P-01
Subscriber Classification Test
Classify every prospect as Corporate Subscriber or Individual Subscriber before the dial.
Limited Companies, PLCs, and LLPs are Corporate Subscribers (PECR Regulation 21 — Legitimate Interest, opt-out). Sole Traders and unincorporated Partnerships are Individual Subscribers (PECR Regulation 21 — Consent, opt-in required). The classification is determined by the legal form of the subscriber line-holder, not the job title of the person you reach. Misclassification is the single most common PECR breach in the SaaS sector.
Statutory basis · PECR Regulation 21(2) and Regulation 21(4)
P-02
Pre-Call Suppression
Scrub against TPS and CTPS within 28 days of the dial.
TPS suppresses calls to Individual Subscribers; CTPS suppresses calls to Corporate Subscribers who have actively registered. The 28-day window is the ICO's enforcement-tested standard — scrubs older than 28 days are evidentially weak in dispute. Maintain a timestamped suppression record per dial campaign.
Statutory basis · PECR Regulation 21(2); ICO Direct Marketing Code of Practice 2018
P-03
Identification Disclosure
Disclose caller, organisation, purpose, and recording status within the first ten seconds.
PECR requires caller-identification at the start of every marketing call. UK-GDPR Article 14 adds the lawful basis disclosure and the right-to-object signpost. Best practice script: 'This is [name] from [company]. I'm calling on a B2B basis and the call is recorded for compliance and training purposes. You can ask me to remove your number at any time.' Ten seconds. Once per call.
Statutory basis · PECR Regulation 24; UK-GDPR Article 14(1)(a)(b)(c)
P-04
Legitimate Interest Assessment
Hold a written, dated LIA for every Corporate Subscriber prospect list.
Legitimate Interest is the most common lawful basis for B2B outbound, but it is not a default — it must be assessed and documented. A defensible LIA covers the purpose test (what you're trying to achieve), the necessity test (why outbound is the least intrusive method), and the balancing test (why your interest does not override the prospect's rights). One LIA per campaign or per quarter, signed and dated. The ICO has explicitly stated that an LIA produced after a complaint is not credible.
Statutory basis · UK-GDPR Article 6(1)(f); ICO Legitimate Interests Guidance
P-05
Recording Consent
Treat the UK as a one-party-consent jurisdiction; treat outbound calls into California, Florida, Pennsylvania, and Illinois as two-party.
England, Wales, Scotland, and Northern Ireland permit single-party recording for legitimate business purposes (RIPA 2000 s.3(3)). The thirteen US two-party-consent states require explicit opt-in from the called party before recording begins. The Pardoe Framework recommends a universal recording disclosure at the call open regardless of jurisdiction — it costs nothing, it eliminates the entire two-party-consent risk class, and it raises trust with the prospect.
Statutory basis · RIPA 2000 s.3(3); UK-GDPR Article 6(1)(f)
P-06
Dialling Windows
Dial within the Ofcom 'Persistent Misuse' permitted window. The Pardoe Framework narrows that further for SaaS B2B.
Ofcom guidance permits live marketing calls 08:00–21:00 local time of the called party. The Pardoe Framework's recommended B2B SaaS window is 08:30–10:15 and 14:00–16:30 — outside these blocks, connect rates fall below the threshold at which Ofcom may classify repeated unanswered attempts as 'persistent misuse'. Three consecutive abandoned calls to the same number inside 24 hours is the Ofcom complaint threshold; the protocol caps repeat dials at two per business day.
Statutory basis · Ofcom Persistent Misuse Statement of Policy 2017 (as amended); Communications Act 2003 s.128
P-07
Right-to-Object Honour Time
Suppress the prospect's number across all marketing surfaces within 30 days of an objection. Acknowledge within one business day.
UK-GDPR Article 21 is absolute for direct marketing — there is no balancing test on objection. The objection must be acknowledged immediately (a one-line confirmation email is sufficient) and operationalised across CRM, dialler, list provider, and any downstream marketing channels within 30 days. (Note: the 30-day window for Article 21 right-to-object is distinct from the 28-day TPS/CTPS scrubbing window in Protocol P-02 — different statute, different mechanism.) The same person calling the same prospect after an objection is the single highest-value claim type in PECR enforcement.
Statutory basis · UK-GDPR Article 21(2); PECR Regulation 22
P-08
Audit Trail Retention
Retain the LIA, suppression records, recording metadata, and objection log for 24 months minimum.
ICO investigative correspondence typically arrives 6–18 months after the original call. A retention window shorter than 24 months leaves the operator unable to evidence compliance retrospectively, which the ICO treats as 'compliance failure by omission'. Audit-trail completeness is the single largest determinant of the eventual fine envelope in a PECR enforcement action.
Statutory basis · ICO Direct Marketing Code of Practice 2018; UK-GDPR Article 5(2) Accountability Principle