One campaign, five steps, in order
A compliant campaign is not luck - it is a sequence. Scope the message, pick a lawful basis, add sender identity, send on the right channel, keep the records. Skip a step and you have a breach waiting to be found; run them in order and the campaign defends itself. This session turns the isolated rules into one repeatable pipeline you can hand to a teammate.
The five-step campaign flow 8 min live
Every compliant marketing send walks the same pipeline. The order matters: you scope before you choose a basis, and you keep records at the end regardless of the path you took to get there.
LiveSteps 1 and 2: scope, then pick a basis3 min▶
The first two steps decide whether DNC even applies and, if it does, what makes the send lawful.
- Step 1 - scope the message. Is it a specified (marketing) message at all? A pure delivery notice or receipt is out of scope, and the campaign is free of the DNC duty. If it markets, continue.
- Step 2 - pick a lawful basis. Two routes: hold clear consent for the number (from b2), OR run a register check that came back "not listed" within the last 21 days. Consent overrides listing; a fresh check clears an unconsented number. You need one or the other for every number.
- The 21-day window runs against the campaign, not the list. Check on the 2nd and you may send through the 23rd - after that, re-check before sending again.
LiveSteps 3 to 5: identity, send, record3 min▶
A clean lawful basis is necessary but not sufficient. Three more steps finish the send:
- Step 3 - add sender identity (s.44). Every specified message must clearly identify the sender and give contact information the recipient can use. The sender-identity details must be valid for at least ~30 days so a reply or query still reaches you.
- Step 4 - send on the channel. For a voice call or fax (s.45), you must not conceal or withhold the calling line identity - the recipient has to be able to see who is calling. For SMS, the sender ID from step 3 carries this.
- Step 5 - record everything. Capture the lawful basis used, the register-check date and result, and the sender ID sent. This is the evidence trail from Part 2.
Screen Marina's send ★ 8 min live · build-along
Now walk a real Marina Retail campaign through the checker step by step. Set the scenario to match the weekend SMS promotion and read the ruling and the provision it cites - then break it deliberately to see which step failed.
Live★ Build-along: run Marina's campaign through the checker6 min▶
Marina wants to SMS a weekend "20% off" promotion. Set the checker to: purpose = marketing, channel = SMS, consent = none, register check = clear within 21 days, sender ID = present. It should rule compliant and cite the check duty. Now flip sender ID to "missing" and watch it fail on s.44 even though the register check still passed - the exact trap the five-step flow is built to catch.
Try one more: switch consent to "on file" and register check to "listed". It still rules compliant - because consent overrides listing. That is step 2 doing its job: either basis carries the send.
Self-studyReading the ruling like an auditor4 min read▶
Each ruling names the provision it turns on. Learn to read them the way the PDPC would:
If it fails on s.43, your lawful basis is missing - no consent and no valid register check. Fix step 2.
If it fails on s.44, the basis was fine but the message has no clear sender identity or contact. Fix step 3.
If it fails on s.45, a voice or fax send concealed the calling line. Fix step 4.
If it comes back out of scope, it was never a specified message - step 1 ended the campaign early, and that is a valid outcome.
Records that prove it 8 min live
If the PDPC asks "how were you entitled to send this?", the answer is not a memory - it is a record. Step 5 builds an evidence trail that answers the query without you having to reconstruct anything.
LiveWhat to keep, and for how long3 min▶
For every campaign, keep three things linked to the send:
- The lawful basis per number. Either the consent record (exact wording, timestamp, channel, source) or the register-check log.
- The register-check date and result. A "not listed" confirmation is valid 21 days - store the date so you can prove the send fell inside the window. Keep it for as long as you may need to demonstrate compliance for that campaign.
- The sender ID used. The identity and contact details actually sent, so you can show the s.44 duty was met.
Marina's clean answer. Six weeks after the weekend promotion, a recipient complains to the PDPC. Marina pulls one record: the number was checked "not listed" on the Thursday, the SMS went out Saturday (inside 21 days), and the sender ID "Marina Retail, reply STOP to opt out" was on the message. The query closes on the first reply - because the evidence was captured at send time, not reconstructed afterward.
LiveThe 21-day window and mid-campaign withdrawal3 min▶
Two timing traps catch teams mid-campaign:
- The 21-day window is against the campaign. A long drip campaign can outrun its own register check. If sends continue past day 21, re-check the numbers first - the earlier "not listed" has expired.
- Buying a "cleaned" list does not transfer the duty. If you send, cause to send, or authorise the send, the obligation to hold a valid check is yours - regardless of what the list vendor promised.
- Withdrawal mid-campaign. If someone withdraws consent during a running campaign, stop sending to that number and re-check the register within 21 days before any further sends - consent no longer carries them.
Build Marina's campaign checklist ★ 10 min · the checker above
Turn the five-step flow into a checklist your team can run without you. Build it for Marina's weekend promotion, then adapt it to your own next send.
Step 1 - scope. Write the one-line test your team applies: is this a specified (marketing) message? If not, note why it is out of scope and stop.
Step 2 - basis + records. For each number, is there consent (with a stored record) or a register check "not listed" within 21 days (with a dated log)? Write the field you store for each.
Steps 3-4 - identity + channel. Confirm the sender ID and contact are on the message (s.44), and for voice or fax that the calling line is shown (s.45). Note the exact sender-ID text.
Step 5 - record + reflect. List the three records you keep per send. Then, in one line: which step is weakest in your current process, and what is the one fix?
Before session b4 ◐ 40 min total
- Run your next planned send through the five steps on paper. Note where it would stall and what evidence you can produce for each step.
- Pull one past campaign and try to assemble its evidence trail: lawful basis per number, register-check date, sender ID. What is missing?
- Check whether your list exports carry a register-check date and a 21-day expiry. If not, design where that tag would live.
- Read: the PDPC Advisory Guidelines on the DNC Provisions, the sections on the check duty and message identity (s.43-s.45).
Official sources covered
Taught from the PDPC's own DNC guidance. This page covers ~80% of its working content on running a campaign compliantly - message-identity depth lands in b4.
Three questions before you go 🎯 ◐ 90 seconds
1 · In the five-step flow, what do you do before choosing a lawful basis?
Step 1 is scoping. If the message is not a specified marketing message it is out of scope and the DNC duty never applies - so you check that before spending effort on a lawful basis.
2 · Your register check came back "not listed". For how long can you rely on it for this campaign?
A "not listed" confirmation is valid 21 days. A long campaign can outrun it - if sends continue past day 21, re-check first. Consent, by contrast, does not expire on a timer.
3 · A customer withdraws consent midway through a running campaign. You should...
Consent no longer carries that number. Stop the send, then re-establish a lawful basis by re-checking the register within 21 days before you send to them again.