RLCB Do-Not-Call /Tele-Services Compliance Procedures

Background:

RLCB, Inc. is a private nonprofit organization started in November 1966 with a mission to empower people who are blind and visually impaired through employment opportunities, providing products and services to achieve social and economic equality. 

RLCB, Inc. began providing Tele-services in 2000 through contracts with the Veterans Administration Medical facilities in Kentucky .  These contracts serve the need for onsite, inbound dedicated switchboard operations, 7 x 24, fully staffed and managed by visually impaired staff.

Today, adaptive technologies and communications technologies have matured to the point where employment for non sighted staff is possible anytime, anywhere. With the success of the existing switchboard contracts, expanded Tele-Services programs represent next generation employment opportunities for RLCB. Tele-services programs represent a critical means for RLCB, Inc to satisfy the mission of providing employment opportunities.

To take advantage of market opportunities, RLCB Tele-services department has developed marketing programs, implemented training processes, secured both adaptive and communications technologies positioning itself  to market and deliver inbound and outbound Tele-Services to a broad client base.  The Tele-services programs address organizations which outsource their market research efforts, want to ensure customer satisfaction, wish to augment their own customer acquisition programs; need to collect debt and or those needing to drive event attendance. 

Tele-services direct marketing, for both its own textile business units and its Tele-services clients, are critical elements to the RLCB business strategy to ensure consistent client growth. RLCB does not sell client products or services over the phone, rather informs potential buyers about the products and services of our clients.  It is our clients who conduct follow-on appointments for additional company information and product/service specific information.

RLCB, Inc values its client relationships and those of our clients.  We strive for the highest levels of satisfaction, business ethics and practices.  It is our goal to be the premier Contact Center for both our clients and for their clients.

A. Overview

In response to the Federal Communications Commission Report and Order Adopted on June 26, 2003 addressing the Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, RLCB, INC. has implemented and documented procedures for all Contact Center and Tele-services staff which demonstrate and ensure all efforts to fully comply with the national do-not-call rules have been taken.

B. Purpose

By adoption and utilization of documented compliance procedures, as well as all other necessary steps, RLCB, Inc. will benefit from the “safe harbor” provisions of the national do-not-call rules, and will therefore not be liable for violations of the rule which are the result of error.  The RLCB, Inc. Tele-services staff, its leadership, personnel, campaign management and IT staff has developed and maintains a code of conduct which meets or exceeds the required operational standards set forth by the FCC telemarketing Sales Rule (TSR) and North Carolinas telemarketing Law.

C. Required Procedures

All individuals, employees, and affiliates telemarketing on behalf of the company or individual listed above shall comply with the national do-not-call rules and additional office procedures listed below:

1. All agents, when making a solicitation call, shall comply with the National do-not-call rules beginning October 1, 2003.

2. The National do-not-call list itself will be available at http://www.donotcall.gov/ Or http://www.ftc.gov/  All agents shall maintain a record listing the do-not-call numbers. Furthermore, all agents shall “scrub” (update) that record at least once every month.

3. Agents shall check the record before making any solicitation call.

4. Agents shall not call any telephone number contained on the record, unless they fit within one of the exceptions listed below. This applies to all calls, including those within and outside of Utah .

5. Agents may call any telephone number not listed on the record, but if the individual called asks to be placed on the “company” do-not-call list, agents shall honor their request, place their number on the record, and refrain from calling them in the future.

6. Agents shall allow the phone to ring for 15 seconds or four rings before disconnecting any unanswered call.

7. Agents shall transmit caller ID information for each call and shall not block the caller ID information.

8. Agents shall obtain express written permission before sending faxed advertisements.

9. Agents may call individuals whose number is recorded on the list if the agent has an “established business relationship” with them. The “established business relationship” exception allows agents to contact any client with whom they are currently conducting business, and extends for a period of 18 months from the consummation of their last transaction. It also allows agents to contact those who have made an application or “inquiry” with them for a period of 3 months following their inquiry.

10. The established business relationship exception extends to all affiliated companies, employees or agents of the company if they are offering a service related to the type of service the company originally rendered.

11. Agents may call individuals whose number is recorded on the list if that agent has received explicit written permission to do so. The written permission shall be signed, and shall include the telephone number to which calls may be placed.

12. Agents may call individuals with whom they have a “personal relationship,” which means those “personally known” to them such as family members, friends, and acquaintances. Note: in the case of a referral, it is not sufficient that the individual referred have a relationship with the referring source; the exception only applies to the marketer individually and his or her personal relationships.

13. If agents call anyone under one of these exceptions, and the recipient of the call asks to be placed on the company do-not-call list, then that agent shall honor their request, place the number on the company do-not-call list, and refrain from calling them in the future.

14. Agents shall read the national do-not-call rules once each year.

15. Agents shall comply with all sections and requirements contained in the national do-not-call rules, including those not listed in these procedures.

16. Agents shall participate in training on these procedures and the national do-not-call rules when offered by the company.

17. Agents shall make a good faith effort to comply with the national do-not-call rules at all times.