Staff have to be trained on the internal list, and it has to be evidenced

The requirementstatement

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

Severityseverity: MediumMEDIUMUsually survives review, but lowers your trust score or invites a manual look you would rather avoid.
When it bitesphase: After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
What is checkedobject: training records
Where it liveslayer: OperationalOPERATIONAL
How Ekas settles itdetectability: Human checkHUMAN; Only someone holding the document or making the call can settle it. Ekas tells you exactly what to look at.
What the fix involvesfailureClass: Supply evidenceTERMINAL_EVIDENCE; Needs proof only you hold: a screenshot, a recording, a scan of the form people signed.
Who requires itauthorities: FCC
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

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 itremediation

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 yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

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

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

Notesnotes

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.

Rules you will hit next

Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.

OPS-032A help request containing a stop-word is not an opt-outMediumMEDIUM OPS-042Somebody has to own revocations that arrive in conversationMediumMEDIUM OPS-050The opt-out confirmation is worth sending inside five minutesMediumMEDIUM OPS-051Only ask which messages to stop when there is more than one kindMediumMEDIUM OPS-057Log the sends you did not makeMediumMEDIUM OPS-062An opted-out consumer must be able to come backMediumMEDIUM

All operational rules

OPS-107 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.