Frequently Asked Questions (FAQs)

General


Commercial Communication refers to any voice call or message sent through telecommunication services, where the primary intent is to inform about or advertise or solicit business for-

i. goods or services; or

ii. a supplier or prospective supplier of offered goods or services; or

iii. a business or investment opportunity; or

iv. a provider or prospective provider of such an opportunity;

"“Unsolicited Commercial Communication” signifies any commercial communication that is neither as per the consent nor the registered preference(s) of subscriber, but shall exclude:

i) any transactional message or voice call;

ii) any service message or voice call;

iii) any message transmitted on the directions of Central Government or State Government or agencies established under the Constitution, when such communication is in Public Interest;

iv) any message or voice calls transmitted by or on the direction of the Authority or by an agency expressly authorized for the purpose by the Authority."

"“Transactional communication” means a communication triggered by a transaction performed by the Subscriber, who is also the Sender’s customer, provided such a communication is sent within thirty minutes of the transaction being performed and is directly related to it.

Provided that the transaction may be a banking transaction, delivery of OTP, purchase of goods or services, etc.

Example 1:

TRANSACTIONAL

Hello! Your A/C no. <XXXXX> has been debited by Rs. <XXXX> The A/C balance is Rs. <XXXX> on <DD/MM/YY> The A/C balance is Rs. <XXXX> Info:<TYPE>/<PURPOSE>/< Rs. of template OR REFERENCE NUMBERs

Example 2:

TRANSACTIONAL

Thank you for using <...PRODUCT..> Card No. <XXXX> on <DD/MM/YY> for INR <XXXX> To check EMI eligibility on spends above INR <XXXX> log on <URL> T&C Apply

Example 3:

TRANSACTIONAL

<XXXXXX> is your One Time Password for online purchase, Amex card ending >XXXXX>, if not requested call the number on back of your card.<date&time>."

"""Promotional communication""- Communication indicating a marketing communication, upsell or cross sell. Promotions cannot be combined with service or transaction message.

Example 1:

PROMOTIONAL

Lose weight naturally!

Get MY DIET by <NAME OF CONSULTANT> & lose up-to 10Kg. No exercise. No machine. First free consultation Click <URL> To revoke consent send SMS as REVOKE HEADER to 1909

Example 2:

PROMOTIONAL

Latest in COLLECTION <SEASON OR YEAR> now at <BRAND> store near you. Shop now to upgrade your wardrobe. T&C apply To revoke consent send SMS as REVOKE HEADER to 1909"

"“Service message or Service Call” means a message sent to a recipient or voice call made to recipient either with his consent or using a template registered for the purpose, the primary purpose of which is to facilitate, complete, or confirm a commercial transaction that the recipient has previously consented to enter into with the sender; or to provide warranty information, product recall information, safety or security information with respect to a commercial product or service used or purchased by the recipient;

to provide—

i. notification concerning a change in the terms or features of; or

ii. notification of a change in the recipient’s standing or status with respect to; or

iii. at regular periodic intervals, account balance information or other type of account

iv. statement with respect to, a subscription, membership, account, loan, or comparable ongoing; or

v. commercial relationship involving the ongoing purchase or use by the recipient of

vi. products or services offered by the sender; or

vii. information directly related to an employment relationship or related benefit plan in which the Recipient is currently involved, participating, or enrolled; or

viii. information relating to delivery of goods or services, including product updates or upgrades, that the recipient is entitled to receive under the terms of a transaction that the recipient has previously consented to enter into with the sender;

Example 1:

SERVICE

Dear , your product -<PRODUCT-ID> is due for Service on <DD/MM/YY>, visit <URL> or contact your nearest <XXXXXX> dealer for appointment. We look forward to serve you!.

Example 2:

SERVICE

Dear Customer, This is in continuation to the multiple reminders sent by the bank for updating Adhaar number with the bank. Please note, customer failure to update Adhaar Number will lead to a freeze being placed in his/her account /card post <DD/MM/YY>. Please update at <URL> immediately. Kindly ignore the message if you have already updated your Adhaar number <BANK NAME>"

“Access Providers” includes the Basic Telephone Service Provider, Cellular Mobile Telephone Service Provider, Unified Access Service Provider, Universal Access Service Provider and Virtual Network Access Provider (VNO) as defined in the respective licenses issued by Department of Telecommunication (DOT).

DLT uses high end technology to safeguard all the information once the data is published in the system.

To provide a reliable and robust DLT platform, Trubloq is enabled with modular, flexible, secure architecture with telco-grade security features and efficient data security controls.

"Valid complaint refers to objection made against any commercial communication that is neither as per the consent nor as per registered preference(s) of recipient, but shall not include:

i. Any transactional message or transactional voice call

ii. Any message or voice calls transmitted on the directions of the Central Government or the State Government or bodies established under the Constitution, when such communication is in Public Interest

iii. Any message or voice calls transmitted by or on the direction of the Authority or by an agency expressly authorized for the purpose by the Authority

Provided that every such complaint shall be made by a subscriber within three days of receipt of the unsolicited commercial communication (UCC)"

"A subscriber can register complaint to his/ her access provider through available modes. As per the new regulation, the complaint needs to be filed within three days of receipt of the UCC.

Subscriber can register complaint in following ways:

i. SMS: Send complaint details in a standard format to 1909

ii. Email: Send email with relevant details of UCC to your Access provider

iii. IVRS/ Call center: Call 1909 and provide details of complaint

iv. Web/ Mobile app: Visit website/ mobile app of Access provider/ DLT platform and file a complaint by furnishing relevant details

Details to be provided by a subscriber during complaint registration:

i. Telephone number/ CLI/ Header/ sender ID from which UCC was received

ii. Date

iii. Time range (optional)

iv. Referred telephone number (optional)

v. Label of commercial communication (transactional/ service/ promotional)

vi. Message content (for message only)

On receipt of valid request, an acknowledgement message is communicated (within 15 minutes) with a unique reference number to subscriber on registered mobile number and E-mail along with its resolution timelines."

The TAT for complaint resolution is 72 hours, post receipt of complaint request.

For any technical support, you can contact our customer support team via email and phone.

Telemarketer


"Telemarketer is a individual or legal entity engaged in transmission or delivery of commercial communications or aggregation

A registered telemarketer (RTM) refers to any telemarketer who is registered with any one Access provider(s)/ DLT platforms in accordance with the requisite procedures stated in the regulation."

"To facilitate commercial communication, a registered telemarketer (RTM) is eligible to perform following functions:

i. Register on DLT platform as telemarketer for Aggregator function (TM-AF) and telemarketer for Delivery function (TM – DF)

ii. Register on behalf of principal entity and manage their account to carry out following activities:

a. Register and manage headers (Sender ID) for message and/ or Caller Line Identity (CLI) for voice communication

b. Register and manage consent/content templates

iii. Initiate scrubbing of commercial communication by providing relevant details

iv.TM-DF with telecom resource connectivity to Access provider can initiate delivery of commercial communication to the scrubbed target list

v. Maintain data repository of all commercial communication sent by RTM for future reference and traceability"

"Each Telemarketer can register as Aggregator function (TM - AF) and/ or as Delivery function (TM - DF) on DLT platform to generate a unique Registered Telemarketer (RTM) ID. The RTM ID will be unique across all Access providers/ DLT platform.

Procedure to register on DLT platform is as follows:

i. Visit Trubloq (Hyperlink) and select to sign up as Telemarketer.

ii. Select the area of operation:
a. Aggregator function (TM-AF)
b. Delivery function (TM-DF)
c. Both

iii. Select functional domain
a. Voice
b. SMS
c. Both

iv. Provide details of authorised person to access the RTM account. Further, provide business details and upload relevant documents. Additionally, in case of registration as a TM-DF, the applicant needs to share IP details for whitelisting. Multiple IPs can be whitelisted by Telemarketer(s) to ensure business continuity.

v. Pay the applicable registration fee through available online payment modes. Additionally, in case of registration as a TM-DF, the telemarketer needs to submit security deposit for telecom resources.

vi. Entity registrar will validate and verify details provided by the telemarketer within 72 hours.

vii. On successful registration, the registrar will approve, register and activate the RTM id on the DLT platform.

vii. The registrar function will communicate successful validation or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

viii.Post activation, each registered telemarketer can login to the portal and perform telemarketing functions."

"The fee for Telemarketer registration is given below:

1. Registration Fee for Telemarketer Aggregator function (TM-AF) is INR 5,000/-

2. Additional fee of INR 50,000/- for registration as Telemarketer Delivery function (TM-DF)"

"The validity of each Telemarketer ID is five years from the date of registration.

The Telemarketers can request for renewal of RTM ID as per the following procedure:

i. Login to Trubloq using TM login credentials

ii. Go to account settings -> RTM ID renewal

iii. Confirm the request using OTP

iv. Confirm/ provide requisite business details and upload relevant documents

v. Pay the applicable registration fee through available online payment modes

vi. Entity registrar will validate and verify details submitted by the telemarketer within 72 hours

vii. On successful registration, the registrar will approve, register and renew the RTM ID on the DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours)"

Yes, all Telemarketers need to register with Originating Access Provider's DLT platform to be able to deliver commercial communication.

No, as per the regulation, it is mandatory for a Telemarketer to register on DLT platform for the purpose of facilitating commercial communication.

Yes, registered telemarketer (RTM ) ID is unique across all access providers/ DLT platforms.

No, a telemarketer needs to register only once with the OAP's DLT platform to generate RTM ID. This ID is shared across all the platforms seamlessly.

The TAT for entity registrar to approve Principal Entity/ Telemarketer on DLT platform is 72 hours from receipt of registration fees.

The registrar function will communicate successful validation or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

Trubloq empowers the Principal Entity(s) and Telemarketer(s) to manage their respective accounts, campaigns, etc. through near real time performance reports and dashboards.

TMs and PEs can view the reports/ dashboards online on Trubloq platform or choose to download the same in the available formats

Telemarketer (TM) or Principal Entity (PE) can update or modify their respective account information as per the procedure listed below:

i. Login to Trubloq (hyperlink) using TM or PE credentials

ii. Go to account settings and update account details

iii. Authenticate updated account details using OTP

iv. Entity registrar will validate and verify details as per the submitted changes/ updates within 72 hours

v. On successful update, the registrar will approve, register and renew the RTM ID on DLT platform.

vi. The registrar function will communicate successful update or any discrepancy i.e. missing document or incorrect details with the applicant on the registered E-mail and mobile number in the defined TAT (72 hours).

The payments from Telemarketer(s) and Principal Entity(s) will be accepted through the following modes as mentioned below:

i. Online mode: E.g. Credit cards, Debit Cards, Internet Banking, etc.

ii. Offline mode: Demand Draft (DD) and Cheque

Trubloq enables the registered telemarketer to manage Principal Entity's account on their behalf. A telemarketer (registered on Trubloq as Aggregator and/ or delivery function) can register a Principal Entity (PE) by following below mentioned steps:

i. Visit Trubloq (Hyperlink) and login using registered Telemarketer credentials

ii. Go to Entities account (dropdown) -> Register a new Principal Entity

iii. Provide valid business PAN, details of authorised person, business details and upload business documents along with letter of authorization

iv. Pay registration fee

v. Entity registrar will validate and verify details provided by the telemarketer within 72 hours

vi. On successful registration, the entity registrar will approve, register and activate PE ID on DLT platform

vi. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

vii. Post PE ID activation, each telemarketer can carry out functions on behalf of Principal Entity as per business requirements.

Trubloq enables the registered telemarketer to manage Principal Entity's account on their behalf. A telemarketer (registered on Trubloq as Aggregator and/ or Delivery function) can register a Principal Entity by following below mentioned steps:

i. Visit Trubloq(Hyperlink) and login using registered Telemarketer credentials

ii. Click on Entities account button and select add Principal Entity

iii. Provide Principal Entity ID and letter of Authorization (LoA)

iv. Entity registrar will validate and verify details provided by the telemarketer within 72 hours

v. Upon successful registration, the entity registrar will approve access to telemarketer for managing Principal Entity account and update DLT platform

vi. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

vii. Post access approval, each telemarketer can carry out functions on behalf of Principal Entity as per business requirements

Trubloq enables a registered telemarketer to manage the account of a principal entity. and perform the following functions:

i. A telemarketer may choose to register principal entity and further manage their account for transmission of commercial communication to their subscribers

ii. The telemarketer is then eligible to register and manage headers (Sender ID) for message and/ or Caller Line Identity (CLI) for voice communication, on behalf of Principal Entity

iii. It may also register and manage consent/content templates for contracted Principal Entities.

The renewal is due after five years. The renewal fee shall be decided during later period.

A Principal Entity can add, modify/ remove a telemarketer in the following ways:

i. Visit Trubloq (Hyperlink) and login to access Principal Entity portal with registered login credentials

ii. Go to telemarketer->Add a telemarketer

iii. Further, on Telemarketers page, the principal entity can select a preferred TM from the list of all registered Telemarketers (Aggregators Function and Delivery Function)

iv. Once a telemarketer is selected it gets reflected on the Manage Telemarketer (summary) page with status- 'Active'

v. Trubloq also enables the Principal Entity to modify/ remove any of the desired telemarketer by selecting the delete option

There is no limitation on the number of TMs (TM-DF/ TM-AF) registered by a Principal Entity. However, for sending commercial communication each PE shall select minimum one TM at the time of registration.

A registered telemarketer after logging into the telemarketer's portal can view and approve/ reject the request received from a principal entity for transmission of commercial communication.

Letter of Authorisation (LoA) shall be signed by authorised signatory of a principal entity to allow/ delegate select functions to a telemarketer on behalf of the entity. LOA is a mandatory document for a telemarketer to register on-behalf of a principal entity.

Important considerations in LoA:

i. Name of principal entity

ii. Name of the signatory with designation and contact details (mobile number and email)

iii. Business details and purpose for which LoA is being assigned

iv. Name of the telemarketer with details of Key Account Manager

No, a Principal entity cannot perform delivery function on its own. It has go through a RTM with delivery function to send the communication.

Yes, headers and templates registered under a Principal Entity can be used by other telemarketers managing Principal Entity's account for different functions.

Trubloq helps you track activities/ functions on real time basis and monitor performance of your RTM.

To monitor the activities/ functions performed by a telemarketer on-behalf of a principal entity, a principal entity needs to login to Trubloq (Hyperlink) using registered login credentials and view the dashboards.

Header is a unique 6-digit string created by an entity for sending commercial communication. Header should be connected to entity's business category and relevance.

As per the regulation, number series for different types of commercial communication via voice are as follows:

i. "140XX" for sending promotional messages

ii. Fixed line number series ('040', '044', '022') for sending transactional/ service messages

No. Headers are non-transferrable. However, a PE can surrender a registered header. Surrendered header is sent back to the header pool and can be allocated on request to any interested PE by header registrar

No, a Principal Entity is not allowed to block a header series for sending commercial communication.

Header is a unique 6-digit alpha string assigned to an individual, business or legal entity for sending commercial communication. Special characters such as @, $, %, &, etc. and blank space (“ ”) are not allowed.

Every principal entity or telemarketer on-behalf of principal entity need to register header with access providers as per the procedure below:

i. Login to the Trubloq using Telemarketer/Principal Entity login credentials

ii. Go to SMS headers-> Add header in header page

iii. Fill the requisite details such as content category, sender ID / header and provide details of sender

iv. Submit the request for approval and make payment through available payment modes

v. Header registrar will validate and verify details provided by the telemarketer/Principal Entity within 60 mins

vi. On successful registration, the registrar will approve, register the header on the DLT Platform

vii. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

A newly registered header comes with a lifetime validity. But, if found inactive for more than 90 days, it will be sent back to the header pool and made available for others.

There is no limit on the number of headers registered by a principal entity till date. However, a minimum of one header needs to be registered by a principal entity to send commercial communication to its subscribers

Yes, there is an exclusive header list which cannot be used by a Principal Entity or Telemarketer on-behalf of a Principal Entity at the time of header registration.

The list covers different categories and may not be limited to:

i. Names of celebrities, politicians

ii. Trademarks

iii. Registered companies, brands

iv. Any obscene material

v. Govt., SEBI related headers

Yes, Trubloq enables a Principal Entity/ Telemarketer on behalf of Principal Entity to bulk upload header/ sender ID(s) for transmission of commercial communication.

Promotional Message

Promotional message means commercial communication that can be sent to a mobile subscriber whose preferences are not set (not on DND). Or, any commercial communication that an enterprise can send to an intended Recipient after taking consent to send such messages.

Header (6-digits): 565690, 787878, 987123, 555555, etc.

Sample SMS template1: Happiness Sale on 21 & 22 Dec. Get up to 71% OFF on over 100 brands. Register & get EXTRA Rs. 100/- OFF. Give missed call to 808XXXX234. TnC

Sample SMS template2: 24 Hr Kitchen Furniture SALE up to 35% OFF, till 22 Dec, T&C

Sample SMS template3: Get MY DIET by <NAME OF CONSULTANT> & lose up-to 10Kg. No exercise. No machine. First free consultation Click <URL>. To revoke consent, send SMS as REVOKE HEADER to 1909

Transactional Message

Transactional message means a message which contains One Time Password (OTP) and requires to complete a banking transaction initiated by the bank customer. This is applicable to all banks including national/ scheduled/ private/ Govt. and MNC banks.

Header (6-alpha): KLMNOP, TRUBLQ, DLTDLT, etc.

Sample SMS template1: 763892 is the OTP for trxn of INR 9876.90 at ABCD App with your card XX0000. OTP is valid for 10 mins. Pls do not share it with anyone.

Sample SMS template2: 763892 is OTP for txn of INR 373.32 at ABCD on XYZ Bank Credit Card XX0000. OTPs are SECRET. DO NOT disclose it to anyone. Bank NEVER asks for OTP.

Service Implicit Message

Service Implicit: Any messages, arising out of customer’s actions or his relationship with the Sender, that is not promotional, and is not in the interest of the customer to block such communications. These messages may or may not be triggered by a subscriber-initiated transaction and will not be blocked for subscribers who have otherwise blocked service messages also.

Confirmation messages of a net banking or a credit/debit transaction;
Product purchase confirmation; delivery status of a parcel;
OTP required for e-commerce website, app login, social media apps, KYC, etc.;
Messages from home operator; Messages from schools regarding attendance/transport;
Messages from hospitals/clinics regarding appointment/discharge reports;
Govt./TRAI/DoT mandated messages, advisories, messages from state Govt., LEAs, local
authorities, traffic advisories, election commission, disaster management advisories;
Service messages from car workshops, gadget service centers;
Day-end/ month-end settlement alerts to securities/demat account holders.

Header (6-alpha): ABCDE, AFIOMA, UNFOCO, etc.

Sample SMS template1: Hello! Your A/C no. <XXXXX> has been debited by Rs. <XXXX> The A/C balance is Rs. <XXXX> on <DD/MM/YY> The A/C balance is Rs. <XXXX> Info: <TYPE>/<PURPOSE>/< Rs.  of template OR REFERENCE NUMBERs

Sample SMS template2: Dear Customer, as per your request, contact details have been updated against your fixed deposit account.

Sample SMS template3: Dear Customer, your order has been picked up by the delivery boy and is on his way. Your delicious pizza is reaching early!

Service Explicit Message

Any service message which doesn’t fall under the category of service message (Implicit) will be sent only against service explicit, digitally verified/verifiable consent that has been taken from the subscriber by the respective enterprise.

Header (6-alpha): NUTUKI, PRIZEM, ZSERTA, etc.

Sample SMS template1: Dear Customer, Congratulations on your Home Anniversary! Now avail a Top-up up to Rs 50 lacs* with ROI @9.20%* on your Home Loan. Call Toll Free 1800XXXXX00 *T&C

Sample SMS template2: Dear , based on your relationship, we are approving a per-approved Home Loan up to Rs. 1 crore. Click here https://www.domain.com/ . Regards, QT Housing. T&C.

Subscriber can register preferences with respect to time band for receiving commercial communication as follows Time band:

a. 00:00 hrs to 06:00 hrs

b. 06:00 hrs to 08:00 hrs

c. 08:00 hrs to 10:00 hrs

d. 10:00 hrs to 12:00 hrs

e. 12:00 hrs to 14:00 hrs

f. 14:00 hrs to 16:00 hrs

g. 16:00 hrs to 18:00 hrs

h. 18:00 hrs to 21:00 hrs

i. 21:00 hrs to 24:00 hrs

The default preference of time band for receiving commercial communication is 10:00 hrs to 21:00 hrs

Service (explicit consent) and Promotional messages are subject to preference and consents of a subscriber. However, Service (inferred consent) and Transactional messages are not subject to subscriber preference or consent.

No, government entities do not need to acquire subscriber consents. Any message or voice calls transmitted on the directions of the Central Government or the State Government or bodies established under the Constitution, when such communication is in Public Interest are not subject to user consents or preferences.

However, Govt. limited companies e.g.- PSUs, Banks etc. need to take subscriber's consent prior sending notifications to them.

Yes, a subscriber can register his/her consent for preferred Principal Entity by visiting the website of the desired Principal Entity, providing basic subscriber details and digitally authenticating via OTP.

A unique reference number is generated and communicated to the subscriber on the registered e-mail and mobile number with implementation timelines.

To de-register a consent template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to Trubloq using telemarketer/ principal entity credentials

ii. Go to Consent template -> Select the template -> Delete

To register a content template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to DLT using telemarketer/ principal entity credentials

ii. Go to Content template -> Add new content template

a. Define template type – Promotional/Transactional/Service

iii. Select category of content and a registered header

iv. Provide content for fixed part and demarcate variable content in the template using insert variable button

v. Submit template for verification

vi. Content template registrar will validate and verify details provided by the telemarketer/ principal entity within 60 mins

vii. On successful registration, the content template registrar will approve and register content template ID on DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy in case of incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

Once the template is registered, only the variable part of template can be changed, however, a Principal Entity can register multiple templates as per business requirements.

A Principal Entity is eligible to register multiple headers and multiple templates under each header. Example: For a Principal Entity with different departments, it may register multiple headers for each department and further, multiple templates can be registered under each header.

All languages that support unicode functionality.

Currently, only english language is supported to register a consent template.

A consent template is tagged with a header, hence cannot be used with multiple headers. A content template can be used with multiple headers.

To scrub messages, a telemarketer has to follow below mentioned procedure:

i. Login using registered credentials

ii. Go to scrubber -> Create a scrubbing list

iii. Provide details of registered header and template

iv. Provide content for variable part for the template

v. Upload target list in CSV format

Telemarketer can choose to perform one of the following actions:

i. Scrub and Deliver (Both actions using the OAP)

ii. Scrub and Generate Ref# (Scrubbing through one operator and generate Ref#, that can be used for delivery using another operator)

iii. Deliver from Ref# (Bring the scrubbed file from one operator and deliver through another operator)

Scrubbed file is valid till 23:59:59.

A report will be generated after every scrubbing with success %. Only the count is shares, and not the actual mobile numbers.

Delivery acknowledgement report will be generated only for Transactional and Service Implicit messages.

Yes, time-based delivery scheduling is available and can be opted through the RTM login.
No, scrubbing criteria is same for all types and modes of commercial communication. Scrubbing is performed against various parameters like Consents, preferences, Header and Template.

No, each commercial communication is scrubbed for header and templates (consent/ content) and hence the same cannot be changed for scrubbed data prior to delivery.

If any parameter of the scrubbed data needs to be changed, the message/ call shall be scrubbed again.

No, preference and consent database will not be accessible to Telemarketers due to secure controls and use of Blockchain technology on DLT platform.

Headers and templates are linked to the Sender/ Principal Entity under which they are registered (whether registered by Principal Entity or by telemarketer on behalf of Principal Entity), therefore, they are not detained while removing a telemarketer.

Yes, if the commercial communication is not in line with subscriber's consent and preference or does not adhere to the regulation, the telemarketer will be penalised.

The different scenarios leading to blacklisting of a telemarketer are as under:

i. Sending continuous UCC messages to subscribers

ii. Failure to produce relevant business information, agreements

iii. Submission of fraudulent documents while registering on DLT platform

Also, a telemarketer may face hefty penalties on violations to the regulations such as:

i. Restrict provision of telecom resource to a blacklisted telemarketer by any access provider during the period of blacklisting

ii. Names of the blacklisted telemarketers will be communicated to all access providers

Each telemarketer can de-register and surrender its RTM ID. To de-register as a registered telemarketer, follow the below mentioned steps:

i. Visit Trubloq (Hyperlink) and login using registered credentials

ii. Raise a request to de-register as telemarketer (make sure all registered telecom resources have been surrendered and agreement for delivery with all access providers are terminated before raising the request for de-registration)

iii. Once the request is submitted, the telemarketer is temporarily de-registered and during this period a telemarketer prohibited to perform any of telemarketer’s functions

iv. Further, verification of telecom resource holdings and delivery agreement with other access provider is executed

v. Upon successful verification, entity registrar will approve the request, permanently deactivate the RTM ID and update DL- Telemarketer.

vi. The registrar function will communicate successful validation or any discrepancy with reason of failure and suggestion for correction through registered mobile number and e-mail

Principal Entity


As per the regulation, it is mandatory for every entity to register on DLT platform for transmission of commercial communication.

Classification of Principal Entity are:

i. Individual

ii. Sole Proprietor

iii. Partnership Firm

iv. Private/ Public/ Govt. Limited Company

v. Limited Liability Partnership

vi. Trust, Association, Security & Club (TASC)

vii. Govt. Entity


Functions of a Principal Entity:

i. Register with Operator's DLT platform by submitting business documents.

ii. Select a Registered Telemarketer (RTM) and choose to give permission to perform functions on its behalf.

iii. Acquire consents from consumers (mobile subscribers) through SMS, Web or Mobile App and upload them on DLT platform.

ii. Register all it Headers and Templates on the platform through its login

iii. Use the selected RTM to send communication (SMS and Voice)

Yes, the Principal Entity ID will be unique across all telecom Access providers in India.

For a Principal Entity, it is not required to register separately with each Access provider/DLT platform.

Each Principal Entity needs to register only once with any of the Access Provider to obtain an Entity ID.

A Principal Entity (PE) can register using the following steps:

i. Visit DLT platform (Hyperlink) and select to sign up as an Enterprise.

ii. Provide valid business PAN, details of authorised person (mobile no. & email ID), business proofs and upload the documents and then pay the registration fee.

iii. Entity registrar will validate and verify details provided by the Principal Entity within 72 working hours.

iv. On successful registration, the entity registrar will approve, register and activate the Entity ID on DLT.

v. The registrar function will inform successful renewal or any discrepancy, i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

vi. Post PE ID activation, each Principal Entity can login to the portal and carry out its functions as per business requirement.

vii. In case the Entity fails to submit requested documents or address queries raised by Registrar within 15 working days, the account will be deleted. In such a scenario, Entity has to create a new account from the beginning.

Mandatory documents are as follows:

i. Govt. registered entity - Letter of Intent/ Agreement issued by the Govt. of India or State Govt.

ii. SEBI registered entity - Certificate of registration issued by SEBI as well as Entity validation on SEBI portal

iii. POI of authorised person.

iv. LOA addressed to TM.

Yes, it is necessary for a Principal Entity to define its line of business. Entity can choose from the list of options during the singup process.
No, a Principal entity cannot send commercial communication related to other line of business as regulation mandates that the content of commercial communication must be aligned to the line of business of the Principal Entity
The validity of a Principal Entity (PE) registration is 1 Year. PE can renew post expiry based on terms and conditions prevailing at that time. A grace period of 30 days will be given.

A Principal Entity can add, modify/ remove a telemarketer in the following ways:

i. Visit Trubloq (Hyperlink) and login to access Principal Entity portal with registered login credentials

ii. Go to telemarketer->Add a telemarketer

iii. Further, on Telemarketers page, the principal entity can select a preferred TM from the list of all registered Telemarketers (Aggregators Function and Delivery Function)

iv. Once a telemarketer is selected it gets reflected on the Manage Telemarketer (summary) page with status- 'Active'

v. Trubloq also enables the Principal Entity to modify/ remove any of the desired telemarketer by selecting the delete option

There is no limitation on the number of TMs (TM-DF/ TM-AF) registered by a Principal Entity. However, for sending commercial communication each PE shall select minimum one TM at the time of registration.

A registered telemarketer after logging into the telemarketer's portal can view and approve/ reject the request received from a principal entity for transmission of commercial communication.

Letter of Authorisation (LoA) shall be signed by authorised signatory of a principal entity to allow/ delegate select functions to a telemarketer on behalf of the entity. LOA is a mandatory document for a telemarketer to register on-behalf of a principal entity.

Important considerations in LoA:

i. Name of principal entity

ii. Name of the signatory with designation and contact details (mobile number and email)

iii. Business details and purpose for which LoA is being assigned

iv. Name of the telemarketer with details of Key Account Manager

No, a Principal entity cannot perform delivery function on its own. It has go through a RTM with delivery function to send the communication.

Yes, headers and templates registered under a Principal Entity can be used by other telemarketers managing Principal Entity's account for different functions.

Trubloq helps you track activities/ functions on real time basis and monitor performance of your RTM.

To monitor the activities/ functions performed by a telemarketer on-behalf of a principal entity, a principal entity needs to login to Trubloq (Hyperlink) using registered login credentials and view the dashboards.

Trubloq enables the Principal entity/telemarketer (on behalf of principal entity) to upload its existing customer’s consents on DLT platform. Existing consent can be uploaded by following below mentioned steps:

i. Visit Trubloq (Hyperlink) and login using registered credentials

ii. Go to consents -> Select upload

iii. Define purpose of consent, upload CSV file (sample template available on portal) and submit

As per the regulation, all Principal Entities and Telemarketers need to register on the DLT platform to facilitate commercial communication. A Principal Entity willing to perform the telemarketer function needs to register as a telemarketer (TM-DF for delivery) separately.
Yes, a Principal Entity can assign multiple telemarketers to manage their accounts for transmission of commercial communication
An Entity is typically a legal entity. If a group company has multiple legal entities under it, then every legal entity needs to be registered separately on the platform as different Principal Entity based on its line of business.

The TAT for entity registrar to approve Principal Entity/ Telemarketer on DLT platform is 72 hours from receipt of registration fees.

The registrar function will communicate successful validation or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

Trubloq empowers the Principal Entity(s) and Telemarketer(s) to manage their respective accounts, campaigns, etc. through near real time performance reports and dashboards.

TMs and PEs can view the reports/ dashboards online on Trubloq platform or choose to download the same in the available formats

Telemarketer (TM) or Principal Entity (PE) can update or modify their respective account information as per the procedure listed below:

i. Login to Trubloq (hyperlink) using TM or PE credentials

ii. Go to account settings and update account details

iii. Authenticate updated account details using OTP

iv. Entity registrar will validate and verify details as per the submitted changes/ updates within 72 hours

v. On successful update, the registrar will approve, register and renew the RTM ID on DLT platform.

vi. The registrar function will communicate successful update or any discrepancy i.e. missing document or incorrect details with the applicant on the registered E-mail and mobile number in the defined TAT (72 hours).

Trubloq enables the registered telemarketer to manage Principal Entity's account on their behalf. A telemarketer (registered on Trubloq as Aggregator and/ or delivery function) can register a Principal Entity (PE) by following below mentioned steps:

i. Visit Trubloq (Hyperlink) and login using registered Telemarketer credentials

ii. Go to Entities account (dropdown) -> Register a new Principal Entity

iii. Provide valid business PAN, details of authorised person, business details and upload business documents along with letter of authorization

iv. Pay registration fee

v. Entity registrar will validate and verify details provided by the telemarketer within 72 hours

vi. On successful registration, the entity registrar will approve, register and activate PE ID on DLT platform

vi. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

vii. Post PE ID activation, each telemarketer can carry out functions on behalf of Principal Entity as per business requirements.

Trubloq enables the registered telemarketer to manage Principal Entity's account on their behalf. A telemarketer (registered on Trubloq as Aggregator and/ or Delivery function) can register a Principal Entity by following below mentioned steps:

i. Visit Trubloq(Hyperlink) and login using registered Telemarketer credentials

ii. Click on Entities account button and select add Principal Entity

iii. Provide Principal Entity ID and letter of Authorization (LoA)

iv. Entity registrar will validate and verify details provided by the telemarketer within 72 hours

v. Upon successful registration, the entity registrar will approve access to telemarketer for managing Principal Entity account and update DLT platform

vi. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

vii. Post access approval, each telemarketer can carry out functions on behalf of Principal Entity as per business requirements

Trubloq enables a registered telemarketer to manage the account of a principal entity. and perform the following functions:

i. A telemarketer may choose to register principal entity and further manage their account for transmission of commercial communication to their subscribers

ii. The telemarketer is then eligible to register and manage headers (Sender ID) for message and/ or Caller Line Identity (CLI) for voice communication, on behalf of Principal Entity

iii. It may also register and manage consent/content templates for contracted Principal Entities.

The payments from Telemarketer(s) and Principal Entity(s) will be accepted through the following modes:

i. Online mode using payment gateway via credit cards, debit cards, net-banking, mobile wallets, etc.

ii. Offline mode: NEFT bank transfer.

PE registration fee is INR 5,000/- (one-time, non-refundable).

TM Aggregator Function: Registration fee is INR 5,000/- (one-time, non-refundable).

TM Delivery Function: Registration fee is INR 5,000/- (one-time, non-refundable) and refundable security deposit is INR 50,000/-.

Header is a unique 6-digit string created by an entity for sending commercial communication. Header should be connected to entity's business category and relevance.

As per the regulation, number series for different types of commercial communication via voice are as follows:

i. "140XX" for sending promotional messages

ii. Fixed line number series ('040', '044', '022') for sending transactional/ service messages

No. Headers are non-transferrable. However, a PE can surrender a registered header. Surrendered header is sent back to the header pool and can be allocated on request to any interested PE by header registrar

No, a Principal Entity is not allowed to block a header series for sending commercial communication.

Header is a unique 6-digit alpha string assigned to an individual, business or legal entity for sending commercial communication. Special characters such as @, $, %, &, etc. and blank space (“ ”) are not allowed.

Every principal entity or telemarketer on-behalf of principal entity need to register header with access providers as per the procedure below:

i. Login to the Trubloq using Telemarketer/Principal Entity login credentials

ii. Go to SMS headers-> Add header in header page

iii. Fill the requisite details such as content category, sender ID / header and provide details of sender

iv. Submit the request for approval and make payment through available payment modes

v. Header registrar will validate and verify details provided by the telemarketer/Principal Entity within 60 mins.

vi. On successful registration, the registrar will approve, register the header on the DLT Platform

vii. The registrar function will communicate successful renewal or any discrepancy i.e. missing document or incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

A newly registered header comes with a lifetime validity. But, if found inactive for more than 90 days, it will be sent back to the header pool and made available for others.

There is no limit on the number of headers registered by a principal entity till date. However, a minimum of one header needs to be registered by a principal entity to send commercial communication to its subscribers

Yes, there is an exclusive header list which cannot be used by a Principal Entity or Telemarketer on-behalf of a Principal Entity at the time of header registration.

The list covers different categories and may not be limited to:

i. Names of celebrities, politicians

ii. Trademarks

iii. Registered companies, brands

iv. Any obscene material

v. Govt., SEBI related headers

Yes, Trubloq enables a Principal Entity/ Telemarketer on behalf of Principal Entity to bulk upload header/ sender ID(s) for transmission of commercial communication.

Promotional Message

Promotional message means commercial communication that can be sent to a mobile subscriber whose preferences are not set (not on DND). Or, any commercial communication that an enterprise can send to an intended Recipient after taking consent to send such messages.

Header (6-digits): 565690, 787878, 987123, 555555, etc.

Sample SMS template1: Happiness Sale on 21 & 22 Dec. Get up to 71% OFF on over 100 brands. Register & get EXTRA Rs. 100/- OFF. Give missed call to 808XXXX234. TnC

Sample SMS template2: 24 Hr Kitchen Furniture SALE up to 35% OFF, till 22 Dec, T&C

Sample SMS template3: Get MY DIET by <NAME OF CONSULTANT> & lose up-to 10Kg. No exercise. No machine. First free consultation Click <URL>. To revoke consent, send SMS as REVOKE HEADER to 1909

Transactional Message

Transactional message means a message which contains One Time Password (OTP) and requires to complete a banking transaction initiated by the bank customer. This is applicable to all banks including national/ scheduled/ private/ Govt. and MNC banks.

Header (6-alpha): KLMNOP, TRUBLQ, DLTDLT, etc.

Sample SMS template1: 763892 is the OTP for trxn of INR 9876.90 at ABCD App with your card XX0000. OTP is valid for 10 mins. Pls do not share it with anyone.

Sample SMS template2: 763892 is OTP for txn of INR 373.32 at ABCD on XYZ Bank Credit Card XX0000. OTPs are SECRET. DO NOT disclose it to anyone. Bank NEVER asks for OTP.

Service Implicit Message

Service Implicit: Any messages, arising out of customer’s actions or his relationship with the Sender, that is not promotional, and is not in the interest of the customer to block such communications. These messages may or may not be triggered by a subscriber-initiated transaction and will not be blocked for subscribers who have otherwise blocked service messages also.

Confirmation messages of a net banking or a credit/debit transaction;
Product purchase confirmation; delivery status of a parcel;
OTP required for e-commerce website, app login, social media apps, KYC, etc.;
Messages from home operator; Messages from schools regarding attendance/transport;
Messages from hospitals/clinics regarding appointment/discharge reports;
Govt./TRAI/DoT mandated messages, advisories, messages from state Govt., LEAs, local
authorities, traffic advisories, election commission, disaster management advisories;
Service messages from car workshops, gadget service centers;
Day-end/ month-end settlement alerts to securities/demat account holders.

Header (6-alpha): ABCDE, AFIOMA, UNFOCO, etc.

Sample SMS template1: Hello! Your A/C no. <XXXXX> has been debited by Rs. <XXXX> The A/C balance is Rs. <XXXX> on <DD/MM/YY> The A/C balance is Rs. <XXXX> Info: <TYPE>/<PURPOSE>/< Rs.  of template OR REFERENCE NUMBERs

Sample SMS template2: Dear Customer, as per your request, contact details have been updated against your fixed deposit account.

Sample SMS template3: Dear Customer, your order has been picked up by the delivery boy and is on his way. Your delicious pizza is reaching early!

Service Explicit Message

Any service message which doesn’t fall under the category of service message (Implicit) will be sent only against service explicit, digitally verified/verifiable consent that has been taken from the subscriber by the respective enterprise.

Header (6-alpha): NUTUKI, PRIZEM, ZSERTA, etc.

Sample SMS template1: Dear Customer, Congratulations on your Home Anniversary! Now avail a Top-up up to Rs 50 lacs* with ROI @9.20%* on your Home Loan. Call Toll Free 1800XXXXX00 *T&C

Sample SMS template2: Dear , based on your relationship, we are approving a per-approved Home Loan up to Rs. 1 crore. Click here https://www.domain.com/ . Regards, QT Housing. T&C.

Subscriber can register preferences with respect to time band for receiving commercial communication as follows Time band:

a. 00:00 hrs to 06:00 hrs

b. 06:00 hrs to 08:00 hrs

c. 08:00 hrs to 10:00 hrs

d. 10:00 hrs to 12:00 hrs

e. 12:00 hrs to 14:00 hrs

f. 14:00 hrs to 16:00 hrs

g. 16:00 hrs to 18:00 hrs

h. 18:00 hrs to 21:00 hrs

i. 21:00 hrs to 24:00 hrs

The default preference of time band for receiving commercial communication is 10:00 hrs to 21:00 hrs

Default status of preferences for subscribers who are not registered on DND is "Unblock all" i.e. receive commercial communication all categories of content, mode, time band (10 am - 9pm only) and day types.

Any consent that has been verified directly from the subscriber/ recipient in a robust and verifiable manner and recorded by consent registrar is known to be explicit in nature.

Example:

Any individual who registers his/ her e-mail Id on a website to receive newsletters/ information about new products and services.

Whereas, an inferred consent is any permission that can be reasonably inferred from the subscriber's conduct or the relationship between the subscriber and the telemarketer/ principal entity.

Example: An individual takes personal loan from a bank and receives messages related to loan settlement.

Yes, consent given to principal entity will override preference set by subscriber for service and promotional communication. For example, if a consumer blocks retail as category in his preferences, but has given a consent to Nature's Basket, he will receive communication from Nature's Basket.

Service (explicit consent) and Promotional messages are subject to preference and consents of a subscriber. However, Service (inferred consent) and Transactional messages are not subject to subscriber preference or consent.

No, government entities do not need to acquire subscriber consents. Any message or voice calls transmitted on the directions of the Central Government or the State Government or bodies established under the Constitution, when such communication is in Public Interest are not subject to user consents or preferences.

However, Govt. limited companies e.g.- PSUs, Banks etc. need to take subscriber's consent prior sending notifications to them.

Consent is a voluntary permission given by mobile subscriber to a entity/ enterprise to receive commercial communication related to specific purpose, product or service. Consent is given only for Promotional and Service Explicit messages. Consent is not required for Transactional and Service Implicit messages.

Yes, it is mandatory for Principal Entity(s) to get subscriber's consent digitally authenticated via OTP.

However, at inception the Principal Entities can migrate existing consents for existing entities, processes and data. Migrated consent recorded under existing regulations are valid for maximum six months, after this time period consent to remain valid only after renewing it for next 12 months.

A telemarketer/ principal entity can acquire subscriber consents from the following modes-

i. SMS

ii. Web

iii. Mobile app

The validity of an acquired consent is 12 months.

Yes, a subscriber can register his/her consent for preferred Principal Entity by visiting the website of the desired Principal Entity, providing basic subscriber details and digitally authenticating via OTP.

A unique reference number is generated and communicated to the subscriber on the registered e-mail and mobile number with implementation timelines.

For a telemarketer/ principal entity, it is required to register consent template on DLT platform to acquire consent from new subscribers prior to transmission of commercial communication.

To register a consent template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to Trubloq using telemarketer/ principal entity credentials

ii. Go to Consent template -> Add new template

iii. Provide template label, content of message and purpose of consent

iv. Further, provide details to revoke the consent and submit

v. Consent template registrar will validate and verify details provided by the telemarketer/principal entity within 60 mins

vi. On successful registration, the consent template registrar will approve and register consent template ID on DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy in case of incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

To de-register a consent template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to Trubloq using telemarketer/ principal entity credentials

ii. Go to Consent template -> Select the template -> Delete

For a principal entity it is required to register consent template on DLT platform to acquire consent from new subscribers prior to transmission of commercial communication.

To register a content template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to DLT using telemarketer/ principal entity credentials

ii. Go to Content template -> Add new content template

a. Define template type – Promotional/Transactional/Service

iii. Select category of content and a registered header

iv. Provide content for fixed part and demarcate variable content in the template using insert variable button

v. Submit template for verification

vi. Content template registrar will validate and verify details provided by the telemarketer/ principal entity within 60 mins

vii. On successful registration, the content template registrar will approve and register content template ID on DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy in case of incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

Once the template is registered, only the variable part of template can be changed, however, a Principal Entity can register multiple templates as per business requirements.

A Principal Entity is eligible to register multiple headers and multiple templates under each header. Example: For a Principal Entity with different departments, it may register multiple headers for each department and further, multiple templates can be registered under each header.

All languages that support unicode functionality.

Currently, only english language is supported to register a consent template.

A consent template is tagged with a header, hence cannot be used with multiple headers. A content template can be used with multiple headers.

No, each commercial communication is scrubbed for header and templates (consent/ content) and hence the same cannot be changed for scrubbed data prior to delivery.

If any parameter of the scrubbed data needs to be changed, the message/ call shall be scrubbed again.

No, preference and consent database will not be accessible to Telemarketers due to secure controls and use of Blockchain technology on DLT platform.

Headers and templates are linked to the Sender/ Principal Entity under which they are registered (whether registered by Principal Entity or by telemarketer on behalf of Principal Entity), therefore, they are not detained while removing a telemarketer.

Yes, if the commercial communication is not in line with subscriber's consent and preference or does not adhere to the regulation, the Principal Entity will be penalised.

Access Provider


Yes, all Telemarketers need to register with Originating Access Provider's DLT platform to be able to deliver commercial communication.
No, as per the regulation, it is mandatory for a Telemarketer to register on DLT platform for the purpose of facilitating commercial communication.
Yes, registered telemarketer (RTM ) ID is unique across all access providers/ DLT platforms.
No, a telemarketer needs to register only once with the OAP's DLT platform to generate RTM ID. This ID is shared across all the platforms seamlessly.

For a telemarketer/ principal entity, it is required to register consent template on DLT platform to acquire consent from new subscribers prior to transmission of commercial communication.

To register a consent template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to Trubloq using telemarketer/ principal entity credentials

ii. Go to Consent template -> Add new template

iii. Provide template label, content of message and purpose of consent

iv. Further, provide details to revoke the consent and submit

v. Consent template registrar will validate and verify details provided by the telemarketer/principal entity within 60 mins

vi. On successful registration, the consent template registrar will approve and register consent template ID on DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy in case of incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

For a principal entity it is required to register consent template on DLT platform to acquire consent from new subscribers prior to transmission of commercial communication.

To register a content template, a principal entity or telemarketer need to follow below mentioned steps:

i. Login to DLT using telemarketer/ principal entity credentials

ii. Go to Content template -> Add new content template

a. Define template type – Promotional/Transactional/Service

iii. Select category of content and a registered header

iv. Provide content for fixed part and demarcate variable content in the template using insert variable button

v. Submit template for verification

vi. Content template registrar will validate and verify details provided by the telemarketer/ principal entity within 60 mins

vii. On successful registration, the content template registrar will approve and register content template ID on DLT platform

vii. The registrar function will communicate successful renewal or any discrepancy in case of incorrect details with the applicant on the registered e-mail and mobile number in the defined TAT (72 hours).

No, preference and consent database will not be accessible to Telemarketers due to secure controls and use of Blockchain technology on DLT platform.

To scrub messages, a telemarketer has to follow below mentioned procedure:

i. Login using registered credentials

ii. Go to scrubber -> Create a scrubbing list

iii. Provide details of registered header and template

iv. Provide content for variable part for the template

v. Upload target list in CSV format

Telemarketer can choose to perform one of the following actions:

i. Scrub and Deliver (Both actions using the OAP)

ii. Scrub and Generate Ref# (Scrubbing through one operator and generate Ref#, that can be used for delivery using another operator)

iii. Deliver from Ref# (Bring the scrubbed file from one operator and deliver through another operator)

Scrubbed file is valid till 23:59:59.

A report will be generated after every scrubbing with success %. Only the count is shares, and not the actual mobile numbers.

Delivery acknowledgement report will be generated only for Transactional and Service Implicit messages.

The different scenarios leading to blacklisting of a telemarketer are as under:

i. Sending continuous UCC messages to subscribers

ii. Failure to produce relevant business information, agreements

iii. Submission of fraudulent documents while registering on DLT platform

Also, a telemarketer may face hefty penalties on violations to the regulations such as:

i. Restrict provision of telecom resource to a blacklisted telemarketer by any access provider during the period of blacklisting

ii. Names of the blacklisted telemarketers will be communicated to all access providers

Mobile Subscriber


Any consent that has been verified directly from the subscriber/ recipient in a robust and verifiable manner and recorded by consent registrar is known to be explicit in nature.

Example:

Any individual who registers his/ her e-mail Id on a website to receive newsletters/ information about new products and services.

Whereas, an inferred consent is any permission that can be reasonably inferred from the subscriber's conduct or the relationship between the subscriber and the telemarketer/ principal entity.

Example: An individual takes personal loan from a bank and receives messages related to loan settlement.

Yes, consent given to principal entity will override preference set by subscriber for service and promotional communication. For example, if a consumer blocks retail as category in his preferences, but has given a consent to Nature's Basket, he will receive communication from Nature's Basket.
Consent is a voluntary permission given by mobile subscriber to a entity/ enterprise to receive commercial communication related to specific purpose, product or service. Consent is given only for Promotional and Service Explicit messages. Consent is not required for Transactional and Service Implicit messages.
The validity of an acquired consent is 12 months.

To opt-in or register a consent to receive commercial communication, a subscriber can follow one of these modes:

i. SMS: Respond "OPT-IN" to the consent acquisition message received from entity on < XXXX >

ii. Web/ App: Provide consent on the web portal or mobile application of the desired Principal Entity through one time password (OTP) authentication

To revoke a registered consent, subscriber can use one of the below steps:

i. SMS: Send "REVOKE" or "OPT-OUT" to < XXXX > (as defined in consent acquisition message)

ii. IVRS: Call Access Provider's customer support and request to revoke consent by providing Entity/Header details.

iii. Web/ App: Login to web portal or mobile application of Entity and revoke using OTP authentication by going to consent page.

Trubloq enables the subscribers to view the summary of their active/revoked consents. Kindly follow the below mentioned steps to view your summary:

i. Visit Trubloq and login using registered MSISDN (phone number) and OTP

ii. Go to Consent -> View summary of active and revoked consents

As per the regulation, TRAI has suggested to fix a deadline for expiry of consent not registered with consent registrar

TRAI in its code of practice (CoP), has defined the validity of existing consent as up to 6 months. All Principal Entities willing to send commercial communication through Trubloq needs to get their subscribers consents digitally verified within 6 months.

Yes, a subscriber can register his/her consent for preferred Principal Entity by visiting the website of the desired Principal Entity, providing basic subscriber details and digitally authenticating via OTP.

A unique reference number is generated and communicated to the subscriber on the registered e-mail and mobile number with implementation timelines.

Yes, your preferences registered on DND (NCPR - National customer preference register) portal are still valid and these would be migrated to Trubloq.

To view the current status of your preference or to modify your preference, kindly visit Trubloq (Hyperlink) and sign in using your mobile number.

You can register/ modify your preference(s) using the following available modes:

i. Trubloq web portal or mobile application: Visit Trubloq web portal () / mobile app. Sign in using your mobile number to register/ modify your preferences.

ii. SMS: Send preference request in a standard format () to 1909.

iii. USSD: Send preference request by short code in standard format ()

iv. IVRS/ Voice Call: Request to modify preference by calling 1909.

On receipt of valid request, an acknowledgement message is sent to with a unique request number to subscriber on registered mobile number and email along with its timelines, confirmation and final status along with options to unblock;

Available categories for preference modification are as follows:

i. Content category:

a. Banking/Insurance/Financial products/ credit cards,

b. Real Estate

c. Education

d. Health

e. Consumer goods and automobiles

f. Communication/Broadcasting/ Entertainment/ IT

g. Tourism and Leisure

h. Food and Beverages

ii. Mode of commercial communication:

a. Voice call

b. SMS

c. Auto dialer call (with pre-recorded announcement)

iii. Time band:

a. 00:00 hrs. to 06:00 hrs.

b. 06:00 hrs. to 08:00 hrs.

c. 08:00 hrs. to 10:00 hrs.

d. 10:00 hrs. to 12:00 hrs.

e. 12:00 hrs. to 14:00 hrs.

f. 14:00 hrs. to 16:00 hrs.

g. 16:00 hrs. to 18:00 hrs.

h. 18:00 hrs. to 21:00 hrs.

i. 21:00 hrs. to 24:00 hrs.

iv. Day-type:

a. Monday

b. Tuesday

c. Wednesday

d. Thursday

e. Friday

f. Saturday

g. Sunday

h. Public holiday and National holiday

There is no limitation to number for preference modification. However, the preference modified by the subscriber are made to effect in near real time and in such manner that no delivery of commercial communication is made or blocked in contravention to subscriber's preference after twenty four hours.

Trubloq enables the subscribers to view their preference modification summary. Kindly follow the below mentioned steps to view your summary:

i. Visit Trubloq and login using registered MSISDN (phone number) and OTP

ii. Go to Preference -> View preference modification summary

FULLY BLOCK option shall put the customer in Fully Blocked state and block service as well as promotional types of commercial communications for all categories of content, mode, time band and day types

BLOCK PROMO option shall block only promotional types of commercial communications for all categories of content, mode, time band and day types except service and transaction type of commercial communications.

Yes, you need to register preferences separately for each mobile number.

No, each preference registration or modification needs to be digitally authenticated using OTP and hence needs to be done by subscriber using the same mobile number for which preferences need to be registered/ modified.

Trubloq enables the subscribers to track status of logged complaints. To view status of logged complaints, follow below mentioned steps:

i. Visit Trubloq and login using registered MSISDN (phone number) and OTP

ii. Go to Complaints -> view status of logged complaints

Yes, a subscriber can register complaints against UCC received from a 10 - digit mobile number

Currently, there is no procedure in place for re-opening of a closed complaint, however, a subscriber can escalate the complaint if he/ she is not satisfied with the resolution.

Currently there is no provision to amend a registered complaint so, a subscriber needs to raise a separate complaint.

Trubloq enables the subscriber to escalate his/her existing complaint. To escalate:

i. Visit Trubloq (hyperlink) and login using OTP

ii. Go to complaints -> Select existing complaint and escalate by providing relevant information

No, there is no limitation to number of complaints logged by a subscriber. However, if a complaint is found to be duplicate, notification of inability to process complaint will be shared with the subscriber along with the status of previously logged complaints.

If the subscriber is not satisfied by the resolution of a complaint, he/she can escalate the complaint through his/her login.

Registrar


For a principal entity it is required to register consent template on DLT platform to acquire consent from new subscribers prior to transmission of commercial communication.
Yes, if the commercial communication is not in line with subscriber's consent and preference or does not adhere to the regulation, the telemarketer will be penalised.

The different scenarios leading to blacklisting of a telemarketer are as under:

i. Sending continuous UCC messages to subscribers

ii. Failure to produce relevant business information, agreements

iii. Submission of fraudulent documents while registering on DLT platform

Also, a telemarketer may face hefty penalties on violations to the regulations such as:

i. Restrict provision of telecom resource to a blacklisted telemarketer by any access provider during the period of blacklisting

ii. Names of the blacklisted telemarketers will be communicated to all access providers

Yes, if the commercial communication is not in line with subscriber's consent and preference or does not adhere to the regulation, the Principal Entity will be penalised.