learn-pdpa-dnc-with-phoebe / Practitioner session 4 of 8
Learn PDPA + DNC with Phoebe · Practitioner track · Session 4 of 8

Message-ID and calling rules

Passing the register check is only half the job. Every marketing message you send also has to say who it is from and how to reach them - and if it is a voice call or a fax, the number cannot be hidden. This session works through the two identification duties that apply to every specified message, no matter the channel, and audits a real Marina Retail SMS against them.

🟡 Medium Marketers · DPOs · sales ops Applies to every send ~45 min
0-3 · Welcome 3-22 · Sender ID (s.44) 22-40 · Calling line (s.45) 40-45 · Q&A
Part 0

Who sent this, and how do I reach them?

The register check keeps you off the wrong numbers. The identification rules make sure the people you do message can see who is behind the send and reply, opt out, or complain. Two short duties carry the weight: s.44 (identify the sender and give valid contact info, on every specified message) and s.45 (do not hide the calling line on voice or fax). Get both into your send template once and you stop thinking about them.

Read this first Educational, not legal advice. This session is a practical walk-through of the PDPA Part 9 identification duties - always verify against the current PDPC Advisory Guidelines on the DNC Provisions and get proper advice for real campaigns.
Live - presented in session Self-study - full depth after class ★ Try it now Sources covered at the end
★ What you build today A send template that satisfies both identification duties by default: a clear, accurate sender identity and a contact route that will still work in a month, plus an unconcealed calling line on every voice call and fax - so a compliant send stays compliant even when the register check passed.
Part 1 · covers the sender-identification duty

Identify the sender (s.44) 8 min live

Section 44 says every specified message must let the recipient see who sent it and how to contact them. It is simple to state and easy to forget - the "from" and the reply route are exactly what gets stripped when a template is trimmed for length. Here is the anatomy of a message that satisfies it.

From: Marina Retail Pte Ltd Weekend sale - 20% off storewide this Saturday. Show this at the counter. Reply STOP to opt out care@marinaretail.sg Sender identity clear + accurate: who sent it Contact info how to readily reach them, valid at least ~30 days Both are required on EVERY specified message, any channel No visible sender or no working reply route = a s.44 breach, even if the register check passed.
🔍 Click to zoom - the two parts s.44 requires on every message
LiveWhat s.44 actually requires3 min▶

Every specified message must clearly and accurately identify the sender - the person who sent it or authorised the send - and tell the recipient how they can readily contact that sender. Both parts, together, on every marketing message.

  • Clear and accurate. A vague "from a partner" or a brand the recipient will not recognise does not satisfy it. The identity has to be one the recipient can actually tie to who is marketing to them.
  • Readily contactable. A reply route the recipient can use without jumping through hoops - a phone number, an email, an address. It has to actually reach the sender.
  • It applies to every channel. SMS, email, voice, fax - if it is a specified message, s.44 is in force. Small screens and short scripts are not an exemption.
LiveThe contact info must stay valid (~30 days) + the URL rule3 min▶

The contact information you give has to be reasonably likely to remain valid for at least 30 days after the message is sent. A number you are about to retire, or a mailbox nobody reads, does not count - the recipient must be able to reach you after the fact.

  • The ~30-day validity is about contactability, not about the register. It says "the reply route you gave still works a month later" - nothing about re-checking numbers.
  • A website address counts only if the sender is identifiable from it. A URL satisfies s.44 when the recipient can tell who sent the message from the URL itself or the landing page it opens. A bare, unbranded short link does not.
  • Do not conflate the two 30-day/21-day rules. The s.44 "~30 days" is the sender-contact validity. The 21-day rule from b1 is the register-check validity. Different sections, different clocks - see the callout below.
Two clocks, do not mix them The s.44 ~30-day window is how long your contact info must stay valid. The 21-day window from b1 is how long a "not listed" register check stays valid before you must re-check. They are separate rules under separate provisions - a common exam-and-audit trap.
Part 2 · covers the calling-line duty + channels

Do not hide the number (s.45) 8 min live

On top of identifying yourself, if the specified message is a voice call or a fax, you must not conceal or withhold the calling line identity - the number the recipient sees. A blocked or spoofed caller ID on a marketing call is its own breach, separate from s.44. Here is what each channel needs.

Voice call s.44 ID + s.45 show number SMS / text s.44 ID (no s.45) Fax s.44 ID + s.45 show number s.44 sender ID every channel - no exceptions s.45 calling line voice + fax only - do not conceal Blocked caller ID on a marketing call = s.45 breach s.44 rides every channel. s.45 adds one thing for voice and fax: the recipient must see your number.
🔍 Click to zoom - what each channel needs
Lives.45 and the per-channel checklist3 min▶

Section 45 targets one thing: on a voice call or a fax carrying a specified message, you must not conceal or withhold the calling line identity. The recipient has to be able to see the number the message came from.

Channels.44 sender IDs.45 calling line
Voice callRequiredRequired - show the number
SMS / textRequiredNot applicable
FaxRequiredRequired - show the number
  • s.44 applies to all three channels. Sender identity and contact info are never optional.
  • s.45 adds the calling-line duty for voice and fax. Withholding or spoofing the number is the breach, even when everything else is in order.
LiveMarina's SMS - and the clock trap again3 min▶
Real world

Marina Retail's headerless SMS. Marina's team sent a promo SMS from a plain long-code number with no brand name in the body and no reply route - just "20% off this weekend, tap here" over an unbranded short link. The register check had passed, so they assumed they were fine. They were not: with no identifiable sender and no working contact, the message failed s.44. The fix was one line in the template - a sender name plus "Reply STOP or care@marinaretail.sg" - not a new process.

Keep the two clocks apart When you fix a s.44 gap, resist the urge to say "valid for 21 days". The contact info you add must stay valid ~30 days (s.44). The 21-day clock belongs to the register check (b1). Writing "21" on a s.44 control is the mistake auditors catch most.
Self-studyWhere these duties break in real send stacks4 min read▶

The identification duties rarely fail because someone decided to hide. They fail because a template was trimmed, a channel was swapped, or a tool defaulted to something unbranded. The recurring failure modes:

  • The trimmed SMS. A body cut to fit one segment drops the sender name or the "Reply STOP" line. Both are s.44 content - a length budget is not a defence.
  • The shared short link. A campaign reuses a generic bit.ly-style link that resolves to a page with no clear sender. The URL then does not satisfy s.44, because the sender is not identifiable from it.
  • The dialler default. An outbound calling platform set to withhold or randomise caller ID trips s.45 on every marketing call, silently, until someone checks a handset.
  • The retired mailbox. A reply-to address or number that is decommissioned inside the month breaks the ~30-day contact validity even though it was correct when the message went out.

The fix for all four is the same shape: set the sender identity, reply route, and caller ID at the platform or template level, and put a periodic check on the list so a decommissioned route is caught before the next send.

Build-along · audit a real message

Audit a Marina message ★ 10 min

The whole session collapses into three questions you can run on any message in under a minute. Pull a real Marina Retail send - or one of your own - and walk it through.

Is the sender identifiable? Read only the message, as the recipient would. Can you tell who is marketing to you, clearly and accurately? If a URL is the only clue, is the sender identifiable from the link or its landing page?

Are they contactable? Is there a reply route - phone, email, address - that actually reaches the sender, and is it reasonably likely to still work in ~30 days? A retired number fails.

Voice or fax? Is the number shown? If the send is a call or a fax, confirm the calling line identity is not blocked, withheld, or spoofed. SMS and email skip this one.

Fix it in the template. Whatever failed, patch it once at the template level so every future send inherits the fix. Note the change and who owns the send template.

★ Marina Retail after b4 Marina's send template now carries a clear sender name and a working reply route by default, and their outbound calls show the number instead of a blocked ID. A campaign that passes the register check now also survives the identification duties - and the team no longer confuses the 30-day contact clock with the 21-day register clock. Next, in b5, we find the messages that fall outside the DNC rules entirely.
Homework

Before session b5 ◐ 40 min total

Source material

Official sources covered

Taught from the PDPC's own DNC guidance. This page covers the identification duties - the sender-ID and calling-line rules that apply to every specified message.

✓PDPC · Advisory Guidelines on the DNC Provisions (Part IV)Part 1-2 · s.44 sender identity + contact validity · s.45 calling line · per-channel duties
◐PDPA Part 9 (s.44, s.45)Part 1-2 · the statutory identification and calling-line provisions
Check yourself

Three questions before you go 🎯 ◐ 90 seconds

1 · Under s.44, the contact information in a marketing message must be reasonably likely to stay valid for at least...

s.44 requires the sender contact info to be reasonably likely to remain valid for at least 30 days. Do not confuse this with the 21-day register-check validity from b1 - separate rule, separate clock.

2 · A marketing SMS passes the register check but shows no sender name and no reply route. It is...

s.44 applies to every channel. Passing the register check is necessary but not sufficient - a message with no identifiable sender and no contact route fails on s.44.

3 · Which duty applies to a voice marketing call but NOT to a marketing SMS?

s.45 - the calling-line duty - applies to voice and fax only. s.44 sender identification applies to every channel, and the register check applies to whichever register covers the channel.

Practitioner session 4 cheat sheet · pin this

s.44 - identify the senderEvery specified message must clearly and accurately show who sent or authorised it.
s.44 - contact infoGive a route the recipient can readily use to contact the sender - phone, email, or address.
~30-day validityThat contact info must be reasonably likely to stay valid at least 30 days after the send.
URL ruleA website address counts only if the sender is identifiable from the URL or its landing page.
s.45 - calling lineVoice calls and faxes must not conceal or withhold the calling line identity (the number shown).
Every channels.44 rides SMS, email, voice, and fax. s.45 adds the number-shown duty for voice and fax only.
Two clocks, do not mixs.44 ~30 days = contact validity. 21 days = register-check validity (b1). Separate rules.
Fix at the templateSet sender ID and reply route once in the send template so every campaign inherits it.