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CRTC, call center, contact center, customer service, telemarketing, Canadian Radio-television and Telecommunications Commission

Call Tracker

Inverhuron Business Information
Services Inc

call compliance, do not call rules, telelisting, marketel, computer, program, software, Canadian, do not call list, registry, phone, telephone,
telemarket, mortgage, broker, real estate, realty, realtor, comply, compliance, scrub, scrubber

Basics of Compliance

Most SMB in Canada do not telemarket in any concerted manner. However a large percentage will at some time or on a regular basis place telephone calls to consumers about their products. Any of these calls could result in a compliance issue.

The Main Issues

  1. How do we avoid calling a number on the National Do Not Call List?
  2. How do we maintain an internal company Do Not Call List?
  3. How do we circulate Do Not Call List information to everyone in the company?
  4. How do we make sure our employees use both the National Do Not Call List and our internal Do Not Call List?
  5. How do we prove due diligence if we are investigated for a violation?


It costs nothing to register, so why not do it? Besides, you are supposed to, even if you are exempt (see Telecommunications Rules part III item 1).


Download subscriptions are costly, but you can take a subscription for online enquiries that will cost a small fee per number you check. The break even on this is checking about 250 numbers per month: about a dozen a day. Fewer than that and you might as well pay per number you check.

If you expect to make more than 200 enquiries in a month then a download subscription is probably a better solution than the online, pay as you go method. A download subscription should be easier to administer, so you may decide it is a better solution even for less than 200 numbers per month. Typically, having just one person in your office spending a few hours a week cold calling could put you into the area where a download subscription is the best value proposition.

Maintaining a Company Do Not Call List

This could be as simple as a notebook with a list of numbers.

If you get many requests to be added to the company Do Not Call List then such a simple solution will soon become unworkable. Keeping a list on a computer is a better idea, but for best results you will have to combine it with the National Do Not Call List. That means keeping it in the same format and merging it with each National Do Not Call List download or doing separate checks for each number you want to call using both lists. The process will be more complicated when you are dealing with multiple area codes. Distributing the internal Do Not Call data involves all of the same issues as distributing the National Do Not Call List download.

A good list scrubber will allow for separate feeds of internal Do Not Call and National Do Not Call data.

Ensuring People Use the Lists

Apart from making the lists available and easy to use, could we suggest training? You could then get each employee to sign a document acknowledging they have been trained and accepting specific responsibility for using the lists as instructed.

Due Diligence

Due diligence consists of a number of parts:

  • Staff training
  • Downloading the list
  • Keeping an internal list
  • Making the lists available for use
  • Using the lists
  • Keeping records of your registration, subscriptions, payments and telemarketing activity
Downloads are something the National Do Not Call List operator should record, but it is wise to have your own records as well. The rest can all be done with forms, procedures, office records and manual notes.

Call Tracker will not train your staff, but it will:

  • take regular downloads of your subscription to prove due diligence to the National Do Not Call List operator as a matter of record
  • maintain your internal Do Not Call List with date stamped entries
  • ensure all your staff have the most recent data available for their use
  • keep time stamped records of all activity that can be searched by phone number, employee or date in case of investigation

We think Call Tracker covers every point of due diligence as thoroughly as possible. If you think we could do something better, please tell us.

Using the Download

You need to take your download at least every 30 days during your subscription period to show due diligence.

The list will come in a compressed file that will need to be unzipped. Software is readily available for this purpose. You likely have this software on your computer already, but if not you can get it free off the internet. For commercial use there may be a small license fee to pay. One such option is to use IZArc.

Once the file is unzipped you can use Windows Notepad to look up numbers. Spreadsheet programs do not have enough capacity to cope with most area codes of the National Do Not Call List. Browsers and most word processors are slow to load the list. If you use Notepad, then make sure you search both UP and DOWN the file for every number. If you handle multiple area codes then you will need to look at the right data. This can get tricky with the XML format download, and will require changing files with the CSV format download unless you combine them into one large file that could easily become too large for convenient use. You must update every copy of the National Do Not Call List on every computer used by your employees at least every 30 days, and it will be important to keep detailed records of doing so in case you are investigated.

You can employ a telemarketing organisation to make calls for you. Telemarketers are required to verify your subscription before providing you with services. Even if the telemarketing organisation is outside of Canada you still must have a subscription and your telemarketer must comply with the regulations. You will also have to give them a copy of your internal Do Not Call List. If they make mistakes, you could be held liable.

You can use a list scrubbing program. A list scrubber takes the list of numbers you want to call and compares it with the National Do Not Call List (and hopefully your internal Do Not Call List also) to segregate the numbers you must not call from those which are not on either the National Do Not Call List or your internal Do Not Call List. You will need a list scrubber that uses the National Do Not Call List format. You must also prepare your internal Do Not Call List in the same format.

You can employ a service such as Call Tracker that will

  • download your National Do Not Call List subscription for you
  • check each phone number you enquire about
  • maintain your internal Do Not Call List for you
  • record your activity in case you are investigated