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Our Vault Ltd fined £70,000

 Article added: 18/06/2018

Your dialler data still needs TPS screening

Chorley based Our Vault Ltd have been fined £70,000 by the Information Commissioners Office (ICO) for making calls to numbers registered on the Telephone preference Service (TPS) register.

Our Vault Ltd also trades as Our Insurance Vault.

Recognise that although Our Vault called 55,534 numbers registered on the TPS, it was the 179 complaints that triggered an investigation.

You could be unlucky enough to get 179 complaints from calling 179 numbers registered on the TPS. It’s not all about the volume of calls!

Our Vault Ltd was generating leads for its sister company, and FCA regulated business, ST&R Ltd.

Our Vault Ltd conducted survey calls and supplied leads off the back of the surveys to ST&R Ltd. The Commissioner was keen to point out “It is clear, from a review by the Commissioner of call recordings and scripts provided by OVL, that the calls are aimed at promoting ST&R’s products under the guise of research.”

Our Vault Ltd advised that their data was TPS screened prior to being put into their dialler, but then no further screening took place.

You have to screen your data a minimum of every 28 days. That’s the law.

Although Our Vault Ltd were clearly on the ICO’s watchlist, they continued to call numbers registered with the TPS and further complaints were received from consumers who were registered on the register.

It seems that Our Vault Ltd dropped the ball or thought they could justify calling these numbers, but either way they got fined £70,000.

Current ICO Guidance (as of October 2018) states:

“If someone who an organisation has called in the past subsequently registers their number with TPS, the organisation should not make any more marketing calls to them from that point. Even if they have not specifically objected to calls in the past, registering with TPS acts as a general objection which all organisations must respect. An organisation can only call the person again if they have already specifically consented to receive its marketing calls. If so, the fact that they later register with TPS will not override that specific consent, and that organisation may continue to call them.”

Our Vault Ltd fined £70,000

In practice this creates a bit of a problem insofar as many organisations don’t seek specific marketing permission from their customers to be able to continue calling if they register on the TPS after they become a customer.

TPS Services Richard Kane said:

“It gets boring sometimes repeating the obvious. If you’re unsure whether to TPS screen your data, then do it. Play safe.

Although the fine is by far the biggest problem, it’s not the only problem. The extra work and pressure brought to bear by the ICO will take it’s toll (just talk to anyone who’s been fined) and the negative press can be unpredictable.

Once you put your data into your dialler, don’t forget it still needs screening! ”

Finally, but not least of all, just because they’re your customers, doesn’t mean you can make sales calls to them if they’re registered on the TPS. You’re probably thinking that’s stupid, but that is unfortunately the law.”

Companies linked to Our Vault Ltd

If your business purchases or sells data then you should read the latest Direct Marketing Guidance issued by the ICO for a complete explanation of what the ICO expects from companies involved in or buying from the direct marketing industry.
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