A call centre is where TPS compliance either works or fails, because it is where the dial happens. The law is short: PECR's rule on live marketing calls (regulation 21) bars unsolicited marketing calls to numbers on the TPS, the register for individual subscribers, and the CTPS, the register for corporate subscribers. Everything else is operations. This checklist is the operational side, in the order a campaign runs: before the list is loaded, while agents are dialling, and after the call. The legal background is on the compliance page; the operating model for outbound floors is in TPS screening for call centres.

Before the list is loaded

  1. Use a licensed data source for the registers. The TPS and CTPS files are supplied under licence from the DMA, which operates both registers. Screen through a licensed list cleaner or a service that holds the licence, and keep a copy of the licence documentation with your supplier contract. A verdict from an unlicensed copy of the register is a verdict you cannot stand behind.
  2. Screen before the dial, not only overnight. A nightly batch screens the list as it stood at 02:00. New records imported at 09:30 and numbers edited at 11:00 are not on it, and those are the records agents dial first. Screen each number when it enters the system and again when it changes, and let the nightly run be a backstop rather than the control.
  3. Check the CTPS on every business number, and the TPS as well. A B2B campaign that screens only against the CTPS walks past sole traders, who are individual subscribers and sit on the TPS. A campaign that screens only against the TPS misses every limited company on the CTPS. Check both registers on every number, whatever the campaign type.
  4. Apply the 28-day rule per list. The industry standard, set by the DMA, is that screening data is no more than 28 days old when you rely on it. A list screened on the 3rd must be screened again before the 31st, and a list loaded on the 20th runs on its own clock. Build the re-screen into the list, not into the calendar. The two 28-day rules are set out in the 28-day rule explained.
  5. Hold an in-house do-not-call list and apply it first. A person who has asked your organisation to stop calling is off limits whether or not they are on the TPS. Keep the list in the dialler's path, not in a spreadsheet, and apply it before any register check so that an opt-out can never be overridden by a clear TPS verdict.
  6. Keep consent records that would survive a question. A TPS-listed number may be called only where that subscriber has told your organisation they are happy to receive marketing calls. There is no soft opt-in for live calls, so an existing customer relationship on its own is not consent. For each number dialled on consent, hold the date, the wording the person agreed to, and the channel. If a record has no consent reference, treat it as unsolicited and screen it.

While agents are dialling

  1. Make the dialler read the verdict. A verdict that sits in a CRM field the dialler ignores is decoration. The dialler should refuse, or skip, any record whose latest verdict is TPS-listed, CTPS-listed, unchecked, or older than 28 days. If the dialler cannot read a field, filter the dial list on the verdict before it is loaded and log who built the filter.
  2. Give agents a script line for "I am on the TPS". An agent who hears this needs one sentence and one action. The sentence: "I am sorry, I will make sure we do not call this number again." The action: end the call, add the number to the do-not-call list, and flag the record for a same-day check of why it was dialled. Arguing that the number screened clear this morning is the wrong response, even when it is true.
  3. Treat every stop request as an opt-out, in any wording. "Take me off your list", "do not ring here again" and "I am not interested, stop calling" all count. Agents should not be judging which phrasing qualifies. Record the request against the number, with the date and the agent, before the next call is placed.

After the call

  1. Run complaint handling as a process with an owner. A complaint can arrive by phone, by email, through the client, or through the ICO. Name one person who receives all of them, log the date received, the number, the campaign and the outcome, and reply within a stated number of working days. Pull the screening log for the number on the day it arrives, while the record is still to hand.
  2. Keep the screening log, and keep it long enough. For every number dialled the log should hold the number, the TPS verdict, the CTPS verdict, the date and time of the check, the data source, and the campaign or client it was dialled for. Decide a retention period, write it down, and apply it. The log is the evidence that you took reasonable steps before the call; without it, the ICO has only your word.
  3. Train agents and supervisors, and keep the attendance record. The training covers what the two registers are, what a verdict means, the script line in item 8, and what to do with a stop request. Run it at induction and again when the process changes, and keep the sign-in sheet. The penalty for a breach of the calling rules is up to £17.5 million, or 4% of worldwide turnover for an undertaking, for conduct from 5 February 2026, and once a company has been fined, a director or manager can be fined personally where the breach happened with their consent, connivance or neglect. Training evidence is what separates a failure from neglect.

How to use this list

Take the twelve items into a meeting with the people who own the dialler, the CRM and the floor, and mark each one as done, partly done, or not done. Partly done is the common answer for items 2, 4 and 7, because most operations screen in batch and trust the calendar. Those three are also the items that a complaint investigation lands on, because the question is always whether the specific number was screened close enough to the specific call.

The items that need tooling (2, 4, 7 and 11) are the ones TPSClear covers: every number screened when it enters the CRM or changes, re-screened on a 27-day cycle, with the verdict and timestamp on the record where the dialler can read them. Voll Studios Ltd, the company behind TPSClear, is licensed by the DMA as a TPS and CTPS list cleaner, and register data is supplied through our licensed data partners. The items that need people (5, 8, 9, 10 and 12) are yours, and no tool replaces them.

What to do next

Score the floor against the twelve items this week, and fix item 7 first: a dialler that reads the verdict closes most of the gap on its own. If you dial for more than one client, TPS compliance for agencies with several clients covers how to keep each client's data, consent and suppression list apart. The wider legal picture, including the consent exception and what the ICO fines, is in the complete guide to TPS compliance.