Compliance Resource
The Do Not Call Registry and Following Up on Calls
An inbound enquiry does not automatically license outbound marketing. This guide explains the general position on Singapore’s Do Not Call provisions and how to keep follow-up on the right side of the line.
The general position
The Do Not Call provisions of the Personal Data Protection Act cover marketing messages sent to Singapore telephone numbers. Individuals can register their numbers, and organisations are generally expected to check the relevant register before sending a marketing message, unless they hold clear and unambiguous consent from that individual.
The registers cover voice calls, text messages and faxes separately, so a number may be listed on one and not another. There are exemptions, but they are narrower than most businesses assume, and they do not apply uniformly across the three channels.
Rules and validity periods change, so treat this page as an orientation rather than an authority. Check the current requirements published by the Personal Data Protection Commission and confirm your obligations with your own advisers before running any outbound follow-up programme.
Where the line usually falls
The distinction that matters is between completing the thing the caller asked for and promoting something they did not. The examples below illustrate the difference; how they apply to your business is for your advisers to confirm.
| Follow-up | Nature | Consideration |
|---|---|---|
| Returning a callback the caller requested | Service | The caller asked to be contacted about this specific matter |
| Confirming or reminding about a booked appointment | Service | Directly related to a transaction the caller initiated |
| Sending the quotation the caller asked for | Service | Fulfilling the request made on the call |
| Chasing an enquiry that went quiet weeks later | Borderline | Depends on what the caller asked for and what you told them |
| Promoting a different service to a past caller | Marketing | Register checks and consent requirements come into play |
| Adding callers to a broadcast list | Marketing | Requires a considered consent and preference position |
An AI receptionist captures contact details efficiently, which makes it easy to build a marketing list without ever deciding to. Decide deliberately what the captured numbers may be used for, and record that decision.
Practical points to settle
Consent, if you rely on it
Consent for marketing is expected to be clear and unambiguous, and evidenced. A caller agreeing to a booking has not agreed to a promotional campaign, and treating the two as equivalent is the most common error.
Register checks
Where you rely on a register check rather than consent, the confirmation is valid only for a limited period and applies to the specific register. Confirm the current duration with the Commission before building a process around it.
Channel by channel
Voice, text and fax are treated separately, and exemptions that exist for one channel may not exist for another. Do not assume that a permitted message may be sent by any means.
Message content rules
Marketing messages are expected to identify the sender and provide contact details. Build that into your templates rather than leaving it to whoever sends the message.
Opt-out handling
A caller who says they do not want marketing should have that recorded immediately and reflected wherever your lists live. Test that the preference actually propagates.
Record keeping
Keep evidence of consent or of the register check for each number you contact. If you cannot produce it later, you are relying on memory rather than a process.
Designing the call so follow-up is clean
Most of the difficulty disappears if the call itself establishes what the caller expects. Ask the receptionist to confirm the specific follow-up the caller wants, and to capture any marketing preference separately and explicitly.
- The caller states what they want to be contacted about, and it is recorded
- Marketing preference, where you ask for it, is a separate question with a plain answer
- Consent language is not bundled into a booking confirmation
- Records distinguish service follow-up from marketing permission
- Objections are captured verbatim and routed to a person
- Every list your team can send from reads the same preference field
- Templates identify your business and give a contact route
- Evidence of consent or register checks is retrievable per number
Do not let an automated system make the consent ask harder to evidence. If you rely on spoken consent captured during a call, agree with your advisers in advance what the record must show, then test that the flow actually produces it. Deciding after the campaign has run is the wrong order.
Frequently asked questions
Can we call back someone who rang us?
Returning a callback the caller asked for is service, not marketing. The position changes when the purpose of the call shifts to promoting something they did not ask about.
Does an appointment reminder count as marketing?
A reminder about a booking the customer made is generally transactional. Adding promotional content to that reminder is where businesses commonly blur the line.
We have an ongoing relationship with the customer. Is that enough?
Exemptions of that kind are narrower than many businesses expect and do not apply identically across voice, text and fax. Confirm the current scope with your advisers rather than assuming it covers phone calls.
How long is a register check valid?
For a limited period only, and the duration has changed over time. Check the current figure published by the Personal Data Protection Commission and build the process around that rather than a remembered number.
Does this apply to overseas numbers?
The Singapore provisions concern Singapore telephone numbers. Contacting numbers elsewhere brings other jurisdictions’ rules into play, which is again a question for your advisers.
Can the AI receptionist ask for marketing consent?
It can ask a clear, separate question and record the answer. Whether that satisfies the evidential standard for your purposes should be settled before you rely on it, alongside the wording covered in consent and call notifications.
Related reading
More guidance on call data and follow-up is in the resources library.
Separate service follow-up from marketing at the design stage
We will show how the call flow records what a caller has actually agreed to, so your team is not reconstructing it from a transcript months later.