Check the Do-Not-Call Registry Before Marketing to Singapore Phone Numbers
As surveys reveal that 90% of Singaporeans have access to a smartphone, many companies continue to rely on telemarketing and cold calling as a means of prospecting customers. These organisations will need to pay attention to consumer laws regulating the use of personal data for marketing purposes.
This guide will help your business comply with the relevant regulations, especially if you employ telemarketing activities as part of promotion and marketing.
What is the Do Not Call (DNC) Registry?
The Do Not Call (DNC) Registry is a database where individuals can register their mobile/telephone numbers to opt out of receiving unsolicited marketing messages and calls.
Marketing messages are generally defined as messages used for advertising or promoting goods and services, suppliers or suppliers of such goods and services. This extends to the advertising and promotion of interests in land or business/investment opportunities.
However, messages sent for conducting market research surveys or for charitable and religious purposes are exempted.
It is important to note that the DNC Registry provisions also applies to the sending of telemarketing messages through smartphone applications such as WhatsApp.
B2B marketing calls or messages sent to other organisations do not fall under the purview of the DNC Registry. If an individual uses a number for both personal and business use, he/she may still receive B2B marketing calls or messages that are sent to his/her number as a business phone number.
When do You Need to Check the DNC Registry?
There are three separate Registers of Singapore telephone numbers – voice calls, text messages and fax, depending on the organisation’s method of outreach.
Under the Personal Data Protection Act (PDPA), your organisation is required to screen your call lists with the relevant registers prior sending out marketing messages to Singapore telephone numbers.
All businesses who need to use the DNC Registry for screening will need to create an account at a one-time fee of $30 ($60 for overseas companies) to gain access. Your company can log on to the DNC Registry website to start an account.
Are There Any Situations Where You do Not Need to Check the DNC Registry?
Unless your organisation has obtained clear and unambiguous consent in written or accessible form from the subscriber of that telephone number, you are required to check all telephone numbers before sending out telemarketing messages.
Under the Personal Data Protection (Exemption from Section 43) Order 2013, an organisation is able to send telemarketing messages without checking the DNC registry if several conditions are satisfied:
- It must have an ongoing relationship with the subscriber, characterised by a business relationship or activity between the organisation and subscriber, i.e. a subscription, membership, account etc. One off transactions or past interactions do not fulfill this definition.
- The content of the message must be related to the subject of the organisation’s ongoing relationship with the subscriber.
- It must provide an opt-out facility at the end of the message, usually in the form of a short code or text message reply. Once the subscriber has opted out, the organisation has to cease sending any telemarketing messages to that subscriber after 30 days of the opt-out.
How can an Organisation Check the DNC Registry?
Once at the DNC Registry website, you will have to submit a list of telephone numbers you wish to screen against the DNC Registry. There are 2 ways to do this:
(I) Small Number Lookup
You can enter up to 10 phone numbers manually at one time. Results of the search are displayed immediately.
(II) Bulk Filtering
Under this option, your company can check more than 10 numbers at one time by uploading a CSV file containing a list of all 8-digit Singapore telephone numbers. Once the check is complete, an automated SMS or email can be sent to notify you. Within 24 hours, the results will be available for download in the following formats:
- Filtered Numbers: This displays the list of submitted numbers and their status (Registered/Not registered) in each Register (Voice/call/fax)
- Summary: A summary of the submission (quantity submitted/checked/rejected)
- On behalf list: If your company is checking the telephone numbers on behalf of another organisation(s), the list of organisation(s) is displayed here.
- Rejected numbers: This lists all the numbers that cannot not be processed, accompanied with reasons for the rejection.
All results are valid for 30 days, after which if your company wishes to conduct telemarketing activities, you will have to check with the DNC Registry again.
How Much will it Cost to Check the DNC Registry?
Upon submission of numbers, the DNC Registry will process and begin deducting one credit for each 8-digit telephone number. The DNC Registry allows for an annual 1000 free credits, which is useful for businesses that have less than 1000 numbers to check.
For additional checks beyond the 1000 free quota, your organisation is required to pay a fee.
There are 2 options for payment:
Purchasing credits in advance. There are different tiers (A to G), corresponding to 5000 – 1000,000 credits. Depending on the credit tier selected, this can cost between $100 to $10,000.
(II) Pay per use
Your company pays a fee each time it submits telephone numbers for screening. A minimum charge of $10 applies regardless with an additional 2.3 cents – 2.5 cents charged per telephone number submitted.
Both online (credit/debit) and offline (Telegraphic Transfer or bank transfer) payment modes are available.
For more detailed information on pricing structures and conditions, please refer to the Personal Data Protection Commission (PDPC) website here.
What are the Penalties for Sending Specified Messages to Numbers Listed on the DNC Registry?
Sending telemarketing messages to numbers listed on the DNC Registry without consent is an offence. Any organisation that breaches the DNC Registry provisions in the PDPA is liable to pay a fine up to S$10,000 per offence.
As an example, Star Zest Tuition agency became the first company to be charged under the PDPA in 2014 for breaching the DNC Registry requirements. The tuition agency was found guilty of sending out unsolicited messages marketing the teaching services of its tutors to numbers listed on the DNC registry.
Both its director and Star Zest Tuition agency were fined $39,000 each after pleading guilty to 13 of the 37 charges of contravening section 43 (1) of the PDPA.
The need to check the DNC Registry before sending marketing messages to Singapore phone numbers will place additional compliance requirements on companies that engage in B2C marketing and promotions via SMS or phone calls.
It will be necessary to educate your organisation’s telemarketing and sales teams on these regulatory requirements. For a start, it will serve your company best to create an account with the DNC Registry as this also allows you to start budgeting for any necessary compliance expenses.
You should also consult a data protection lawyer if you need legal advice on how your business can comply with the PDPA when marketing to Singapore telephone numbers.
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