You will be able to check whether you may contact a person on your list and record why.
In his first month, Daniel's manager suggests he "start with his warm market". Daniel has three lists to hand: 400 contacts in his phone, a spreadsheet of customers from his previous job at a car dealership, and a sign-up sheet from a friend's yoga studio where people left their numbers for a free class. They all look like prospects to him. They are not equally safe to use, and for one of them the answer is almost certainly no.
The general rules on prospecting are covered in Prospecting: build a pipeline that does not run dry. If you have not taken it, two lessons there are the foundation for this one: lesson 5.1, What the Do Not Call Registry covers and how to check it, and lesson 5.2, PDPA basics for prospecting: consent, purpose and records. They explain the rules for any business. This lesson does not repeat them in full. It adds what changes when you are a representative working inside a regulated firm.
In brief, the DNC Registry, run by the PDPC, lets people register Singapore numbers against marketing calls, text messages and faxes. Before sending a marketing message by those channels to a Singapore number, you check the number against the relevant register unless you hold the person's clear consent, and the check is only valid for a limited period. The PDPC website has the current rules, exemptions and validity period.
What changes for you is that your firm will have its own checking process, and you must use it. Many firms run DNC checks centrally, or require representatives to submit lists through a particular system and keep records in a set way. Ask your compliance team how it works before you make your first marketing call or text, and follow that process even if you know how to check a number yourself.
The DNC rules are about the channel. The PDPA's data protection rules are about the data itself, and they apply whatever channel you use.
Under the PDPA, to use someone's personal data for marketing you generally need their consent, or another basis the Act allows. And you may only use the data for the purposes the person was told about when it was collected, or would reasonably expect. A phone number given to a car dealership so the customer could be told when the car was ready was given for that purpose. Using it to market insurance is a different purpose.
This is why the source of each contact matters. Daniel's phone contacts are mostly people he knows personally, and a personal message asking whether they would be open to a conversation is a different thing from a marketing blast. Even so, a marketing call or text to their Singapore numbers is covered by the DNC rules, which do not make an exception for friends. Lesson 5.1 of Prospecting tells the story of a representative who assumed they did.
The car dealership spreadsheet is the clearest problem. Those customers gave their details to a different business for a different purpose. They did not consent to be marketed financial products by a former salesman at a new firm. Using that list would very likely breach the PDPA, and it may also breach whatever confidentiality terms Daniel had with his previous employer.
Bought lists carry a similar risk that you cannot see. A seller may say the people on it consented to marketing, but you usually cannot check what they were told, by whom or for what. If a person on the list complains, it is you and your firm who used their data.
The yoga studio sheet sits in between. The people on it gave their numbers to the studio for a free class. Unless the sheet told them their details would be shared with an insurance representative for marketing, using it is a problem.
The rule for representatives is simple: before you use any list you did not build yourself with clear consent, ask your compliance team. They have seen these situations before and can tell you whether your firm allows it, what checks it needs, and what records to keep. Ask before you use the list. An apology from compliance after a complaint is worth much less.
The protection that works is a record, kept for every contact, that shows where the contact came from, what basis you have for using their details for marketing, and whether a DNC check is needed and when it was done.
Daniel adds three columns to his contact list: source, consent basis and DNC status. For a friend from school, the source is "personal contact", the consent basis is "none for marketing yet; will ask before any product discussion", and the DNC status is "check before any marketing call or text". For a person who filled in an enquiry form on his firm's website, the source is the form, the consent basis is what the form said, and the DNC column notes whether the consent covers calls and texts. The car dealership list does not go in at all.
It takes time the first time you do it. After that, it is a habit you keep up as you add each new contact. In the activity below you do it for 20 names from your own list.
Take 20 names from your contact list and record for each the source, the consent basis and whether a DNC check is needed.
Junxiong-WFG Organisation is an authorised representative of AIA Financial Advisers Private Limited (Reg. No. 201715016G).