{
  "id": "OPS-107",
  "slug": "ops-107",
  "title": "Staff have to be trained on the internal list, and it has to be evidenced",
  "statement": "Personnel must be trained in the existence and use of the internal do-not-call list, and the training records retained.",
  "rationale": "The internal list only works if the people who receive the requests know it exists and where to put them, and the training record is what turns a policy into something the brand can show it operates. In an enforcement action the absence of records is treated as the absence of training, whatever actually happened.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "training records",
  "severity": "MEDIUM",
  "detectability": [
    "HUMAN"
  ],
  "failureClass": "TERMINAL_EVIDENCE",
  "authorities": [
    "FCC"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Train everyone who takes customer contact on how to record a do-not-call request, and keep a dated record of who was trained and when. Done when you can produce the roster for any date in the last five years.",
  "notes": "Records inside the brand that we never see. What the user has to do is keep them for the same period as the suppression records themselves — five years — because the two are asked for together.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Could you produce the training roster for any date in the last five years?",
    "howToCheck": [
      "Train everyone who takes customer contact on how to record a do-not-call request.",
      "Keep a dated record of who was trained and when, for five years — the same period as the suppression records, because the two are asked for together."
    ],
    "failureLooksLike": "In an enforcement action the absence of records is treated as the absence of training, whatever actually happened."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-107/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-107.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}