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September 8th, 2021

How Florida Outbound Call Centers Can Thrive Under CS/SB 1120

Starting July 1, 2021, outbound call centers operating in the state of Florida must contend with a state-level equivalent of the Telephone Consumer Protection Act (TCPA): CS/SB 1120.[1] As with TCPA, organizations subject to Florida’s law now need prior express written consent from consumers before placing sales calls, text messages, or direct-to-voicemail transmissions. Each violation could incur up to $500 in damages. A judge may triple that penalty in cases of willful or knowing violations.

Florida’s new law puts outbound call centers on a tightrope. Either they must adjust operations to manage compliance, or they face penalties and class-action lawsuits. However, significant financial impact will follow overly cautious adjustments—such as manually dialing or erroneously eliminating good phone numbers. Organizations that fail to adapt their outbound communications strategy accept substantial risk without a potential upside.

Data decay hampers outbound call center compliance and operational efficiency

Outbound organizations operating in Florida must keep consumer contact information up-to-date and accurate in order to maintain a link between a consumer and his or her consent. This task challenges even the most sophisticated companies because 4.9 million people in Florida change their phone carriers, and 2.3 million change their phone numbers every year.[2] Between 5 and 15 percent of typical CRM records go out of date in a single month.

Compliance risk increases when contact files contain only partial information about phone numbers. When companies try to reach Floridians at incorrect or out-of-date phone numbers, they risk contacting the wrong consumer—a potential violation of CS/SB 1120. Missed connections become more frequent as a larger portion of a consumer file goes out-of-date.

The continuous and cumulative nature of Florida consumer data decay degrades operational efficiency, too. Almost half of outbound contact centers report higher operating costs due to challenges related to lack of contact data; over 40 percent report lost productivity.

Overly cautious workarounds to the new law can harm operating margins. Dialing numbers manually—to avoid the risk of an automatic dialer acting on incorrect data—slows down operations. Avoiding contact with some consumers—for fear of calling without prior consent—reduces revenue, efficiency, and profitability. Good phone numbers may be skipped or removed from contact files due to an inability to differentiate true disconnects from temporary suspends or reassigned numbers. Despite the intensifying impact on operational efficiency, the workarounds become increasingly necessary as the data in a file decays.

Conventional data sources offer little value to outbound call centers

Data from most third parties cannot resolve the above challenges. The type of customer intelligence that credit bureaus aggregate—consumers’ credit risk and behavior, as well as Know Your Customer identifiers, such as dates of birth and social security numbers—has no value for compliance with CS/SB 1120. Referencing third-party data sources can corroborate changes in consumer data. However, contradictions and blind spots that span across these sources make it very difficult for outbound organizations to establish the single source of truth necessary to operate effectively and in compliance.

Managing these risks requires resources and overhead, eroding operating margins and distracting from revenue-generating activity. However, non-compliance exposes brand reputation to risk. Legal experts believe[3] that CS/SB 1120 will spur “a tidal wave of lawsuits.” The most expansive cases will likely attract negative publicity, as has happened multiple times to defendants of class-action TCPA complaints. Outbound call centers in Florida must maintain the balance between competing priorities.

Better compliance and operations start with better data

Prospective compliance methods cannot sacrifice answer rates. A clearer picture of the compliance risk associated with dialing or texting a specific phone in Florida emerges from analyzing the relationship between the identity of the consumer and the following data elements:

  1. Has the phone number been reassigned to another consumer?
  2. Are there breaks in subscriber continuity that suggest the number has been reassigned?
  3. Does the subscriber name still belong to that number?
  4. Is the number associated with a wireless phone?
  5. Has the number been consistently active?
  6. Does the phone number frequently change hands from one pre-paid subscriber to another?
  7. Is the phone a Voice-over-Internet-Protocol (VoIP) number that could resolve to a mobile phone?

This approach, proven in many major call centers, hinges on keeping a complete, accurate, and persistent understanding of consumer identity. In addition to mitigating compliance risk, this can also increase operational efficiency via higher right-party-contact (RPC) rates. Roughly 85 percent of right-party contacts come from just 50 percent of calls. Focusing on the best phone numbers reduces cost, improves efficiency, and benefits consumers.

More effective compliance practices balance overall risk with operational efficiency. Cleansing disconnect data to remove as much of the noise as possible confirms that remaining phone numbers are still associated with consumers. Strategically limiting the number of phone numbers removed helps to focus dialing activities on numbers that are more likely to yield right-party contacts.

Few organizations can afford to develop and maintain the technology and processes required to keep a CRM current with changes in consumers’ information and consent—at scale. That’s unfortunate. There’s a substantial upside to the effort: mitigating data decay reduces compliance risk and allows agents to reach customers at the numbers more likely to be answered.

How Neustar helps outbound call centers to comply and thrive

With the increased penalties and complexity enacted by Florida’s new law, outbound dialing organizations must ensure that their operational practices and consumer data remain in compliance. Neustar Contact Compliance Risk has been helping outbound organizations to maintain that balance for years.

Neustar Contact Compliance Risk provides insights on whom to call or text and how to prioritize numbers for lowest risk and highest efficiency in call center operations. By leveraging unique relationships with telecom providers and powering over 90 percent of caller ID in the U.S., Neustar verifies in real time the linkages among a consumer's name, phone number, valid consent, and other attributes. With the most accurate phone intelligence in the industry, Neustar provides unique insight into the attributes of nearly any phone number. As verified changes to consumer data occur, Neustar proactively pushes updates directly to client databases in near real time.

For companies that make a substantial number of outbound calls to consumers, this is about more than keeping on the right side of Florida’s new law. It is also about getting the most out of operations, which play a crucial role in driving sales and fortifying the bottom line. The precision of Neustar data intelligence reduces risk and improves outbound dialing organizations’ RPC rates by as much as 19 percent. Better compliance and better operations start with better data.

Forward-thinking outbound contact centers are prepared to thrive under CS/SB 1120. Neustar Contact Compliance Risk allows these organizations to maximize outreach and efficient calling technologies while maintaining reliable compliance and avoiding potential fines. The result is a safer, more efficient and effective outbound call center operation.


[1] Contact Center Compliance, Florida Legislature Passes New, TCPA-like, State-Level Telemarketing Bill

[2] In 2021, an estimated 21.6 million people reside in Florida, 6.48% of the U.S. population. 6.48% of 75 million carrier changes and 35 million changed phone numbers across the U.S. (Source) are 4.9 million and 2.3 million, respectively.

[3] Law360, Fla. Robocall Law Could Bring New Wave Of Litigation

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