You will be able to check whether you may contact each person on your list, and write down why.
Before your first marketing call or text, ask your compliance team how the firm checks numbers against the Do Not Call Registry. Your firm will have its own checking process, and you must use it, even if you already know how to check a number yourself. Many firms run DNC checks centrally, or make representatives submit lists through a set system and keep records in a set way.
The course Prospecting: build a pipeline that does not run dry covers the general rules on prospecting for any business. Lesson 5.1, "What the Do Not Call Registry covers and how to check it", is the foundation on DNC rules. Lesson 5.2, "PDPA basics for prospecting: consent, purpose and records", is the foundation on consent, purpose and records. Those rules aren't repeated in full here. What follows are the extra rules for representatives working inside a regulated firm.
The DNC Registry is run by the PDPC. It lets people register Singapore numbers against marketing calls, text messages and faxes. Before you send a marketing message by call, text or fax to a Singapore number, you must check the number against the relevant register, unless you hold the person's clear consent. A DNC check is only valid for a limited period. The PDPC website has the current rules, the exemptions and the validity period.
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 you generally need a person's consent, or another basis the Act allows, to use their personal data for marketing. You may only use the data for the purposes the person was told about when it was collected, or for purposes they 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 only. Using it to market insurance is a different purpose.
Daniel (an invented example) is a new representative at a regulated financial firm. In his first month, his manager suggests he start with his warm market, meaning the people he already knows. He has three lists: 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. All three look like prospects to him. They are not equally safe, and for one of them the answer is almost certainly no.
His phone contacts are mostly people he knows personally. A personal message to someone you know, asking whether they would be open to a conversation, is different from a marketing blast, and is acceptable in principle. A marketing call or text to a friend's Singapore number is still covered by the DNC rules, and the rules make no exception for friends. Lesson 5.1 tells the story of a representative who assumed they did.
The car dealership spreadsheet is the clearest problem. The people on it 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 the list would very likely breach the PDPA, and it may also breach confidentiality terms with his previous employer.
The yoga studio sheet sits in between. A third party collected the details for another purpose, a free class. It is a problem unless the sheet told people their details would be shared with an insurance representative for marketing.
Bought lists aren't in Daniel's pile, but they carry a hidden risk. A seller may claim the people consented to marketing, but you usually cannot check what they were told, by whom or for what purpose. If a person on a bought list complains, you and your firm are the ones who used the data.
The source of each contact matters, so start by identifying where each list came from. If you did not build a list yourself with clear consent, because it was inherited, bought or collected by a third party, ask your compliance team before you use it. They can tell you whether the firm allows the list, what checks it needs and what records to keep. Ask before using the list, because an apology from compliance after a complaint is worth much less.
What protects you is a record kept for every contact. Daniel adds three columns to his contact list. The first is the source, which is where the contact came from. The second is the consent basis, which is the basis he has for using the person's details for marketing. The third is the DNC status, which records whether a DNC check is needed and when it was done.
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 and the consent basis is what the form said. The DNC column notes whether that consent covers calls and texts. The car dealership list does not go into his contact list at all, and you should likewise leave out any list you cannot lawfully use.
Fill in the three columns for every contact. Building the record takes time the first time. After that it becomes a habit, and you keep it up to date as you add each new contact.
In the activity below you fill in source, consent basis and DNC status for 20 names from your own list.
Pick 20 names from your contact list. For each one, write down where the name came from, the consent basis and whether it needs a DNC check.
Junxiong-WFG Organisation is an authorised representative of AIA Financial Advisers Private Limited (Reg. No. 201715016G).