Rules and best practices for outbound voice

This article outlines the rules and best practices for placing outbound calls with your Avaya.cx account. The purpose of these rules and best practices is to mitigate SPAM and consumer fraud calls.

Rules

General rules

• Do not create traffic that violates FCC, FTC, or any other applicable US federal rules and regulations.

• Do not create traffic sent with the intent to steal or harm.

• Do not create unlawful robocalls (North America)

• Do not make phone calls to numbers on the US National Do Not Call Registry.

• Do not engage in any of the following activities:

  • • Traffic Pumping

    • Domestic Toll Fraud

    • International Toll Fraud

    • International Revenue Share Fraud

    • Phishing scams (e.g. impersonating the IRS, SSA, etc.)

    • Outbound mass dialing

FTC telemarketing rules

The FTC has laid out the following federal rules related to telemarketing that you must follow. Note that there are also state regulations for telemarketing that should be taken into account.

• You cannot call before 8 a.m. or after 9 p.m. in the recipient’s local time zone.

• You cannot deliver artificial voice calls or recordings to residences without written consent.

• You cannot use autodialers, recordings, or simulated voices to make calls to mobile phones or other recipients where the recipient pays for the call.

• You cannot make false or misleading statements to induce anyone to pay for goods or services or make a charitable contribution.

• You cannot call a person whose number is on the National Do Not Call Registry or who has asked not to get telemarketing calls from a particular company or charity.

Best practices

Implement customer opt-in to unrequested calls

We suggest implementing a process for customers to opt into sales, marketing, or otherwise unrequested calls.

Include any CSAT surveys in the same call

When sending a customer a CSAT survey, we suggest that the CSAT is part of the same call as the survey is evaluating.

Take ownership of interactions before placing outbound calls

The system is designed for queue users to explicitly claim interactions before placing outbound calls. The FCC doesn’t permit the use of auto dialers, so all interactions in Edify must be formally claimed by an individual before outbound calls can be made.

For example, if your organization has a list of leads (or a list of customers who have opted into receiving phone calls), the list can be imported into your Avaya.cx account. Then, a queue user can manually accept the interaction to initiate the outbound phone call.

Avoid short-duration calls

Phone calls of a short duration (less than 15 seconds) raise flags on most service provider networks. We suggest limiting the use of short-duration calls as they may lead to call blocking per FCC guidelines.

FAQ

Who do the Telemarketing Rules apply to?

Telemarketing is the marketing of goods or service by means of telephone calls to unsolicited individuals. It is suggested that all businesses placing outbound calls to consumers follow the rules as outlined by the FTC. 

For more information, see: FTC - Complying with the Telemarketing Sales Rule (web page)

What is SHAKEN/STIR?

SHAKEN (Signature-based Handling of Asserted information) and STIR (Secure Telephone Identity Revision) are protocols for digitally validating the handoff of phone calls passing through phone networks. This allows phone companies to verify that a call is actually from the number displayed on the Caller ID.

For more information, see: FCC - Combating Spoofed Robocalls with Caller ID Authentication (web page).

What is Spoofing?

Spoofing is when a caller deliberately falsifies the information transmitted to the caller ID display to disguise their identity.

For more information, see: FCC - Caller ID Spoofing (web page).

What is a Robocall?

A robocall is an automated telephone call that delivers a recorded message. Examples of unlawful robocalls include:

• Calls made with invalid ANI/FROM telephone numbers

• Calls with unallocated ANI/FROM telephone numbers

• Calls with blank or alpha-numeric characters in ANI/FROM telephone numbers

• Calls by telephone numbers on the Do Not Originate (DNO) list.

For more information, see: FTC - Robocalls (web page)

What is the Do Not Call Registry?

The Do Not Call Registry (https://www.donotcall.gov/) is a federal registry maintained by the Federal Trade Commission (FTC). It is a list that tells telemarketers what numbers not to call.

The Do Not Call Registry covers personal phone numbers. It does not cover business phone numbers or fax lines.

Companies that illegally call numbers of the Do Not Call Registry (or place an illegal robocall) can be fined up to $43,792 per call (as of August 2023).

For more information, see: FTC - National Do Not Call Registry FAQs (web page)

Unlawful calls

Unlawful calls (as defined by the FCC) are not permitted.

Resource: FCC - Advanced Methods to Target and Eliminate Unlawful Robocalls (PDF)

• UNALLOCATED

  • A valid NPA NXX XXXX in the North American Numbering Plan (NANP) that’s not been assigned to a carrier, nor is it in the Local Exchange Routing Guide (LERG).

  • Any call that contains a phone number in the ANI/From field that’s not yet been released for public consumption from the NANP.

• INVALID NUMBER

  • A complete telephone number that is not valid (not the correct format)

  • Correct format: [2-9][0-9][0-9] [2-9][0-9][0-9] [0-9][0-9][0-9][0-9]

    • 10 digits in length. The first and fourth digits are [2-9]. The rest are [0-9].

• INVALID DIGITS

  • The calling party’s number is numeric, but it doesn’t comply with the format described above under INVALID NUMBER (e.g. all 1’s, all 0’s, etc.).

• INVALID ALPHA-NUMERICS

  • Invalid alphanumeric strings used to misdirect, impersonate, disguise, or deceive SIP signaling.

• Specific number patterns

  • 8YY

  • N11, like:

    • 911

    • 411

    • etc.

  • 555

• ALPHA

  • The calling party number has “alpha” characters that are random or the word ANONYMOUS in it.

• EMPTY

  • There’s no calling party number present

We recommend you make sure that your calling traffic contains valid telephone numbers in the ANI/FROM fields. We also recommend that calls from your network (or from your customer’s) never have ANI/FROM phone numbers that fall into the categories listed above.

Note: Calls made for lead generation are outside of best practices and not approved use cases under the TCPA (PDF).