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Compliance

Compliance is
architecture here,
not a policy

Every competitor in this industry has a compliance paragraph. Ours is a page, because the rules are enforced by the system that places the call rather than by a document nobody opens.

01 The dial check

What happens before a call is placed

Every record passes these gates before it is presented to an agent. Pick a market to see the same architecture applied to a different rule set, including one that fails.

Dial check
+1 (480) 555-0114
state
AZ
timezone
America/Phoenix
local time
09:42
  • timezone sourcederived from lead address and area codepass
  • calling windowpermitted 08:00 to 20:00 localpass
  • dnc registrynot listed, checked at dial timepass
  • internal suppressionno prior opt-out on this recordpass
  • attempt cap2 of 3 used this periodpass
  • recording consentone-party state, disclosure readpass
  • qa capturerecorded and queued for reviewpass
Cleared to dial

Every gate is evaluated against this lead’s own timezone, not the agent’s.

02 TCPA-aware dialing

TCPA-aware dialing

The Telephone Consumer Protection Act and the state rules layered on top of it are not a single switch you turn on. They are a set of conditions that differ by state, by time of day, by the consent attached to the record and by how many times that record has already been called.

We built the dialer around that reality. Each record carries its own compliance context, and the platform evaluates that context at the moment of dialing rather than relying on a list having been correct when it was imported last week. Where a condition is not satisfied, the call is not placed and the record is held.

This page describes the operating controls we run. It is a description of our systems, not legal advice, and it does not replace your own counsel on what your campaign requires.

03 Calling hours

Calling hours on the lead's timezone

This is the control most often got wrong, and it is got wrong in a way that is easy to miss. A floor calling from one timezone against records spread across several will breach calling windows constantly while every clock in the building says the working day is perfectly normal.

Our platform derives the timezone from the lead's own address and number, then evaluates the permitted window against that local time. An agent sitting anywhere in the world cannot place a call into a state where it is too early or too late, because the record is not eligible until it is. Windows are held per state rather than as one national rule.

Timezone derived per record Taken from the lead's address and dialling code, not from the agent's location or the campaign's default.
Windows held per state Where a state sets a narrower window than the federal rule, the narrower window is the one applied.
Evaluated at dial time Eligibility is checked at the moment of the call, so a record that becomes ineligible mid-session stops being dialled.
Held, not discarded A record outside its window returns to the queue for the next permitted window rather than being lost or force-dialled.
04 Attempt caps

State-level attempt caps

Several states limit how many times a consumer may be called within a defined period. Those limits differ, and a campaign that applies one cap everywhere is either breaching the strictest states or leaving contact on the table in the rest.

Attempt counts are held against the record itself and evaluated against the cap for that record's state. When a record reaches its cap it stops being eligible, and no amount of pressure on the floor changes that, because the constraint sits in the platform rather than in a rule an agent is asked to remember.

05 DNC

DNC scrubbing and enforcement

Scrubbing a list at import is not the same as enforcing DNC at dial time, and the gap between the two is where most breaches live. A record can be clean on Monday and registered by Thursday, and a campaign that only checked at import will keep calling it.

We do both. Data is screened before it enters a campaign, and DNC status is checked again at the moment of dialing. Internal suppression is treated with the same weight: when someone asks us not to call again, that request is applied across campaigns rather than only to the one they were speaking to.

Screened on load Records are scrubbed before they enter a campaign, against DNC in the US and TPS and CTPS in the UK.
Enforced at dial time Status is checked again when the call is placed, so a registration made after import still stops the call.
Internal suppression is permanent An opt-out is held against the contact and applied across every campaign we run, not just the one that generated it.
Applied to supplied data too Data a client provides is screened on the same terms as data we source. We do not dial an unscrubbed file because it arrived from the client.
06 Recording consent

Recording consent, gated by state

We record every call, which means we have to be exact about consent. One-party and two-party consent states require different handling, and a single national recording policy is guaranteed to be wrong in one direction or the other.

The consent regime is attached to the record's state and the platform applies it before the call connects. In two-party states the consent gate is armed and the required disclosure is part of the call flow rather than something an agent is trusted to remember at the top of a long shift. UK calls carry the notification required there.

07 QA review

Recorded is not the same as reviewed

Plenty of operations record every call and never listen to any of them. Recording only becomes a control when somebody reviews the recordings against a standard and acts on what they find.

Calls are scored against a written scorecard that covers the opening, the disclosures, how qualification was handled and how the call was closed. Reviewers calibrate against each other so the standard does not drift, and anything that looks like a compliance breach is escalated rather than averaged away. Clients see the QA outcomes for their own campaign, including the exceptions.

How QA works on a campaign

08 UK markets

The same architecture in the UK

UK campaigns are not a US campaign with a different area code. The registers are different, the consent expectations are different, and the data protection regime is materially stricter.

The platform handles UK records under UK rules: screened against TPS for consumer numbers and CTPS for business numbers, dialled inside permitted local hours evaluated on the record's own timezone, and recorded with the notification required there. Data handling for UK and EU contacts follows UK GDPR, which is described in our privacy policy.

Ask us the hard compliance questions

Most buyers in this industry have been burned by an operation that treated compliance as paperwork. Bring the questions that got a vague answer last time.