Changing your telephone number when making sales calls
Article added: 16/06/2017
In an effort to increase sales, some dialler companies offer their customers a solution where the company’s CLI is changed to the same CLI as the number being called.
For example, if your business is based in Birmingham and you call a number in London beginning 0207 then the dialler would dial the number showing a CLI beginning with 0207.
This process is designed to make the recipient of the call believe that it’s a local number calling them and in turn has the desired effect of increasing call connectivity as more people are inclined to answer an unknown number calling them if they think it’s local.
But is it legal?
Shortage of telephone numbers in the UK
Telephone numbers are in short supply within the UK and have been for some time. There are around 610 different STD codes in operation and some companies offer a pool of numbers that their dialler will use to represent your outbound call.
Whilst this may get you the desired effect of getting the target caller to answer their phone, there are consequences.
Diallers offering the facility to change your businesses telephone number to match the STD code of the number you are dialling tend to operate in one of three ways:
1. A general pool of telephone numbers (CLI’s)
Some diallers will present a CLI from a general pool of numbers from within the system. These numbers may be used generally by every business using the dialler company’s services.
This method of masking the true location of a business is not legal for many reasons, least not of which that your business will be essentially presenting a CLI that does not belong to it when making calls.
Consumers can of course never call you back on the same number as it will go nowhere. It can’t, as the same number will be used by multiple businesses using the same facility from the same dialler provider.
These numbers will often, when called, simply put the caller through to a pre-recorded message of some kind.
From a legal perspective, regulation 21 of the Privacy Electronic Communications Regulations (PECR) explicitly forbids this use of CLIs:
Calls for direct marketing purposes
(A1) A person shall neither use, nor instigate the use of, a public electronic communications service for the purposes of making calls (whether solicited or unsolicited) for direct marketing purposes except where that person—
- (a) does not prevent presentation of the identity of the calling line on the called line; or
- (b) presents the identity of a line on which he can be contacted.
2. A pool of fake telephone numbers (CLI’s)
Similarly to example 1 above, some diallers offer a solution whereby not only is it pulling from a pool of CLI’s that can be displayed to match the target callers location, but the numbers simply don’t exist.
So when the caller tries to call back, they get a number not recognised message from the network.
Believe it not, companies are still using this method. Perhaps to hide their identity, perhaps in an attempt to avoid complaints, but the practice is still going on.
Although the net result is very similar to example 1 above, this is much worse insofar as neither the caller nor the regulator would have very much to go on to investigate any complaints.
3. A pool of real telephone numbers (CLI’s) dedicated to your business
Using a degree of logic, this option may seem reasonable insofar as each number would in fact dial back to the business. However, the same logic that is used in changing the CLI you’re calling from to match the person you’re calling is actually the source of the issue that causes a regulatory problem.
The regulators don’t like the concept that businesses are ‘pretending’ to be somewhere they are not.
We enquired with OFCOM about the practice for clarification and they said:
The use of multiple CLIs in this fashion could constitute persistent misuse, if the purpose is to increase call pick-up rates by deceiving consumers into thinking a local person is calling. If enforcement action was taken against a company doing this it would be assessed on a case by case basis and we would always advise that the company seeks its own independent legal advice.
Richard Kane, of TPS Services says:
The practice of rolling the CLI’s to match the destination you’re calling is one of many practices that has come about in recent years that has now fallen casualty to the latest raft of compliance measures that has hit the industry since the end of 2015.
If you think about it, it’s a fairly reasonable restriction really. People interrogate the CLI calling them as to whether to answer the call or not. If businesses could display any CLI they wanted, no one would have faith in any number calling them and that would have serious consequences for everyone.
So in short, just don’t do it.