Singapore PDPA DNC and marketing messages

Treat a campaign as DNC-relevant when it sends a specified message to a Singapore telephone number by voice call, text, fax, or a data application that uses the Singapore telephone number. PDPC guidance says Singapore telephone numbers are eight-digit numbers beginning with 3, 6, 8, or 9, and DNC business rules state that only those numbers are accepted for registry checks.

Subject to the Eighth Schedule exclusions, a message is generally a specified message when one of its purposes is to offer, advertise, or promote goods, services, land, interests in land, business opportunities, or investment opportunities. The sender must check the relevant DNC Register before sending unless it has clear and unambiguous consent in evidential form from the user or subscriber of the number.

A sender can avoid the DNC check only when it has clear and unambiguous consent in evidential form from the user or subscriber for the sending of the specified message to that Singapore telephone number. PDPC guidance treats consent as stronger when the notice clearly says specified messages will be sent to the telephone number and the individual gives a positive action, such as selecting a channel checkbox, signing next to a marketing clause, replying yes, or submitting an online form.

Do not treat silence, failure to opt out, or a broad statement about marketing use as enough for this DNC exception. The evidence must be accessible later and must show the individual choice, date and time, the interface or form shown, and the clause or channel terms accepted when consent was collected electronically.

Specified text and fax messages must identify the sender clearly and give contact information that lets the recipient readily contact the sender. PDPC business guidance also says organisations must explain how individuals can opt out using the same medium by which the message is sent. For voice calls containing specified messages, the caller's identity must not be concealed.

Sender responsibility is broader than the team pressing send. PDPC guidance treats the person who actually sends, causes, or authorises the message or voice call as a sender. A brand, agency, campaign manager, and call centre can therefore all need DNC controls depending on the arrangement.

Messages in the PDPA's Eighth Schedule are not specified messages and do not need the DNC check. They include messages by public agencies for non-commercial programmes, personal or domestic messages, emergency messages, transaction confirmations, warranty, recall, safety or security information, delivery of product updates or services the recipient is entitled to receive, messages whose sole purpose concerns the subject of an ongoing relationship, market research or survey messages with no marketing element, and B2B messages sent to an organisation for that organisation's purposes.

The exclusion analysis must be strict. If a message mixes an excluded purpose with advertising or promotion that is not excluded, treat it as a specified message and apply the DNC check or consent path. Separately, do not use generated or harvested number lists: PDPC guidance says section 48B prohibits sending, causing, or authorising any message where the recipient telephone number was obtained by dictionary attack or address-harvesting.