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WorkflowSingapore PDPADNC Registry

DNC marketing workflow for Singapore PDPA campaigns

Review this workflow before sending marketing calls, texts, faxes, or telephone-number-based app messages to Singapore telephone numbers.

It turns DNC campaign intake into specified-message classification, register checks, consent evidence, opt-out suppression, vendor controls, and approval records.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections6 primary sources
Overview

Before sending a specified marketing message to a , check the relevant DNC Register unless the user or subscriber gave or a statutory exclusion or exemption fits the message. This workflow gives campaign owners, privacy reviewers, and vendors a campaign-specific record of classification, register results, consent or exemption evidence, opt-out suppression, sender responsibility, and approval.

Section 1

1. Intake the campaign before any send list is loaded

Create the campaign intake record before loading the list into a channel. Record the product or service being promoted, the sender brand, the actual sender or vendor, every channel, the source of the telephone numbers, and whether the list contains Singapore telephone numbers.

For Registry submission, the DNC system accepts 8-digit numbers beginning with 3, 6, 8, or 9. That input rule is not a substitute for the legal scope test, which turns on whether the message is sent to a . If the list is mixed-market or partially formatted, normalize and separate the Singapore numbers before DNC review.

  • Campaign fields: campaign name, business owner, sender identity, vendor or agency, channel, message copy, landing page, offer, audience source, intended send date, and approver.
  • List fields: upload source, number format, Singapore-number filter, deduplication result, suppression-list match, DNC check batch ID, and rejected-number file if bulk filtering is used.
  • Vendor fields: whether the vendor is checking on behalf of another organisation, the organisation named in the DNC declaration, and the file returned to the campaign owner.
  • Stop the launch if the campaign owner cannot identify who authorised the message, who will send it, or which register applies to the channel.
Section 2

2. Classify whether the message is a specified message

Classify the message by purpose, not by campaign label. A message is in scope when its purpose, or one of its purposes, is to advertise, promote, or offer goods, services, land, an interest in land, a business opportunity, or an investment opportunity, or to promote the supplier or prospective supplier.

Do not treat a consent-request SMS or call as low risk just because it asks for permission. PDPC guidance treats offers to send specified messages, and requests for consent sent to a , as specified messages when they promote future offers.

  • Mark in scope when the copy promotes an offer, sale, membership, investment, property, supplier, event, seminar, course, or future promotional messages.
  • Mark out of DNC scope only with a recorded reason supported by the message's actual content and the statutory exclusions, such as a sole response to an individual's request for information, a service or reminder message whose purpose is not promotional, market survey or research, a charitable or religious cause, or a message sent to an organisation for that organisation's purposes.
  • For an ongoing relationship, test the sole purpose of the message. A service notice about the relationship may be excluded, but adding a separate promotional purpose can make the message specified; a once-off transaction does not by itself establish an ongoing relationship.
  • For third-party referrals, record whether the individual actually requested information or gave clear and unambiguous consent for this sender to send specified messages.
  • Escalate mixed-purpose copy if any part of the message promotes goods, services, land, business opportunities, investment opportunities, or a supplier.
Section 4

4. Suppress opt-outs and keep result validity visible

DNC approval expires with the DNC result. Results returned from the DNC Registry are valid for up to 21 days; if the campaign send continues after that period, recheck the remaining Singapore telephone numbers before continuing telemarketing.

Consent and opt-out handling need their own suppression control. PDPC business guidance says organisations must provide information on how individuals can opt out using the same medium as the message. When the recipient opts out through that route, update the suppression list and stop further specified messages to that number within 21 days.

  • Approval status values: not a , DNC checked and clear, consent exception approved, suppressed, rejected number, recheck required, or escalated.
  • Suppression fields: number, channel, sender or brand, opt-out source, received timestamp, scope of withdrawal, suppression applied timestamp, owner, and audit evidence.
  • Recheck trigger: DNC result older than 21 days, changed sender, changed message purpose, new number list, new channel, withdrawn consent, or vendor file replaced.
  • For specified messages, campaign systems should require either a valid DNC result showing that the number is clear for the channel or reproducible consent evidence covering the sender, number, channel, and message. Keep withdrawn consent and other opt-outs in the suppression control; do not approve a send while the required suppression remains unapplied.
Section 5

5. Approve sender, vendor, and message evidence before launch

Approval should cover both the person actually sending the message and anyone who caused or authorised the send. A brand owner, agency, and call centre can each be a sender depending on the arrangement, so the approval record should show who authorised the campaign and who performed each send or check.

If a third-party checker or aggregator is used, do not treat that vendor as an official substitute for campaign approval. Keep the DNC file, date received, expiry, and any on-behalf declaration with the campaign record, and require the vendor to return enough evidence for the sender to verify the decision.

  • Message approval evidence: final copy, sender identification, contact details that recipients can readily use, caller-line identity controls for voice calls, landing page, and channel.
  • Sender responsibility evidence: authorising organisation, agency or vendor, call centre or platform, agreement term restricting unauthorised specified messages, and owner of DNC checking.
  • Vendor evidence: DNC checking account or on-behalf declaration, returned result file, result receipt date, expiry date, rejected-number handling, and confirmation that the vendor is not using dictionary attacks or address-harvesting.
  • Final approval should name the approver, list the source evidence reviewed, state the approved audience and channel, and record the date by which recheck or reapproval is required.
Recommended next step

Turn DNC campaign checks into assigned work

This Singapore PDPA DNC workflow helps assign campaign intake, register checking, consent evidence review, suppression controls, vendor follow-up, and final launch approval.

Assessment workflow
Open Assessment Autopilot for Singapore PDPA

Convert DNC campaign intake into scoped questions, owners, evidence fields, and approval tasks.

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Research workflow
Review DNC source evidence

Use Research Copilot to check follow-up questions against the cited PDPC and DNC source material.

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Talk to Sorena
Talk through implementation

Review campaign scope, sender roles, consent evidence, suppression controls, and vendor responsibilities with Sorena.

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Primary sources

References and citations

Advisory Guidelines on the DNC Provisions
pdpc.gov.sg5 citations
Referenced sections
  • Official PDPC advisory guidelines supporting specified-message classification, consent evidence, sender responsibility, identification, contact information, and DNC checking.
  • Defines Singapore telephone number and explains that DNC obligations apply to specified messages sent to those numbers.
  • Supports purpose-based classification of specified messages and consent-request messages sent to Singapore telephone numbers.
Show 2 more
  • Supports the duty to check unless clear and unambiguous consent in evidential form has been obtained.
  • Supports sender responsibility for actual sending, causing, or authorising marketing messages, including agency and call-centre arrangements.
"Definition of a Specified Message"
More quoted passages
"The DNC Provisions contain a number of obligations that apply in relation to persons sending specified messages to Singapore telephone numbers."
"In most instances, a marketing message of a commercial nature would be a specified message."
"A person is not required to check with the DNC Registry"
"persons who caused or authorised the sending of the message"
Do Not Call Registry Business Rules
pdpc.gov.sg4 citations
Referenced sections
  • Official PDPC operational guidance for DNC accounts, number format, small lookup, bulk filtering, returned files, charges, and result validity.
  • Supports number-format intake, account setup, on-behalf checking, small-number lookup, bulk filtering, returned files, and result validity.
  • Supports the three-register channel split and the files returned by bulk filtering.
Show 1 more
  • Supports the 21-day validity period for DNC Registry results and the need to recheck after expiry.
"Results will be available within 24 hours."
More quoted passages
"Only 8-digit numbers starting with 3, 6, 8 or 9 will be accepted by the system."
"Telephone numbers submitted will be checked against all three DNC Registers."
"Results returned from the DNC Registry are valid for up to 21 days."
Do Not Call Registry and Your Business
pdpc.gov.sg3 citations
Referenced sections
  • Official PDPC business guidance for DNC marketing messages, opt-out handling, consent exceptions, third-party checkers, and examples of messages businesses may send.
  • Lists common marketing-message purposes and examples of message categories that businesses may send outside DNC checking.
  • Supports same-medium opt-out information and the 21-day period for stopping marketing messages after opt-out.
"Provide information on how individuals can opt out"
More quoted passages
"The marketing messages covered under DNC provisions include voice calls, text or fax messages"
"Upon receiving an opt-out request, you have 21 days"
Welcome to the Do Not Call Registry
dnc.gov.sg2 citations
Referenced sections
  • Official DNC Registry landing page supporting consumer registration, organisation checking, and caution about third-party DNC service providers.
  • Supports caution that PDPC does not endorse third-party DNC services and that organisations remain liable when aggregators miss listed numbers.
"Organisations must check with the DNC Registry"
More quoted passages
"Organisations that use third party aggregators to check telephone numbers against the DNC Registry should be aware"
Personal Data Protection Act 2012
sso.agc.gov.sg
Referenced sections
  • Binding source for the DNC Registry, specified-message definition, exclusions, register-check duty, consent exception, sender identification, opt-out, and prohibited number-generation methods.

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