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Monitoring vs. Scrubbing: Protecting Against TCPA Fines

July 12, 2017

The Telephone Consumer Protection Act of 1991 (TCPA) has been a blessing to customers around the world. Now, it’s actually illegal for consumers to receive outreach via phone—whether through calls or texts—that they did not sign up for. However, the TCPA has also been a bit of a thorn in the side of companies that use phone numbers as a primary form of outreach. The problem isn’t necessarily that these companies want to spam customers with unwanted outreach, but rather that they do so accidentally because of recycled numbers.


Due to recycled numbers, organizations have been fined for sending unwanted outreach to customers. Companies work off of lists and, if those lists aren’t updated with current phone number information, sending texts to recycled numbers is inevitable. Industries that are particularly prone to making this mistake are banking, insurance, debt collections, retail and entertainment (think hotels or the travel industry).

So, what can these industries do to stay up to date on phone number information? Monitoring solutions, such as iconectiv’s Right Party Verification for Messaging, can offer companies information about telephone numbers in real time. Monitoring allows companies to keep track of the status of telephone numbers 24/7, which means that they’re constantly aware of any changes that occur. Right Party Verification for Messaging, for example, alerts companies if the telephone number they provided has changed providers,etc. This is an ongoing service that allows them to make sure they are contacting the right party.

Scrubbing, on the other hand, is another common solution to this problem. However, when compared to monitoring, it’s a far inferior option. Scrubbing is a one-time check for the status change of a number. Essentially, companies provide the solution provider with a list of phone numbers and the last time they contacted those numbers. The solution then checks to see if there have been any status changes in that time.

There are some obvious flaws in the scrubbing scenario. What if someone changes their phone number an hour after the scrub? The company can’t turn around and say, “Don’t sue us, we took precautions. They were just poorly timed.” That’s not how the TCPA works, and those companies that send unwanted outreach will undoubtedly be hit with hefty fines.

With monitoring solutions such as iconectiv’s Right Party Verification for Messaging, organizations can stay on top of their phone number database. Monitoring keeps companies up to date with the latest status of the telephone numbers they want to contact, ensuring that they really are reaching the right party each and every time. Not only does monitoring drive revenue by helping companies reach their actual customers and save money by avoiding fines, but it also saves time because it’s automatic. With monitoring, gone are the days of having to periodically scrub for number changes.

 Although monitoring can’t guarantee TCPA compliance or protection—after all, there are other aspects to TCPA—it’s certainly a safer option that scrubbing.




Edited by Maurice Nagle

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