imagined.
So call center managers violating these best practices can find trouble in a hurry; a hosted dialer partner trying to rush a campaign without proper number identification updates can lead to disaster; and some mistaken TCPA regulation advice omitting critical compliance steps can open up a world of hurt with the FCC or private right of actions.
And when things go wrong with Do-Not-Call mistakes, they tend to go south in a hurry.
Entire campaigns are escaping the scrutiny of your correctly updated State lists because the IT officer was out sick. Time Warner’s legal team once called me with 48 overnight Do-Not-Call violations. Yep, they forgot to update their lists against the various registries before launch.
5 tips to make sure your Telephone Sales Rule regulations are being followed every day:
If you’re handling compliance scrubbing chores in-house, have someone designated to update Federal and State Registrations. As they expire, and usually at different times, they won’t be included in your scrubbing procedures, and DNC liability exposure goes through the roof. You’d be amazed at how often this little step is overlooked, as everyone thinks someone else handled renewals. See our Blog: "Vendor Oversight: most Overlooked Component of TCPA Do Not Call Compliance."
If you do make a scrubbing mistake, apologize immediately while you’re on the call. Don’t just hang up. Don’t upset the cell owner. And make a clear notation in your CRM or call center records of the date and time of the potential infraction. And if that consumer calls back to complain, bring it to resolution immediately. See out blog: "Call Center Manager Best Practices for No Complaints."
Make sure ALL lists are included in your scrubbing procedures. It’s amazing how often something is omitted. Particularly company specific in-house requests that never make it to the IT department for updates.
Keep track of list labeling, dating and archiving, and make sure these scrubbed records are available in the format and timeframe the FTC, FCC, State AG’s or smart consumer litigants might want them. If you can’t find the data when you need it, you’re just foolin’ yourself.
Have the handful of little compliance requirements under control to help survive a Safe Harbor Assessment by Government Agencies. Your company specific in-house list up to date and included in scrubs, your Do-Not-Call Policy sent out on demand, agent DNC training records filed and up to date and available – and all policies, procedures and enforcements on hand for review at any time.
It’s human nature to get sloppy with our primary compliance efforts...
as we explore the bright lights of the latest compliance offerings – like how to eliminate previous TCPA litigators from our call lists, or bringing our business to business calls up to speed on cell and DNC registrations. Even VoIP is a new frontier in possible litigation when calling the consumer: See our blog: "VoIP Line TCPA Regulations Penalty Court Case".
Do-Not-Call List Scrubbing is still the backbone on which all our phone marketing compliance efforts are based
It’s not easy to remember all those holidays are we’re not supposed to communicate with folks, or to locate our latest express written consent permissions so we CAN call those numbers, and add them to the campaign.
Whether you handle scrubbing chores in-house or have a competent third party on board for the heavy lifting – three cheers for the managers that keep those lists under control everyday, cutting down on DNC identification mistakes, risks and ultimately TCPA violations and lawsuits.
Here’s to the guys and girls in the trenches that after all these years get it: Do-Not-Call list scrubbing is still the key to DNC compliance!For more information, just call Bob directly at 561-317-3001.