# OPS-107 — Staff have to be trained on the internal list, and it has to be evidenced

> Personnel must be trained in the existence and use of the internal do-not-call list, and the training records retained.

- **Rule ID:** OPS-107
- **Layer:** Operational (`OPERATIONAL`)
- **Checks:** `training records`
- **Severity:** MEDIUM — Usually survives review, but lowers your trust score or invites manual review.
- **When it bites:** Falls due after approval, once you are live and sending
- **How it is detected:** Human check — only someone holding the document can settle it
- **Fix type:** Supply evidence only you hold
- **Required by:** FCC
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/operational/ops-107/

## Why this rule exists

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.

## How to fix it

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.

## Check this yourself

**Could you produce the training roster for any date in the last five years?**

1. Train everyone who takes customer contact on how to record a do-not-call request.
2. 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.

*What wrong looks like:* In an enforcement action the absence of records is treated as the absence of training, whatever actually happened.

## 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.