Who is responsible for calling compliance, the business or the AI vendor?
Both, for different things. The business decides whom to call, why and with what consent, so it owns list sourcing, consent, script content and sector rules from RBI, IRDAI or SEBI. The AI vendor and its telecom partners own the calling infrastructure: DLT-registered lines, correct routing, DND screening tools and data security. Get the split written into your contract.
How TCCCP splits the roles
TRAI's TCCCP Regulations 2018 distinguish the principal entity, the business on whose behalf communication is sent, from the telemarketers and access providers that carry it. The principal entity registers on DLT and is accountable for consent and content; telemarketers and operators are accountable for running compliant infrastructure and enforcing preferences.
The DPDP Act 2023 makes a similar split: the business is the data fiduciary and the vendor a data processor acting on its instructions under a contract.
Typical responsibility split
| Area | Business | AI vendor |
|---|---|---|
| Where numbers came from, and consent | Owns | Should refuse obviously unlawful lists |
| DLT-registered calling line | Uses | Provides or integrates |
| DND screening on bulk lists | Decides to run campaigns | Provides screening |
| Calling window | Sets it | Enforces it |
| Script, claims and disclosures | Owns | Executes as written |
| Recordings and data security | Sets retention | Stores and secures |
| Sector rules (RBI, IRDAI, SEBI, RERA) | Owns | Supports with logs |
Questions to settle in the contract
- —Whose DLT entity ID and which number series will the calls use?
- —Who handles complaints received through the operator?
- —Where is data stored, who can access it and how fast are breaches reported?
- —What logs are available for audits, and for how long?
A practical way to keep the split honest is to name one owner on each side. On the business side, one person owns consent records, the calling list and the script; on the vendor side, one contact owns the line, screening and incident reports. Review the split whenever you add a new campaign type, such as moving from reminders to outreach to new enquiries.
How Outpero fits
Outpero provides a DLT-registered calling line, DND screening on bulk campaigns, configurable calling windows and full recordings and transcripts. Your business owns its lists, consent and script.
The exact split depends on your set-up and contract. Have counsel review the agreement, especially the data-processing terms.
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