How to prove you’re TPS Checking your data
Article added: 05/06/2017
How we use data has been under intense scrutiny by every regulator since the end of 2015. Since that time, the word has spread and many companies are learning that there’s more due diligence required when buying and using data than they realised.
You simply cannot buy ‘anything’ from ‘anyone’, at least not anymore.
Part of this increased scrutiny by the regulators revolves around TPS Checking.
The Telephone Preference Service (TPS) and Corporate Telephone Preference Service (CTPS) registers are the main method for consumers and businesses to opt out of receiving unsolicited sales and marketing calls.
Registration on either register does not physically block calls and so companies failing to screen causes complaints which in turn causes criticism that the TPS ‘does not work’. The regulators have therefore hit back by working with each other to enforce the TPS and hitting companies hard with fines and enforcement notices. In some cases, costing companies their licences.
If that’s not bad enough, get in the regulators bad books and it will follow you around to your next company like a bad smell!
What do I need to do to prove I TPS check my data?
There are three things you need to do to prove that your business has a robust TPS screening practice in place.
1 Show you spend money TPS Checking – it may seem like an odd thing to say, but if you can’t show a commercial relationship with a company providing TPS screening you won’t be able to ‘back date’ something when the regulator comes knocking.
Regular Screening Invoices
You can either keep copies of your TPS Screening invoices in a file or pull them out if you get audited.
Get a TPS Services annual contract
You won’t need to bother with invoices if you get an annual contract as you can use that to show you have TPS Screening facilities in place throughout the year. Talk to us about contracts if that’s something you’re interested in.
2 TPS Complaints – If you’re checking properly every 28 days then you ought not to have any TPS complaints, but if you do get one deal with it promptly. Keep the TPS complaints in your TPS file ready to discuss with the regulator if needed.
If there is an explanation to offer as to why you called a number registered on the TPS then note that down. You won’t remember it 6 months from now, but it could help you demonstrate that you have identified a weakness in your systems and what you’ve put in place to plug it.
3 Double check the work of your TPS Screening provider – this sounds daft, we know, but the principal that the regulators like to see is that you, as a responsible business, do not take for granted that anyone including your TPS Screening supplier is doing their job properly. So what you need to do is double check that their systems work and make that a regular monthly routine.
We suggest you take a small number of telephone numbers (for example 30), run them through your TPS Services account and check the results and log them in an XLS. Then, use an alternative source to double check that the results are consistent. You can use www.tpsonline.org.uk/tps/registered.php for free to check up to 4 numbers each day.
By going through this exercise, it demonstrates that you are not taking for granted that the quality of work undertaken by your TPS Screening provider is necessarily right.
If you come up with any queries, investigate them and annotate those too.
Due Diligence Form