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Glossary · Compliance

What is Do Not Call (DNC)?

  • Also called: do not call registry, internal dnc

Reviewed by Sujan ThapaliyaLast updated

Definition

Do Not Call rules require telemarketers to suppress numbers on the national registry and on their own internal list. Internal do-not-call requests must be honoured within a short window and kept indefinitely, and they override any other consent.
The three STIR/SHAKEN attestation levels, which underpin how do not call (dnc) behaves in practice: A asserts both that the carrier knows the customer and that the customer may use the calling number, B asserts the customer only, and C asserts neither. A shared number pool can reach B at best, which is why number ownership keeps recurring in these definitions.
Attestation is the backdrop to most caller-ID and deliverability terms, do not call (dnc) included.

In practice

How do not call (dnc) actually works

There are two lists and both bind. The national registry must be scrubbed against on a regular cycle; the internal list records anyone who has asked you specifically to stop.

An internal request beats an existing business relationship. Someone who bought last month and then asks not to be called must be suppressed.

Scrubbing has to happen before dialling, not as a post-campaign report. That is the difference between a control and an audit finding.

Registry scrubbing also does nothing about the list you already hold. Numbers added to the registry after your last scrub sit in your database looking exactly like the ones you may call, which is why the obligation is recurring rather than a step at import — and why the date of the last scrub is the first thing asked for in a complaint.

Scrubbing once at list purchase is not compliance — the registry changes while you are calling.
ObligationFrequencySource
Scrub against the national registryAt least every 31 daysTelemarketing Sales Rule
Honour an internal do-not-call requestPromptly, and permanentlyApplies even where an exemption would allow the call
Established business relationship18 months after purchase, 3 after enquiryNarrower than most sellers assume
Keep the evidenceBefore the complaint, not afterA defence you cannot show is not a defence

Worked example

A list bought in January and scrubbed once is illegal to call by March: the registry gains numbers continuously, and the Telemarketing Sales Rule expects a scrub at least every 31 days.

Do Not Call (DNC): common questions

How often must I scrub against the do-not-call registry?
At least every 31 days under the Telemarketing Sales Rule. Scrubbing once at list purchase is not compliance; numbers are added to the registry continuously and a list goes stale while you are calling it.
What is an internal do-not-call list?
Your own record of people who asked you specifically to stop calling. It is separate from the national registry, it must be honoured promptly, and it applies even where an exemption would otherwise let you call.
Do existing customers count as exempt?
There is an established business relationship exemption, but it is narrower and shorter-lived than most sellers assume, and it does not override a direct request to stop. Treat it as a defence you might need to evidence rather than a general licence.

Sources

  1. Combating Spoofed Robocalls with Caller ID Authentication — Federal Communications CommissionThe STIR/SHAKEN framework, the attestation levels carriers sign calls with, and the mandate requiring providers to authenticate caller ID.
  2. 47 U.S.C. § 227 — Restrictions on the use of telephone equipment — Cornell Legal Information InstituteThe Telephone Consumer Protection Act itself — the consent requirements, calling-hours limits, and private right of action.
  3. ITU-T Recommendation E.164 — The international public telecommunication numbering plan — International Telecommunication UnionThe international number format, the 15-digit maximum, and how country codes and national numbers compose.

See do not call (dnc) in the product

An auto dialer is any system that places outbound calls without a person keying digits. There are four modes — power, preview, progressive and predictive — and they differ in how many calls run per rep and who hears the phone ring first. All four are in the base product here, switchable per campaign.

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