Screening means checking a phone number against the TPS and CTPS registers before you call it. Suppression means acting on the answer: flagging or holding back every number you must not call, so nobody dials it. A caller has three lists to respect, not two: TPS, CTPS, and its own list of people who told it to stop, and that third list is the one the registers cannot do for you.
Screening and suppression: two different jobs
The words get used interchangeably, but they describe two steps. Screening is the lookup: a number goes in, and a verdict comes out (on TPS, on CTPS, or on neither). Suppression is what you do with a listed verdict: the number is marked do-not-call in the system your team dials from, so it drops out of call lists and diallers.
A screen with no suppression step is a report nobody reads. A suppression step with no fresh screening goes stale, because people join the registers every day. I have set out how often the lookup needs repeating in how often should you check TPS.
The three lists every caller must respect
Regulation 21(1) of PECR is the rule for live marketing calls. It bars unsolicited direct marketing calls in two cases, set out side by side:
- (a) your own opt-outs: where "the called line is that of a subscriber who has previously notified the caller that such calls should not for the time being be made on that line".
- (b) the register: where the number "is one listed in the register kept under regulation 26". That register is run in two halves, TPS for individual subscribers and CTPS for corporate ones; the difference is covered in TPS vs CTPS.
So the three suppression lists are TPS, CTPS and your own do-not-call list. The registers are shared across every caller in the country. Your own list is private to you, because the notice in (a) is given to "the caller": someone who told a rival to stop has not told you.
| List | Who is on it | Where it comes from | 28-day grace? |
|---|---|---|---|
| TPS | Individual subscribers (consumers, sole traders, partnerships outside Scotland) | The regulation 26 register | Yes, regulation 21(3) |
| CTPS | Corporate subscribers (companies, LLPs, Scottish partnerships and other legal persons) | The regulation 26 register | Yes, regulation 21(3) |
| Your do-not-call list | Anyone who asked you to stop | Your own records | No |
Your own opt-out list outranks the registers
The 28-day grace period in regulation 21(3) only protects you against paragraph (1)(b), the register. There is no equivalent for (a). Once someone tells you to stop, the next marketing call to that line is a breach, whatever the register says and however recently they asked.
It also beats consent. Regulation 21(4) lets a registered subscriber tell a particular caller they do not object to its calls, which is how a TPS-listed number becomes callable. Regulation 21(5) says that notice can be withdrawn "at any time", and once it is, "the caller shall not make such calls on that line". So the order of precedence is: a stop request first, then a documented consent, then the register verdict.
Note the unit in both paragraphs: the line. An opt-out attaches to the number, so suppress the number, not just the contact record it arrived on. The same number often sits on two or three records in a CRM.
This is a plain-English summary of the regulations, not legal advice.
Other suppression files you will meet
Data suppliers and mailing houses run further suppression files that have nothing to do with phone calls but turn up in the same conversation. Two are worth knowing by name:
- Mailing Preference Service (MPS): run by the DMA, "a free and easy way to reduce unsolicited direct mail". It covers addressed post and does not touch phone numbers.
- The Bereavement Register: a free service by which "the names and addresses of the deceased are removed from mailing lists".
Neither replaces a TPS or CTPS check. If your campaign is calls, the regulation 21 lists are the ones that apply.
How long to keep an opt-out
PECR sets no retention period. Regulation 21(1)(a) speaks of a request that calls should not "for the time being" be made, which has no end date written into it. UK GDPR Article 21(3) is the matching data protection rule: where someone objects to direct marketing, "the personal data shall no longer be processed for such purposes". Neither text names a number of months.
My view: keep the opt-out for as long as you do any marketing that could reach that number. Keep only what the suppression needs (the number, the date, who asked and how), and do not use that record for anything else.
Suppression in a CRM: flag, do not delete
The instinct when someone says "take me off your list" is to delete the contact. I would not. A deleted record carries no memory of the request, so the next import from a data supplier, an event list or a colleague's spreadsheet puts the same number straight back into the call queue, clean and callable as far as the CRM can tell.
Flag it instead. A do-not-call property on the record, a suppression list keyed on the number, or both, means a re-imported duplicate is caught on arrival. If the person also asks for their data to be erased, keep the bare number on a suppression list and remove the rest.
How TPSClear handles suppression
Each account in TPSClear has its own suppression list next to the register check. Every number is checked against that list first, before any TPS or CTPS lookup.
- In HubSpot: every mapped phone field gets its own result property (
tps_statusfor the main phone,mobilephone_tps_statusfor the mobile, and so on) with a matching checked-at date. A suppressed number reads Do not call (opt-out) on that field whatever the register says, and the opt-out wins over a consent on the same number. The record card has a Suppress number action for the moment someone asks you to stop: it puts the number on the account's list, so every record carrying that number is blocked, and an optional note records who asked and when. - Through the API:
/v1/suppressionstakes up to 10,000 numbers per request, as JSON or as a CSV of number, reason and date. A number on the list comes back from/v1/screenwith the statussuppressed. The details are on the developers page.
Suppressed numbers are not sent for a register lookup, so they are not charged and do not count towards a plan allowance. If the list cannot be read, the API request fails with an error rather than screening the batch without it. A HubSpot portal and an API account that are linked share one list, and every add or removal is logged. The register side of the check is described on how it works; what a check costs is in TPS screening cost, and the size of each register in the TPS register in numbers.
Summary
Screening is the TPS and CTPS lookup and suppression is acting on it; respect three lists (TPS, CTPS and your own opt-outs), let a stop request beat both consent and the register with no 28-day grace, keep it on the number for as long as you market, and flag rather than delete.