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Stopping Illegal Robocalls Where They Start

Best Practices for Lead Generators

A large fraction of the robocalls we receive are placed by Lead Generators. This cottage industry is part of the massive world of marketing. Like a TV commercial or a billboard or a post card in your mailbox, a phone call from a lead generator is an attempt to sell you some product or service. Because telephone calls are more intrusive than those other channels, federal and state regulations put a lot of constraints on this approach (also called “telemarketing”).

For consumers, adding your name to the FTC’s Do-Not-Call list is some of your best protection against these calls. Once your number is on the DNC list, a telemarketer has to have your explicit consent to call you. So in theory, the only calls you’ll get are ones that you requested (perhaps by visiting a web site and asking for a callback to get more info about something you’re interested in).

Some lead generators are very well-behaved — they follow all the regulations and they show respect for the people they call. There are also a lot of bad lead generators; thanks to them, the industry has earned something of a poor reputation. Here, I’m publishing my suggestions for best practices that a telemarketer might follow if they want to minimize the ire their calls could otherwise provoke.

  1. For any given campaign promoting a product or service, use a single calling number (no neighbor-spoofing or snowshoeing). No matter what, when calling a given number repeatedly, use the same caller-ID for each call. Associate a descriptive CNAM with your caller-ID(s).
  2. First thing, announce: the name of the caller, their (clear and unambiguous affiliation), the consent that was obtained, and the called party’s name.Hi, this is Gloria with State Farm Insurance in Bloomington, Illinois. Conrad Smithfield came to the web site last week and requested that we call with an auto insurance quote. Is Conrad available?
  3. Address any questions or concerns raised by the called party before insisting that your questions are answered. Be prepared to offer a web URL and telephone number where the called party can turn for more information.
  4. If the called party indicates that they did not consent, or that they are no longer interested, or wish to revoke consent, or are argumentative or unwelcoming of the call – indicate that you will not call again and cancel their consent.
  5. Allow at least 30 seconds (5 ring cycles) for the called party to answer. Ensure the called party hears audio within 2 seconds of their greeting. No silent calls.
  6. If the call is answered by voicemail, leave a message with the elements in (2) above, plus a call-back number. The callback number should match the caller-ID. It should answer 24×7 and include an opt-out mechanism. Do not hang up on voicemail.
  7. Limit calls to a given number to 2 in a single day and no more than 5 in a month.
  8. Originate your calls via a telecommunications provider that can sign your calls with Attestation Level A using their own STIR/SHAKEN token.
  9. If special circumstances justify deviation from these guidelines (such as a recruiting web site with multiple positions, or a debt collector) document your practices on your website.

These best practices aren’t laws, but they do incorporate many of the existing regulations. I believe that if a lead generator believes that the people they are calling have in fact consented to the call and really do want to hear from the caller, then all of these practices will make sense. I always welcome dialog regarding refinement to these notions.

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