Here is a brief summary of how the DNCL operates and is used from the point of view of a telemarketer.
Registration is free. You are supposed to register, even if you are exempt (see the rule). Note that it says you should register even if you are making exempt calls. That includes making business to business calls or using permission based marketing.
The CRTC is fining unregistered businesses simply for not being registered if they are caught telemarketing. The only reason for a business not to register is if they never use the telephone to solicit sales. Anyone who is not registered and slips up by accidentally making a call to someone who complains could end up in very serious trouble. It costs nothing to register, so why not do it?
If you make calls to consumers to solicit sales and you are not an exempt organisation involved in an exempt activity (eg. a charity soliciting donations, a newspaper soliciting subscriptions, a politician or political party looking for votes) then you MUST register.
Download subscriptions are costly, but you can take a subscription for online enquiries that will cost only 75 cents per number you check. If you expect to make more than 200 enquiries in a month then a download subscription is a better solution. A download subscription will probably be easier to administer, so you may decide it is a better solution for less than 200 numbers per month.
If you call consumers for any reason, even if you are not promoting your business, and even if you are an exempt organistion involved in an exempt activity, you MUST have an internal do not call list. Anyone, at any time, can ask to be added to this list. You may not be talking with them on the phone, but you still have to put them on the list. You must also use the entries on your internal do not call list and ensure that you do not place calls to them while they are current. Your internal do not call list has an even higher priority than the national do not call list. A recent enquiry or current business relationship can override the national do not call list, but cannot override your internal do not call list. Entries on your internal do not call list remain current for the same length of time as entries on the national do not call list.
Perhaps you have a distributed operation, for example a Real Estate business where many of your people work from home. If any of them is asked to put a number on the internal do not call list then everyone in your business is required to not call that number. Because your people represent the business, the business is bound to not call the number.
There are other rules governing telemarketing activities such as
The CRTC tracks all the downloading activity on your subscription. They will know what you downloaded and when. This means that the numbers you check are only good for 30 days from when you downloaded the list you used for checking. If you downloaded on Monday, and checked a number on Friday, then you have until 30 days from Monday, not Friday, to use that number. If it was added to the DNCL on Wednesday and you called it 29 days after Friday then you would be calling it more than 30 days after it was added to the DNCL. If the consumer complained about your call you would be in the soup.
You cannot use someone else's subscription to safely check a number. If your call resulted in a complaint, perhaps because of a dialing error, or because the list was older than you thought, or just because the consumer complained when they should not have, you could be in trouble. If you could not prove you had a subscription then you would be in trouble. If you had not downloaded your subscription in the last 30 days then you would be in trouble.
If you use the pay as you go method then you have to prepay for 100 numbers. This will cost you $75 at 75 cents per number. Every time you check a number, regardless of whether or not it is on the list, your prepaid balance will be reduced. When your balance reaches zero you will have to buy more.
If you use the download method you have to use your download to check numbers. The download will be compressed, so the first thing to do is uncompress it. The download will be in either CSV or XML format. The CSV format has a separate file for each area code. You can easily check 7 digit phone numbers against the appropriate CSV file using basic utility software. The XML format is structured and has area codes embedded in headers in the data. If your subscription involves more than one area code you will need special software to check numbers.
Give some thought to how you are going to check numbers against your internal do not call list. Also think about how you are going to prove that you are using your internal do not call list.