Lions, and Tigers, and CALL DATA…Oh My!

In the movie The Wizard of Oz, we were instructed to “pay no attention to that man behind the curtain!”  In the telemarketing industry, call data is that “man behind the curtain.” Through our experience, we’ve seen many companies choose to simply leave him back there, pulling his levers and turning his dials. However, when we pull back the theoretical curtain, what is revealed can be friend, or foe.

Call data audits can be a powerful tool in documenting that a company’s internal or vendor calling processes and procedures are working properly and compliantly. On the flip side, the results of an audit on calling data can present itself more like the Wicked Witch of the West rather than Glinda, the Good Witch, and have us shaking in our boots (I mean really, who didn’t shake in their boots as a kid when she showed up on the screen!). Although the data revealed has potential to be less than pleasing, it can demonstrate critical issues that need to be resolved that may not have otherwise been discovered… until it’s too late.

Regular internal and/or external vendor data audits can significantly reduce, or even eliminate, the number of issues by:

• Verifying evidence of consent;
• Ascertaining whether a phone number is wireless;
• Verifying proper use of exemptions;
• Ensuring dials occurred within the grace period;
• Discovering periods or trends of high issue rates;
• Identifying bad records; and
• Finding duplicate records.

Recently, a company was relying on consumers to self-identify if their telephone number was a wireless number when completing their online web form. The required express written consent disclosure language, as required by the TCPA, was only displayed if the number was identified by the consumer as a wireless number. A data audit revealed that approximately 35% of the telephone numbers not identified as wireless, actually were. And as you may have already guessed, dials to those numbers were made using an ATDS and, therefore, putting the company at risk for violations of the TCPA requirements.

Due to the litigious regulatory landscape today, we can take nothing for granted and must put an end to ignoring “that man behind the curtain.” Internal call centers and external vendors should expect that you will inspect. With the number of TCPA class action lawsuits rising 112% between 2012 and then end of 2014, clearly “Toto, we’re not in Kansas anymore.”

Additionally, CompliancePoint is offering a run test file of up to 10,000 records through its data audit process to help your company determine its TCPA & DNC compliance status. To take advantage of this complimentary data analysis, feel free to contact us at consulting@compliancepoint.com or (855) 670-8780.