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DNC Compliance:
Do-Not-Call compliance requires a partnership effort between any teleservices vendor and their client. The list owner (you) are required to determine whether or not you are required to use the Federal Trade Commission's Do-Not-Call registry to "scrub" names from your list.  Paragraph 310.6 of the Telemarketing Sales Rule defines organizations who are exempt from registering with and using the federal Do-Not-Call list. In addition, there may be separate and different Do-Not-Call requirements in your state.

The Telephone Consumer Protection Act (TCPA) of 1991 requires each company that makes telephone solicitations to maintain a list of those people who do not wish to be contacted by phone and to develop a written policy implementing this Do-Not-Call list-keeping requirement. The term "telephone solicitation" does not include calls or messages placed with the receiver's prior expressed permission, by or on behalf of a tax-exempt non-profit organization, or from a person or organization with whom the receiver has an established business relationship.

Although DirectLine Technologies, Inc does not own or maintain telemarketing lists, we have implemented strong internal policies and procedures, implemented within our technology, to insure compliance with Do-Not-Call regulations. DirectLine maintains a corporate Do-Not-Call database.  Any individual who makes a request to be placed on a Do-Not-Call list is maintained on our corporate Do-Not-Call List for a period of five (5) years from the date of the request.  Numbers on our corporate Do-Not-Call list are not called within the five year period, regardless of the client project being dialed.

Each and every Do-Not-Call request is captured on-line during the telephone conversation in which the request is made. The Do-Not-Call refusal flag is appended to the record, the record will be blocked from additional calling, and no additional calls will be made to the phone number that was requested to be placed on the Do-Not-Call list. Individuals who dial the caller-id number shown with calls originating from DirectLine Technologies can use our automated touch-tone system to place their called number (identified by their caller-id) on our Do Not Call list.

The Do-Not-Call requests will be reported electronically to the list owner (you) at the end of the solicitation project. The complete project data, including Do-Not-Call notations, will be forwarded to the list owner in the format they request, as well as archived on storage CD.

HIPAA Compliance:
Your institution's Notice of Privacy Practices is a statement that outlines how medical record information will be used and the limitations upon its use. A covered entity may not use or disclose PHI in a way that is not mentioned in the Notice. Relative to philanthropy, the Notice of Privacy Practices must contain a sentence about contacting individuals to raise funds. The regulations impose many specific requirements, and care must be taken in drafting the Notice. The Notice of Privacy Practices must be made available to patients. Your institution must post the Notice of Privacy Practices on its Web site and make it available electronically, and post it in prominent places inside the institution. You can also include it in newsletters or other communication vehicles.

The Opt-out Requirement: An opt-out clause relating to fund-raising must be included in all solicitations to satisfy the regulations, and must be included in all solicitations. For the purposes of telephone solicitation the Opt-out requirement is met if a prospective donor asks to be placed on a do-not-solicit list, and is recorded and reported to your organization (the list owner) as such.

E-mail solicitations must include a written opt-out statement such as the following which is recommended by AP: "Please write to us at our address if you wish to have your name removed from the list to receive fund-raising requests supporting (name of entity) in the future."
Your organization (the list owner) must also institute a system that will track opt-outs and follow up to ensure that any individual that has opted out is in fact removed from fund-raising lists.

Company Practices:
DirectLine Technologies, Inc. is committed to ensuring that every employee complies with ethical telephone solicitation practices on behalf of exempt and non-exempt clients, including adherence to all federal and state legislation governing teleservices practices.

DirectLine Technologies, Inc. is committed to ensuring with reasonable certainty that:

bullet At the commencement of each call in which an individual answers the phone, employees clearly state their name, the organization they are calling on behalf of, and follow the script word-for-word that has been provided to them.
bullet Telephone calls placed or received will be conducted in an honest and courteous manner, so as to respect both the constituent and the client. Harassment or excessive pressure will not be tolerated.
bullet During a call, all information conveyed will be truthful and all questions will be honestly answered. Employees will not knowingly misrepresent a nonprofit organization's mission, accomplishments, or plans for the future; nor knowingly create confusion between the nonprofit client's identity and that of any other nonprofit, governmental, or private organizations. Misrepresentation of how any funds raised will be used will not be tolerated.
bullet Information received during the course of calls will be used only for purposes for which it was provided and authorized.
bullet Employee calls will be monitored and recorded as DirectLine Technologies, Inc. deems fit to enforce teleservices policies.
bullet Calls will be placed only during prescribed hours (8:00 AM - 9:00PM in any time zone.)
bullet Neither the public nor our clients will be intentionally misled.
bullet Consumer requests, during a call, to be placed on a client's "DO NOT CALL" list will be placed into effect within the required thirty days, and provided to the client in a timely manner.
bullet Requests to be placed on DirectLine's "DO NOT CALL" list will be honored within the prescribed 30-days.
bullet As a condition of employment, all employees will be required to sign individual commitments in which they agree to follow prescribed practices while working for DirectLine Technologies, Inc.
DirectLine Technologies' dialers transmit caller ID information as required by law. DirectLine's predictive dialing technology uses intelligent self-paced real-time monitoring to insure that fewer than 3% of calls are abandoned, and can deliver a prerecorded identification message when abandoning the call.
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