PICO & Associates Outbound Telesales Do Not Call Policy
The Telephone Consumer Protection Act ("TCPA") was passed in 1991. The Federal Communications Commission's rules and regulations implementing the act went into effect on December 20, 1992. Various states have also enacted statutes that govern telemarketing activities.
PICO and Associates engages in telemarketing to existing customers. PICO and Associates will not call any customer who has communicated his or her desire not to be called. A customer's request not to be called is reflected in the customer's account record and is also noted in the tracker database, which is used, among other things, to track telemarketing contacts with customers. In compiling a list of customers to call for a particular telemarketing campaign, we will not include any customer whose account record is marked "do not call."
On occasion, we may retain a third-party service agency to telemarket its services to persons who do not have an existing business relationship with PICO and Associates. In those circumstances, PICO and Associates and/or its third party service agency subscribe to and scrub against all applicable state and federal "Do Not Call" registries.
PICO and Associates requires that all third-party service agencies telemarketing at its request and under its direction ensure they are in compliance with federal and state laws regarding telemarketing and that they fully understand and agree to follow the procedures for maintaining "do not call" data. PICO and Associates also requires that all telemarketing vendors retained by us report to us in the "daily results file" any customer asking to be removed from telemarketing lists. We do not condone telemarketing activities conducted in violation of the TCPA, its rules and regulations, and state laws regarding telemarketing.
PICO and Associates requires all third-party service agencies that make telephone solicitations at our request and under its direction to:
- Institute procedures for maintaining a list of people who do not wish to receive telephone solicitations (a "do-not-call list");
- Scrub all leads against this do-not-call list before initiating any telephone solicitations;
- When applicable, scrub against required state and federal "Do Not Call" registries;
- Institute and maintain a procedure to capture all do-not-call requests and transmit them in the daily results file to PICO and Associates;
- Develop a written policy implementing this requirement to keep a do-not-call list and make this written procedure available to anyone on demand;
- Maintain the do-not-call list for a period of 10 years and refrain from selling or sharing the do-not-call list (except with a subsidiary or affiliated company) without the customer's consent;
- Train and inform personnel engaged in any aspect of telephone solicitation in the existence and use of the do-not-call list;
- Provide the called party with the name of the individual caller, the person or entity on whose behalf the call is made and a telephone number (which may not be a 900 number or any other number for which charges exceed local or long distance transmission charges) or address at which that person or entity may be contacted;
- Make a record of the name and telephone number of the customer or consumer who requests not to be called again and such record forward to (a) PICO and Associates, via the daily results file, (b) the party maintaining the vendor's do-not-call list and (c) affiliated entitles (where appropriate); and
- Place the consumer or customer's name and number on the do-not-call list of any affiliate of the telemarketer where the customer would reasonably expect to be included on such list given the identity of the telemarketer and the product or service being advertised.
