DNC List Scrubbing starts with proper National and State Do Not Call List Registrations, giving you access to these lists before calling. National Registration is done by area code. The first five Area Codes are free, and then it is $69 per Area Code/annually afterwards. You may qualify for some exemptions like “Existing Business Relationship” if the party being called has purchased a product or service from you before. Or “Business to Business Calls” which means you only call other businesses. Keep in mind though, you may still need permission to make these calls to cells even after your national registration exception, with the recent TCPA Rule Changes to Cells.
Several States have additional registrations for their own DNC Lists, which must be included in your DNC List Scrubbing procedures. These states may have additional costs to access their lists. If you’re doing your own list scrubs, you’ll need to gather the National and State information every month for landlines and twice a month for wireless mobile numbers before starting your calling campaign.
If you are making calls, you are actually doing telemarketing. The days of “I’m just taking a survey – no really, I’m not selling anything” are over. You are a for-profit company (in this case you’re selling your surveys later) and you need to register and perform a DNC list scrub, properly saved and with the day, date and time performed.
Watch out for “Free DNC” and “Trial DNC Scrubbing” offers as well as “Do Not Call and TCPA Software”. These DNC solutions may not protect you in court. If you bring in a third party to help with DNC list scrub chores, make sure it’s a robust, certified Do Not Call Law Compliance Service Provider. And make sure you throw some money at these scrubbing challenges. 100,000 numbers scrubbed, dated, archived and sufficiently robust to hold up in court under DNC scrutiny will be between $150 to $200 per month, based on bells and whistles (like Litigant Scrub, VoIP Scrub, and Cell Scrubs). Hey, that’s cheap for multiple $16,000 per incident DNC violations!
Even if you’re not calling cells, you still must register your company with the National and State Registries, and identify or separate those cells from landlines. The Consumer Financial Protection Bureau is on the lookout during audits for cell phone calling procedures today, in fact it’s most likely their #1 priority, given the level of fines levied and cell owner sensitivity.
Be careful if you’re purchasing so called “safe” or “pre-existing relationship lists”. Particularly when provided by a client on whose behalf you are reaching out. If you take on a list to use, you’re responsible for that list. Depending on the source, you may want to perform a DNC scrub on that brokered representation of safe calls. Of particular concern are social media sourced lists containing cells from Linked in and Twitter, many of which are on the National DNC List, and need to be scrubbed out during your DNC procedures.
When scrubbing these DNC Lists, your results will be only as accurate as the data provided. TCPA Lawyers tell us using a third party certified DNC Law Compliance Provider makes sense. This is all these DNC compliance providers do and they seldom make mistakes. Their procedures can be set up in the background to free your IT, Marketing and Sales teams do what they do best – by having the list scrubbing chores on DNC challenges handled beforehand.
Finally, your scrubbing procedures must be strong enough to hold up in court. It's not sufficient for your IT guy trying to help out and save you money by piggy-backing on other company registrations and procedures. The thought of: “We have a guy that handles that list scrubbing thing for us and is registered – I think” doesn’t quite hold up in court.