TCPA Compliance

Our Commitment

Keystone North takes Telephone Consumer Protection Act (TCPA) compliance seriously. Every outbound call and text we place on behalf of our clients meets or exceeds federal and state requirements. This page details our compliance framework.

1. Express Written Consent

TCPA requires "prior express written consent" before autodialed calls or texts to cell phones. We exceed this standard:

• • Explicit checkbox: Lead magnet (InsureCalc) requires checking "I consent to be contacted by Keystone North about agency growth services (calls/texts/emails)" — no pre-checked boxes
• • Clear disclosure: Consent text states exactly who will contact, for what purpose, and via which channels
• • Separate from other terms: Consent is not bundled with Terms of Service or Privacy Policy acceptance
• • Signature equivalent: Checkbox + timestamp + IP + user agent = valid electronic signature under E-SIGN Act
• • Immutable logs: Consent records stored in append-only D1 database with Cloudflare audit trail

1b. FCC One-to-One Consent Rule (2026)

The FCC's Declaratory Ruling (CG Docket No. 02-278) clarifies that a consumer who gives express written consent to be contacted by one seller cannot be transferred to or called by a different seller. This effectively eliminates shared lead models and the "one-to-many" consent approach that many lead generators used.

• • Seller-specific consent: Each lead must consent to Keystone North specifically — not a generic "I agree to be contacted by insurance providers"
• • No shared consent: A lead who consented to Company A cannot be called by Company B, even if they're in the same industry
• • Clear identification: The consent form must clearly identify Keystone North as the entity making the calls
• • Purpose-specific: Consent must specify the type of communication (telemarketing calls, texts, emails)
• • Documentation required: Written records of exactly what the consumer consented to, when, and to whom
• • Penalties for non-compliance: $500–$1,500 per violation (trebled for willful violations) — no cap on class actions

2. DNC Compliance (Federal + State)

We scrub every contact list against Do-Not-Call registries before every campaign:

• • Federal DNC: National Do Not Call Registry (FTC) — updated monthly
• • State DNC: CA, FL, TX, NY, PA, CO, IN, LA, MA, OK, WI — state-specific registries
• • Internal DNC: Company-specific opt-outs honored immediately across all campaigns
• • Scrub timing: Lists scrubbed within 24 hours of campaign launch; re-scrubbed weekly
• • Safe harbor: We maintain written procedures, training records, and scrub logs for FCC safe harbor defense

State-Specific Requirements

3. Calling Hours & Frequency

• • Federal window: 8:00 AM – 9:00 PM local time (called party's time zone)
• • Our standard: 8:00 AM – 8:00 PM local time (stricter)
• • Time zone detection: Based on area code + zip code cross-reference
• • Dialer enforcement: Dialer blocks calls outside permitted hours automatically
• • Frequency caps: Max 3 call attempts per number per 7 days (unless live answer)
• • Weekend policy: No Saturday/Sunday calls unless explicit consent for weekend contact

4. Call Disclosure & Recording

• • Opening disclosure: "This call is recorded for quality assurance" — announced within first 10 seconds
• • Identity disclosure: "This is [Name] from Keystone North calling on behalf of [Client Agency]"
• • Purpose disclosure: "We're calling to schedule a brief discovery call about filling your producers' calendars"
• • Recording: All calls recorded (audio + screen) with dual-channel separation
• • Storage: Encrypted at rest (AES-256), retained 5 years, access-controlled
• • Access: Available for compliance audit, quality review, dispute resolution

5. Opt-Out & Revocation

Consumers and businesses can revoke consent at any time. We honor immediately:

• • Verbal: "Remove me," "Stop calling," "I'm not interested" → immediate suppression
• • DTMF: Press 9 during call → auto-suppression
• • Text/Email: Reply STOP/UNSUBSCRIBE → immediate suppression
• • Email: privacy@keystonenorth.com or hello@keystonenorth.com
• • Processing time: < 5 minutes from opt-out to dialer suppression
• • Confirmation: Opt-out confirmation sent via email/SMS within 1 hour
• • Permanent: Suppressed numbers never re-added without new express written consent

6. Dialer Technology & Autodialer Compliance

• • Preview dialer: Human reviews each record before dialing (not a pure autodialer)
• • No predictive dialing: No abandoned calls, no "dead air" compliance issues
• • Human-in-the-loop: Setter reviews record, clicks-to-dial; qualifies as "human-initiated"
• • Caller ID: Local presence (area code match) or toll-free with business name
• • STIR/SHAKEN: Full attestation (A-level) on all outbound calls
• • CNAM: Registered business name display

7. State Law Compliance Matrix

We track and comply with state-specific requirements beyond federal TCPA:

8. Audit Trail & Documentation

We maintain comprehensive records for FCC safe harbor and regulatory defense:

• • Written procedures: Documented compliance policies, updated annually
• • Training records: Quarterly compliance training for all setters/closers; signed acknowledgments
• • Scrub logs: Timestamped DNC scrub results per campaign
• • Consent database: Immutable consent records with full audit trail
• • Call logs: Complete dial records (number, time, duration, disposition, recording link)
• • Opt-out logs: Timestamped opt-out requests with suppression confirmation
• • Retention: All compliance records retained 5 years (TCPA statute of limitations + margin)

9. Enforcement & Penalties

We take compliance seriously. Internal enforcement includes:

• • Zero tolerance: Any setter violating TCPA = immediate termination
• • Quality monitoring: 100% of calls recorded; 20% sampled weekly for compliance
• • Compliance officer: Dedicated role monitoring dialer, recordings, opt-outs
• • Incident response: 24-hour investigation of any complaint; 72-hour regulatory notification if required
• • FCC penalties: $500–$1,500 per violation (trebled for willful) — 1,052 TCPA class actions filed in H1 2025 alone (95% YoY increase)

10. Client Responsibilities

TCPA compliance is a shared obligation. Clients must:

• • Valid licenses: Maintain active insurance licenses in all states where we dial
• • Carrier appointments: Current carrier appointments in target states
• • E&O insurance: Current Errors & Omissions coverage
• • Accurate data: Provide correct carrier appointments, renewal dates, appetite
• • Complaint handling: Designate point of contact for consumer complaints
• • Script approval: Review and approve call scripts before campaign launch

11. Compliance Contact

• Compliance Officer: Kashif Ali — compliance@keystonenorth.com
• TCPA Hotline (24/7): 1-800-555-0199
• Consumer Complaints: complaints@keystonenorth.com
• Regulatory Inquiries: legal@keystonenorth.com
• Mailing Address: Keystone North, 100 King St W, Toronto, ON M5X 1C9, Canada

Disclaimer

This page is for informational purposes and does not constitute legal advice. TCPA and state telemarketing laws are complex and subject to change. Keystone North makes good-faith efforts to comply but does not guarantee immunity from regulatory action. Clients should consult their own legal counsel regarding their specific compliance obligations.