National Do Not Call Registry
Effective 10/01/2003, use of a National Do Not Call Registry established through the efforts of the Federal Trade Commission (FTC) and the Federal Communications Commission (FCC) is required and covers any plan, program, or campaign to sell goods or services through interstate or intrastate telephone calls. The Registry is a list of telephone numbers from consumers who have indicated their preference not to receive telephone solicitation calls. If an individual's telephone number appears on the National Do Not Call Registry, then the law prohibits telephone solicitation calls to the registered telephone number.
The provisions of this law do not impact companies with which a consumer has an established business relationship. Even if a consumer's telephone number is on the National Do Not Call Registry, if a company has an established business relationship with that consumer, then the company may place a telephone solicitation call to the registered number. For our purposes, an "established business relationship" is limited to the following:
| Active Policyholder – An active policyholder is considered to be anyone with individual or group coverage (including covered members of a group policy). |
| Lapses – A lapsed policyholder is considered to have had an established business relationship with the Company, but contact for solicitation purposes is limited to an 18-month period following the date of last payment. |
| Inquiries – This would include individuals who have made an inquiry or request for information or completed an application with the Company within the past three (3) months. |
Company-Specific Do Not Call List
Under the National Do Not Call provisions, an Internal Do Not Call List is required to be created and maintained. If a consumer specifically requests the Company not make future contact for solicitation purposes, then the Company is required to place the consumer's telephone number on the Company's Internal Do Not Call List and the Company may not contact the consumer again. This applies even if there is an established business relationship with the consumer.
COMPLIANCE:
To ensure compliance with the Do Not Call Provisions:
| • |
Those persons who make telephone solicitation calls on the Company’s behalf have been notified about and will continue to be updated regarding the Company’s procedures for compliance with the Do Not Call provisions, including the Company’s obligation to ensure that telephone numbers have been cross-referenced against the National list no more than thirty-one (31) days prior to the date any call is made. Notification has been made in the form of inter-Company correspondence, discussions at company meetings, and/or articles appearing in the Company’s monthly magazines. |
| • |
Those persons who make telephone solicitation calls on the Company’s behalf have been, and will continue to be, advised regarding their responsibility to continue to adhere to applicable State Do Not Call lists. |
| • |
The Company held training sessions for the Executive Office staff to explain the new law, the Company’s procedures regarding Do Not Call compliance, and how Do Not Call requests are to be handled. |
| • |
Instructions were given to all Officers and Managers requiring all new staff, who have customer contact, to be informed of the existence of the National Do Not Call list and the Internal Do Not Call list, and trained regarding the Do Not Call Procedures before having any contact with consumers. |
| • |
Quarterly notifications will be sent reminding all staff of the National and Internal Do Not Call lists, the Company’s procedure regarding Do Not Call compliance, and how Do Not Call requests are to be handled. |
| • |
The Company has properly registered with the FTC and purchased the National Do Not Call list. Randy Holmes, IT VP, is the contact person for obtaining, paying for, disseminating, and administrating the National Do Not Call list. |
| • |
After the initial pull, the Company’s IT department will download additions/deletions to the National list on a monthly basis from the FTC’s website. The additions/deletions will then be incorporated into the National Do Not Call database the Company keeps on the network server MKDB2 database NationalDNC. |
| • |
UAONLINE will be used to search the National and the Company’s Internal Do Not Call databases if one or two telephone numbers need to be looked up. All other telephone numbers (e.g., lead lists) will be submitted to the Home Office to be uploaded and cross-referenced, or scrubbed, against the National and the Company’s Internal Do Not Call lists. These telephone numbers will be processed and returned within seven (7) business days. Any telephone number found on the National or the Company’s Internal Do Not Call lists will be removed prior to being returned. Lists that have been scrubbed against the National and Company Do Not Call lists will be returned with an expiration date, after which time the list must be resubmitted to the Company to be scrubbed again. |
| • |
UAONLINE will not display telephone numbers on lapsed or inactive policies if the number is included on the National or the Company’s Internal Do Not Call lists. |
| • |
A notation will be added next to the telephone number of active policies on UAONLINE if the number is on the National or the Company’s Internal Do Not Call lists. |
The Company has established an Internal Do Not Call list to record the telephone numbers of consumers who request not to be called by the Company. All individuals having direct contact with consumers have been advised of the existence of the Company’s Internal list. These individuals have been further advised to record immediately and process any requests for additions to the list in the manner described below. The following information should be captured relative to any such request: Date of Request, Requestor’s Name, Telephone Number, and Policy Number (if applicable).
The Customer Service Department shall be responsible for recording and processing customer Do Not Call requests received by Home Office personnel. If such a request is made via e-mail, a Customer Service representative will add the applicable telephone number to the Internal list and reply to the e-mail with confirmation that the requested action has been taken.
First UA Agents may forward Do Not Call requests via e-mail to jsavo@torchmarkcorp.com.
The Company’s policy shall be to honor a consumer’s request within thirty (30) days, or sooner where possible. Company records of consumers requesting not to be called will be retained for a minimum of five (5) years.
|