Handling Do Not Call Requests in Travel
Do Not Call List Management for Call Performance
Pay per call marketers use their time very prudently as they wade through a number of complex DNC rules, within each state, at the national level, and internal opt out requests. Federal law mandates scrubbing call lists against the National DNC Registry at least every 31 days. The tight liability imposed by calling numbers on this list does not even make exceptions in cases in which the marketer had no knowledge of the registry status of the number. The exception for “established business relationship” applies for the first 18 months after a purchase or for 3 months after inquiry, not for calls generated through third party leads. Additional DNC registries within some states vary in their requirements, like Florida’s policy of having no expiration as opposed to California’s 5 year registration limit.
Maintaining Compliant Calling Practices
A sound DNC compliance program for pay per call requires a multilayered scrubbing process. Number verification needs to be done in real time against internal opt out lists before any call is connected, with batch processing being employed for National DNC updates. The system should reverse course and suppress any number during an active call for which an opt out request is made. All lead purchasers must have in place “safe harbor” provisions and written agreements requiring the lead providers they use to scrub those numbers properly. Document, document, document: regulators now want evidence proving DNC compliance procedures that include scrub lists, recordings of opt outs, and training of employees. Fines can be as high as $43,792 per violation in some states; hence superior DNC protocols are important for keeping pay per call business alive.
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