Do B2B Calls in Singapore Need a Do Not Call Registry Check?

Do you need to check the Do Not Call Registry for B2B calls?

Generally no. The Registry's own site says that telemarketing calls or messages of a commercial nature that target other businesses are excluded from the Do Not Call (DNC) provisions of the Personal Data Protection Act 2012 (PDPA).

The exclusion depends on what the call is about. A call to a company, for that company's own purposes, such as buying accounting services, a point-of-sale system or pest control for its premises, sits outside the rules. A call that is really about the person's own needs does not.

When does a B2B call fall back inside the DNC rules?

It falls back inside the rules when the call is about the individual's own needs rather than the organisation's.

If your pitch is to a company, about running that company, and your opening says so, you are on the safer side of the line. If part of your list is people you would approach about their own affairs, treat those numbers as needing a check.

How the line applies to your list is a question for a lawyer, since the facts of each campaign differ.

How does a Registry check work, and how long does it last?

Checks are made through the DNC Registry Portal at dnc.gov.sg. You set up an account on the portal, then submit the numbers you plan to call.

The portal has a Small Number Lookup, which takes up to 10 numbers at a time and shows results immediately. For a larger list, Bulk Filtering takes a CSV file of numbers, and the results are available within 24 hours.

A check result is valid for 21 days. That period has applied since 1 February 2021, and the PDPC's page on checking numbers refers to the 21-day validity. If your call campaign runs past 21 days from the check, check the numbers again before the later calls.

Someone who is on the Registry can still receive marketing if they give you their clear and unambiguous consent in written or other accessible form.

What is a sensible routine for a B2B list?

A short routine covers most cases. First, sort the list into company contacts reached for company purposes, and anyone you would be approaching about their own affairs. Second, run the second group, and any numbers you are unsure of, through the Registry. Third, note the date of the check and keep the result. Fourth, keep a record of every request not to be called again and remove those numbers from the list.

Running the whole list through the Registry removes the argument about which side of the line a number is on. It does mean that some real prospects may drop out, so it is a trade-off between caution and reach, and it is your decision.

What if you use a calling service?

Using a service does not move the question away from the business whose list it is. If you hand over a list, check it against the Registry first, and ask the service in writing how it treats numbers that turn out to be listed.

At Greetsby, the client checks their list against the Registry before sending it and confirms that they have done so when they upload it. Greetsby does not run the check for clients. Anyone who asks not to be called again is not called again, and Greetsby passes that on to the client so the list can be updated.

Greetsby calls the people on the client's own list and books meetings into the client's calendar. The client approves the opening and the reason for the call before any calls start, which is also the moment to confirm the call is about the prospect's business and not their personal needs. If you want to talk it through, write to hello@greetsby.com. Replies come within one working hour, 9.00am to 6.00pm, Monday to Friday.

Questions

Sources

• PDPC: Do Not Call Registry, information for consumers and businesses (dnc.gov.sg)
• PDPC: Check Numbers Against the Do Not Call (DNC) Registry
• PDPC: Do Not Call Registry for organisations (dnc.gov.sg)

General information for businesses in Singapore, not legal advice.