Registered firms ask two questions that other buyers don’t: where does the data come from, and what do we have to do before we dial it? This guide answers the second. It is practical, not legal advice — your compliance officer has the final word — but it is what we tell every SEBI-registered firm that buys from us.
1. Scrub against DND before every campaign
The National Customer Preference Register (the DND registry) is checked by every serious floor before dialling, whatever the source of the numbers. Use your telecom operator’s scrubbing service or a registered scrubbing provider, keep the scrubbed file and the scrub date, and re-scrub any batch older than a few weeks. Treat the scrub as part of receiving the data, not as an afterthought. We recommend it to every registered firm, and we would rather you scrubbed our data than dialled it raw.
2. Ask the sourcing question — and record the answer
Before you pay, get the supplier to say where the numbers come from. The acceptable answers are specific: broker tie-ups, the supplier’s own advertising campaigns, search traffic to the supplier’s own sites, opt-in channels. Record the answer with the invoice. Ours is on the advisory firms page and we will repeat it to your compliance officer on a call.
3. Keep a record of what you bought and when
File per batch: supplier, date, segment, state, format, the replacement terms, the scrub date. When a complaint or an audit comes, the firm that can show the chain — bought here, scrubbed then, dialled in these hours, disposition recorded — is in a different position from the firm that can’t.
4. Dial in sensible hours and say who you are
Calling hours, a clear identification of the firm and the registration, no promises of returns, no pressure to decide on the call. These are your obligations as a registered firm regardless of where the data came from, and they also happen to lift the follow-up ratio. The floors with the best ratios on our own grading are the ones that sound like a registered firm.
5. Match the segment to the product you are registered to sell
A research analyst selling an options package should be dialling F&O traders, not demat holders who have never traded a derivative. Beyond the ratio, it is the right audience for the product — and it is the first thing a compliance reviewer will look at.
6. Know what the supplier will and won’t do
Replacement terms in writing (ours: invalid, switched-off and wrong numbers within 15 working days; not-picking-up numbers are not replaced). We don’t run free samples, and we’d be wary of a supplier who does — sample files get resold. No printed record counts. No leads for offshore or unregulated platforms. A supplier who says these things out loud is a supplier you can name to a regulator without embarrassment.
A one-page checklist
- Sourcing answer recorded with the invoice
- DND scrub done and dated before the first call
- Batch record: supplier, date, segment, state, format, terms
- Calling hours and identification script agreed with compliance
- Segment matches the registered product
- Dispositions recorded per number, replacements claimed inside the window
If your compliance officer wants to hear the sourcing answer directly, that is a ten-minute call — ask for it. The traders database catalogue lists every segment and state we supply.