Tracing the Thread of Consumer Consent: Tracking Consent & Revocation of Consent
Tracing the thread of consumer consent can be an incredibly difficult task given today’s complex cellular world. So how exactly does a company track consent and revocation of consent in order to fully comply with current regulations?
DialConnection has put together this mini guide to help you along the way. But first, let’s get clear on consent.
Customer Consent & Revocation
As a telemarketing company, it’s your job to track customer consent and revocation of consent, but this can be a bit tricky. According to FCC regulations, consent can be given either by the person who primarily uses the wireless phone or by the wireless subscriber. Consent from either party is considered consent to call that specific number.
The challenge is that the individual who gives consent to call a specific number and the one who revokes that consent may not actually be the same person. Further, there’s no guarantee that one person informed the other that they granted consent. So the business needs to not only track that consent had been granted, but also should track which party gave consent, when it was granted, and in the form it was granted.
Of equal importance is that either party may also revoke consent, and they may do so in any number of ways. According to the FCC, “A caller may not limit the manner in which revocation may occur.” The FCC rules say that its up to the consumer to decide how revocation occurs, not the business.
Many leading firms accept revocation of consent from anyone associated with the account, transaction, or phone number regardless of how loosely connected they may be. So from a best practice perspective, move that phone number to your Do Not Call list.
How to Track Consent & Revocation
The next step is figuring out how to properly track the current consent status of each phone number in your system. What you’ll need is consent-related policies and procedures that are both sustainable and practical.
A recent InsideARM article suggests using call recording and retrieval technology to “capture and retrieve consent recordings.” But that’s just one way your organization might receive a revocation of consent or may “ask” to be placed on the Do Not Call list, including by mail, inbound and outbound phone calls, via chat, IM or text messaging, and even through correspondence with an attorney. Each of these methods should be treated in the same manner: as a source of data that needs to be updated in a centralized electronic system that tracks the consent status for each cellular phone number.
Through exploiting the latest innovations in call center solutions, including call recording, text file searches tools, and speech analytics tools, you can automate the process and more easily identify when consent and revocation of consent has occurred.
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