WorkflowSingapore PDPADNC Registry

DNC marketing workflow for Singapore PDPA campaigns

Use 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.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

This workflow is for campaign owners, lifecycle marketers, privacy reviewers, and vendors preparing outbound marketing to Singapore telephone numbers. It should be validated against jurisdiction-specific legal, contractual, and policy requirements before implementation, but it gives teams a concrete operating record for DNC screening and approval.

Section 1

1. Intake the campaign before any send list is loaded

Start with a campaign intake record, not with a channel upload. 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.

Treat a Singapore telephone number as an 8-digit number beginning with 3, 6, 8, or 9. 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 Singapore telephone number, 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, such as a sole response to an individual's request for information, a service or reminder message, market survey or research, charitable or religious cause, or a message targeting businesses and not individuals.
  • 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 should expire with the DNC result, not with the campaign plan. 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. When an individual withdraws consent or opts out through the medium used for the message, update the suppression list and stop further messages to that number within the prescribed period supported by the guidance.

  • Approval status values: not a specified message, 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.
  • Campaign systems should block sends when the DNC check has expired, the number appears on the relevant register, consent evidence is missing, or an opt-out has not been applied.
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.
Primary sources

References and citations

pdpc.gov.sg
Referenced sections
  • Supports sender responsibility for actual sending, causing, or authorising marketing messages, including agency and call-centre arrangements.
"Persons who caused or authorised the sending of the message"
pdpc.gov.sg
Referenced sections
  • Supports same-medium opt-out information and the 21-day period for stopping marketing messages after opt-out.
"Upon receiving an opt-out request, you have 21 days"
pdpc.gov.sg
Referenced sections
  • Supports the 21-day validity period for DNC Registry results and the need to recheck after expiry.
"Results returned from the DNC Registry are valid for up to 21 days."
dnc.gov.sg
Referenced sections
  • Supports caution that PDPC does not endorse third-party DNC services and that organisations remain liable when aggregators miss listed numbers.
"Organisations that use third party aggregators to check telephone numbers against the DNC Registry should be aware"
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