Defining TCPA:

The Telephone Consumer Protection Act protects customers from unregulated and harassing calls.

As a regulated financial service provider (FCA), a UK company, and due to our specific legal framework, we must follow certain rules & regulations when it comes to communicating with customers and/or 3rd parties. 

Prodigy Finance Limited and its subsidiaries must abide by the US Telephone Consumer Protection Act by removing US telephone numbers where a customer or owner of the phone number has revoked consent to contact said number. 

This only applies to phone numbers for customers with a US CURE address. The SOP will guide the teams on how to handle customer requests to revoke consent via call, email, and messenger. 

1. Revoke consent steps:
2. How to identify a customer who revoked consent:
3. Re-authorization of consent on telephone number:
4. Violation:

Revoke consent steps:

A customer with a US CURE address can revoke consent verbally and/or in writing, and we would need to adhere to this. We would no longer be able to call or send SMS text messages to this number, and therefore, we would need to add a tag to the customer's profile on Unitas. However, we are still able to communicate with the customer via email. 

It is important to tag customers who have revoked their consent to be contacted. If a customer revokes consent, the below steps are to be followed:

1. Open the customer’s profile on Unitas 
2. Click the personal information tab
3. Add the appropriate tag (image below)
4. Save changes and confirm with the customer via email that we will no longer be contacting them on the requested number. 

How to identify a customer who revoked consent:

A customer who has revoked consent for contact will have the “Do not call” tag on UNITAS. When reviewing the timezone before making a call, agents must also review the tags on UNITAS before making contact. 

Re-authorization of consent on telephone number:

Re-enabling contact via phone or SMS when a change to CURE or the customer reauthorises consent. Customers can provide us with reauthorization of consent either verbally or in writing where the US or non-US number can be called or SMS text as per normal process. We would then be required to remove the tag from the customer's profile on Unitas. 

If that customer moves outside of the US we can call that number as the TCPA law will no longer apply.

Violation:

A verbal or in writing- violations of the telephone consumer protection act can result in fines of USD 500 - USD 1500 per call or text message.