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Don't it cost like 5 cent a per name to scrub it against the dnc list?
I'd be extremely careful. We are getting "aged" leads submitted as "real time" leads through our system.
What is the legal agreement between you & the lead vendor? Who indemnifies whom? Pretty important IMO.
This type of 'recycled' lead call would be an error. That is, if you comply with the rest of the rules.32. What’s my liability if my company inadvertently calls a number on the registry?
The TSR has a “safe harbor” for inadvertent mistakes. If a seller or telemarketer can show that, as part of its routine business practice, it meets all the requirements of the safe harbor, it will not be subject to civil penalties or sanctions for mistakenly calling a consumer who has asked for no more calls, or for calling a person on the registry. To meet the safe harbor requirements, the seller or telemarketer must demonstrate that:
- it has written procedures to comply with the do not call requirements
- it trains its personnel in those procedures
- it monitors and enforces compliance with these procedures
- it maintains a company-specific list of telephone numbers that it may not call
- it accesses the national registry no more than 31 days (starting January 1, 2005) before calling any consumer, and maintains records documenting this process
- any call made in violation of the do not call rules was the result of an error.