The Do Not Call (DNC) registry provisions under the Personal Data Protection Act 2012 (PDPA) generally prohibits organisations from sending certain marketing messages (in the form of voice calls, text or fax messages) to Singapore telephone numbers, including mobile, fixed-line, residential and business numbers, registered with the registry.

Such marketing messages generally have one or more of the following purposes:

• Offer to supply, advertise or promote goods or services;
• Advertise/promote suppliers or prospective suppliers of goods or services; or
• Supply/advertise/promote land, interests in land or business/investment opportunities.

Whether your organisation is directly sending such marketing messages or authorising another organisation to do so, your organisation has to ensure that such messages are not sent to Singapore telephone numbers registered with the DNC registry.

The DNC registry, however, does not cover messages sent for other purposes, such as service calls or reminder messages sent by organisations to render services bought by the individual. Messages for pure market survey or research and those that promote charitable or religious causes are also not covered under the DNC registry rules. Telemarketing calls or messages of a commercial nature that target businesses are also excluded from the DNC registry rules. For the list of messages that are excluded under the PDPA, please refer to the Eighth Schedule of the PDPA.

There are three DNC Registers for:

• Voice message;
• Text message, including Short Messaging Service (SMS) and Multimedia Messaging Service (MMS); and
• Fax message.

Under the PDPA, your organisation will need to check the relevant register(s) before sending your marketing messages. To give organisations sufficient time to familiarise themselves with the rules of the PDPA, the prescribed duration for organisations to send messages after checking with the DNC registry will be every 60 days for the first six months of the DNC registry’s operations, and every 30 days thereafter.

Organisations sending marketing messages to Singapore telephone numbers will need to:

• Check with the DNC registry, unless you have the recipients’ clear and unambiguous consent in written or other accessible form for sending the marketing message to the Singapore telephone number.
  
  To check, your organisation should send in a list of the telephone numbers that you are planning to send the messages to. The DNC registry will then indicate on the list, whether each number is in each of the Registers. The organisation may then send its marketing messages to the numbers that are not in the relevant Registers. Your organisation may rely on the information given by the DNC registry on whether any number is registered on any of the Registers for up to 30 days (60 days for the first six months of the DNC registry’s operations). If your organisation intends to send the marketing message after the 30 days has lapsed, it must submit its list of numbers to the DNC registry again.  
• If your organisation is sending a text or fax message, include clear and accurate information identifying your organisation as well as contact details within the message. This allows the recipient to contact you for clarifications, if necessary.
• If your organisation is making a voice call, ensure that the calling identity, or phone number from which the message is sent out from, is not concealed.

To allow time for organisations to review and adopt internal personal data protection policies and practices and comply with the PDPA, provisions relating to the DNC registry will come into force in early 2014. Details of the DNC registry subscription, fees and the process of filtering will be published at a later date.