TCPA Consent Evidence Checklist

What counts as consent, evidence hierarchy, and documentation requirements

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What Counts as Consent Under TCPA

Key Principle: The type of consent required depends on (1) the technology used and (2) the purpose of the communication. Telemarketing calls/texts using automated systems require the highest level: prior express WRITTEN consent.

Consent Types Overview

Communication Type Consent Required Key Elements
Marketing calls/texts via ATDS or prerecorded voice Prior Express Written Consent Signed (including electronic), specific disclosure, not required as condition of purchase
Informational/transactional calls via ATDS Prior Express Consent Can be oral or written; person gave you the number for this purpose
Manual calls (not ATDS) - non-DNC No TCPA consent needed But check state laws and DNC rules
Calls to numbers on National DNC Prior Express Invitation/Permission or EBR Written permission OR established business relationship

Prior Express Consent (Non-Telemarketing)

Definition

The consumer has given their phone number to you with the understanding that you may contact them. This consent can be oral or written.

Sufficient Evidence

  • Customer provided number during transaction - Sign-up form, order form, account creation
  • Number provided with context - "Contact me regarding my order"
  • Oral consent (harder to prove) - Recorded call where customer provides number and agrees to contact

Scope Limitations

  • Consent is limited to the purpose for which number was provided
  • Order confirmation consent does NOT extend to marketing
  • Consent to one company does NOT transfer to affiliates without disclosure
Common Mistake: Assuming that having someone's number in your CRM = consent. The question is: did they give it to you for the purpose you're using it?

Prior Express Written Consent (Telemarketing)

Definition

A written agreement (paper or electronic) bearing the signature of the consumer that clearly authorizes telemarketing calls using automated technology.

Required Elements (47 CFR 64.1200(f)(8))

  • Written agreement - Paper document, webform, or electronic record
  • Signature - Handwritten, electronic (E-SIGN compliant), or checkbox click
  • Clear authorization - Must specifically authorize telemarketing calls
  • Telephone number disclosure - Consumer provides the number to be called
  • Automated technology disclosure - Consumer understands calls may use autodialer or prerecorded voice
  • Not a condition of purchase - Cannot require consent to complete transaction

Example Compliant Disclosure Language

"By providing your phone number and checking this box, you agree to receive marketing calls and text messages from [Company] at the number provided, including calls made using an automated dialing system or prerecorded voice. Consent is not a condition of any purchase. Message and data rates may apply."

Revocation of Consent

How Consent Can Be Revoked

Consumers can revoke consent through any reasonable means. You cannot limit revocation to specific channels.

  • STOP or UNSUBSCRIBE - Text response must be honored
  • Verbal request - "Please stop calling me"
  • Written request - Email, letter, webform submission
  • Account settings - Changing communication preferences

Revocation Timing

  • Must be honored within reasonable time (FCC suggests 10 business days max)
  • Best practice: Process STOP requests within 24-48 hours
  • Any calls/texts after revocation = new violations
Post-Revocation Calls Are High Risk: Calling after a clear STOP request often triggers willful violation status ($1,500 per call) because you had actual notice.

Consent Does NOT Transfer

Scenario Consent Status
Company A acquired Company B; calling B's customer list May not have consent unless B's disclosure covered "affiliates"
Lead purchased from third party Need proof the lead seller obtained proper consent for YOUR calls
Phone number reassigned to new person No consent from new subscriber - reassigned number liability
Customer gave number 5 years ago May still be valid, but revocation risk increases over time

Evidence Hierarchy

Burden of Proof: In TCPA litigation, the defendant bears the burden of proving consent. This means you must have affirmative evidence - "I don't have records they didn't consent" is not a defense.

Evidence Strength Tiers

STRONG Gold Standard Evidence

Highest likelihood of prevailing on consent defense

  • Timestamped webform submission with consent checkbox
  • IP address and browser fingerprint
  • Screenshot or archived version of form
  • Signed paper agreement with TCPA disclosure
  • Recorded call with verbal consent (two-party states: with consent)
MEDIUM Supportive Evidence

Helpful but may require additional corroboration

  • CRM record showing consent checkbox marked
  • Lead seller attestation without underlying proof
  • System logs showing form submission (without content)
  • Customer service notes referencing consent
  • Email confirmation sent after consent
WEAK Insufficient Evidence

Unlikely to sustain consent defense alone

  • Number exists in database (no consent record)
  • Customer made a purchase (no call consent)
  • Privacy policy says "we may contact you"
  • Pre-checked consent boxes
  • Consent buried in terms of service

Strong Evidence: What Makes It Strong

Timestamped Webform with Checkbox

Element What to Capture Why It Matters
Timestamp Exact date/time of submission (UTC preferred) Proves consent was given before calls were made
Phone number Number as entered by user Connects consent to specific number
Consent checkbox state Record whether box was checked Proves affirmative action, not pre-checked
Disclosure text Exact language shown to user Proves proper disclosure was made
IP address User's IP at time of submission Helps verify identity; detects fraud
Form version/URL Which form was used If forms change, proves which version user saw

Best Practice: Consent Packet

Create a "consent packet" for each lead/customer that includes:

  • Screenshot or archived HTML of the consent form
  • Database record of the submission with all captured fields
  • System logs showing the submission event
  • Confirmation email sent to customer
  • Any subsequent consent modifications or revocations

Medium Evidence: Strengthening Weak Records

CRM Consent Fields

CRM records showing "consent = yes" are helpful but not sufficient alone because:

  • They can be manually edited
  • They don't show what the person actually saw/agreed to
  • They may lack timestamps
Strengthening CRM Evidence:
  • Add source field (webform ID, campaign, lead source)
  • Capture submission timestamp separately from record creation
  • Store archived form version reference
  • Implement audit trails showing when consent field was set

Lead Seller Attestations

When purchasing leads, the lead seller's consent claim is only as good as their documentation.

  • Ask for: Copy of consent form, sample consent record, certification letter
  • Contractually require: Indemnification, consent documentation on request
  • Verify: Spot-check leads by asking seller for specific consent proof

Weak Evidence: Why It Fails

Number in Database (No Consent Record)

"We have their number" proves nothing about consent. They may have:

  • Given it for a different purpose
  • Been added by third party without consent
  • Revoked consent later
  • Never given consent at all (data entry error, scraping)

Pre-Checked Boxes

Pre-checked consent boxes do not satisfy TCPA requirements. The FCC has been clear that consent must be an affirmative act. Pre-checked boxes are passive, not affirmative.

Buried Terms of Service

Consent language hidden in a Terms of Service document that users scroll past is generally insufficient because:

  • No proof user read the specific provision
  • Not "clear and conspicuous" as required
  • May not meet "separate agreement" requirements for written consent

Evidence Reconstruction

If you don't have strong evidence but need to defend a claim:

Circumstantial Evidence

  • Form version history: What did the form look like when this person signed up?
  • Industry practice: What was standard consent capture in your industry at the time?
  • System capabilities: What fields did your system capture by default?
  • Customer testimony: Does the customer acknowledge signing up?

Wayback Machine / Archive.org

If your website forms were captured by Archive.org, you may be able to show what disclosure language appeared on your forms at the time of consent.

Platform-Specific Logs

Export Now, Ask Questions Later: Most platforms have retention limits (30-90 days for detailed logs). Export everything related to the claimant immediately, even before you know what's relevant.

SMS/Text Platforms

Twilio

Where to Find: Console > Monitor > Logs > Messages

What to Export:

  • MessageSid - Unique message identifier
  • DateSent - Timestamp of message
  • To / From - Phone numbers
  • Body - Message content
  • Status - Delivered, failed, etc.
  • ErrorCode - If delivery failed, why

Retention: 13 months via API, then archived (may require support request)

Export Method: Use API or export CSV from console

EZTexting / SimpleTexting / Similar

Where to Find: Reports > Message History or Contacts > Individual Contact

What to Export:

  • Full message history for the phone number
  • Opt-in date and source
  • Opt-out date (if any)
  • Keyword responses (STOP, HELP, etc.)
  • Campaign/group assignments

Retention: Varies; typically 12-24 months

Klaviyo (SMS)

Where to Find: Profiles > Search phone number > Activity Feed

What to Export:

  • SMS consent status and date
  • All SMS sent/received
  • Consent source (form, import, etc.)
  • Suppression status

Key Field: $consent_timestamp for SMS consent date

Dialer Platforms

Five9 / RingCentral / Dialpad

Where to Find: Reports/Analytics section; Call Detail Records (CDR)

What to Export:

  • Call date, time, duration
  • Caller ID / ANI used
  • Destination number (DNIS)
  • Call disposition/outcome
  • Agent ID (if not automated)
  • Campaign/queue assignment
  • Recording file reference (if calls recorded)

Critical: Export dialer configuration showing whether ATDS features were used

CallFire / CallHub

Where to Find: Results/Reports for each campaign

What to Export:

  • Broadcast/campaign details
  • Call results by phone number
  • DNC/opt-out list membership
  • Audio file for prerecorded messages
  • Upload source for contact lists

CRM Systems

Salesforce

Where to Find: Contact/Lead record; Field History; Activity History

What to Export:

  • Contact record with all custom fields
  • Lead source and creation date
  • Consent-related custom fields (opt-in, consent date, source)
  • Field history tracking for consent fields
  • Activity timeline (calls, emails logged)

Best Practice: Enable Field History Tracking on consent fields

HubSpot

Where to Find: Contact record; Form submissions; Communication preferences

What to Export:

  • Contact property history (shows when values changed)
  • Form submissions with timestamps
  • Communication subscription status
  • Legal basis for processing (if using GDPR features)

Key Report: "Contact property history" shows audit trail

Marketing Automation

ActiveCampaign / Mailchimp / Constant Contact

What to Export:

  • Subscriber profile with signup date and source
  • Signup form used (and form archive/version)
  • IP address at signup
  • Automation/campaign history
  • Unsubscribe/complaint records

Export Checklist by Platform Type

Platform Type Priority Exports Retention Risk
SMS Platform Message logs, opt-in/opt-out dates, message content Often 30-90 days for content; longer for metadata
Dialer/Call Platform CDRs, campaign config, DNC lists, recordings Recordings often 30-90 days; CDRs longer
CRM Contact record, field history, lead source Usually persistent but check archival policies
Web Forms Form submissions, form version/screenshots Submissions usually persistent; form versions may not be
Lead Vendor Portal Lead records, consent certificates, purchase receipts Highly variable; request immediately

Vendor Records to Request

Vendor evidence serves two purposes: (1) Supporting your consent defense and (2) Triggering indemnification obligations if the vendor's consent was defective.

Lead Seller Documentation

Immediate Requests to Lead Sellers

  • Consent record for specific lead - Timestamped proof this person consented on seller's form
  • Copy of consent form/page - Screenshot or archived version of what consumer saw
  • Consent language used - Exact disclosure text at time of consent
  • Source URL - Where was the form hosted?
  • IP address at consent - Consumer's IP when submitting form
  • Lead chain of custody - Did seller generate lead directly or buy from another party?

Lead Purchase Agreement Review

Pull your agreement with the lead seller and identify:

  • Consent warranties - What did seller represent about consent quality?
  • Indemnification clause - Does seller indemnify you for TCPA claims?
  • Consent documentation obligations - Is seller required to provide proof on request?
  • TCPA compliance representations - Did seller certify TCPA compliance?
  • Notice requirements - How must you notify seller of claims to trigger indemnity?
Indemnification Trigger: Many agreements require timely notice to preserve indemnification rights. Send written notice to vendor immediately upon receiving a TCPA demand, even before investigating.

Marketing Agency Records

If Agency Managed Campaigns

  • Campaign documentation - What campaigns did they run? What lists did they use?
  • List source - Where did agency get the phone numbers?
  • Scripts and content - What messages were sent?
  • Consent verification process - How did agency verify consent before calling?
  • Platform access - Can they export detailed logs from platforms they used?
  • Subcontractors - Did agency use any sub-vendors for calling/texting?

Agency Agreement Review

  • Scope of authority - What was agency authorized to do?
  • Compliance obligations - Who was responsible for TCPA compliance?
  • Indemnification - Does agency indemnify for their actions?
  • Insurance - Does agency carry E&O or liability coverage?

Dialer/Platform Vendor Records

Technology Documentation

  • System capabilities statement - Does vendor certify ATDS or non-ATDS status?
  • Configuration documentation - How was your instance configured?
  • DNC integration - How does system handle DNC scrubbing?
  • Opt-out processing - How are STOP requests handled?

Indemnity Tender Process

When to Tender

  • Immediately upon receiving demand - Don't wait until you've investigated
  • Before settling - Vendor may want to participate in defense/settlement
  • Per contract requirements - Check notice deadlines in your agreement

Tender Letter Elements

[YOUR COMPANY]
[Address]

[Date]

VIA EMAIL AND CERTIFIED MAIL

[Vendor Legal Name]
[Address]
Attn: Legal Department / Compliance

Re: Notice of TCPA Claim and Tender of Defense - [Claimant Name]

Dear [Vendor]:

Pursuant to Section [X] of the [Agreement Name] dated [date] between [Your Company] and [Vendor], we hereby provide notice of a claim and tender defense.

The Claim:

We have received a demand letter dated [date] from [Claimant/Counsel] alleging violations of the Telephone Consumer Protection Act arising from [calls/texts] made to [phone number]. A copy of the demand is attached.

Vendor's Involvement:

Our records indicate that [describe vendor's role: "the phone number at issue was obtained through leads purchased from Vendor" / "the calls were made using Vendor's dialing platform" / "the campaign was managed by Vendor"].

Contractual Obligations:

Under Section [X] of our Agreement, Vendor represented and warranted [quote relevant warranty]. Under Section [Y], Vendor agreed to indemnify [Your Company] for claims arising from [quote indemnification scope].

Requests:

  1. We request immediate production of all documentation related to [consent for this lead / this campaign / calls to this number], including but not limited to consent records, form screenshots, timestamps, and IP addresses.
  2. We tender defense of this claim to Vendor pursuant to the indemnification provisions of our Agreement.
  3. Please confirm within ten (10) days whether Vendor accepts the tender and will assume defense.

Reservation of Rights:

This notice is provided to preserve our contractual rights. We reserve all claims against Vendor including but not limited to breach of warranty, indemnification, and contribution.

Please direct all responses to [contact].

Sincerely,

[Name, Title]

Enclosure: Copy of TCPA demand letter

What If Vendor Doesn't Cooperate?

  • Document all requests - Keep records of every request and non-response
  • Escalate internally - Contact vendor's legal or compliance team directly
  • Review contract remedies - May be able to withhold payments or terminate
  • Litigation discovery - If suit is filed, subpoena vendor's records
  • Third-party claim - May need to file cross-claim or separate action against vendor

Preservation Checklist

Spoliation Warning: Destroying, altering, or failing to preserve relevant evidence after receiving a demand can result in adverse inference (jury assumes destroyed evidence was harmful), sanctions, and separate liability. Take preservation seriously.

Litigation Hold Basics

What Is a Litigation Hold?

A directive to preserve all documents and data that may be relevant to anticipated or pending litigation. It overrides normal retention/deletion policies.

When to Implement

  • Upon receiving demand letter - Litigation is reasonably anticipated
  • Upon receiving lawsuit - Definitely implement if not already
  • Upon learning of potential claim - Even before formal demand

Litigation Hold Template

LITIGATION HOLD NOTICE

CONFIDENTIAL - ATTORNEY-CLIENT PRIVILEGED

Date: [Date]

From: [Legal/Compliance Officer]

To: [List of custodians: IT, Marketing, Sales, Customer Service, relevant individuals]

Re: Document Preservation - TCPA Claim from [Claimant Name]


IMMEDIATE ACTION REQUIRED

We have received a legal claim that requires immediate preservation of documents and electronic data. This notice supersedes any existing document retention policies.

YOU MUST PRESERVE all documents, records, and electronic data relating to:

  • Phone number: [XXX-XXX-XXXX]
  • Name: [Claimant Name]
  • All communications (calls, texts, emails) to or from this number/person
  • All consent records, webform submissions, or agreements from this person
  • All opt-out requests or DNC entries for this number
  • All campaign records, dialer logs, and SMS platform data involving this number
  • All lead source documentation if number was purchased
  • All policies, procedures, and training materials related to TCPA compliance
  • All vendor agreements related to calling/texting services

DO NOT:

  • Delete any files, emails, texts, or records related to this matter
  • Allow automatic deletion/archival systems to destroy relevant data
  • Modify or alter any existing records
  • Discuss this matter with anyone outside the company without authorization

REQUIRED ACTIONS:

  1. Immediately suspend any auto-delete or retention policies for the data described above
  2. Export and preserve copies of all relevant platform data
  3. Identify and preserve any personal devices or accounts that may contain relevant data
  4. Contact [Legal Contact] within 24 hours to confirm receipt and compliance

Duration: This hold remains in effect until you receive written notice that it has been lifted.

Questions: Contact [Legal Contact] at [email/phone].

Failure to comply with this notice may result in serious legal consequences for the company and may constitute grounds for disciplinary action.


ACKNOWLEDGMENT

I have read and understand this Litigation Hold Notice. I will preserve all relevant documents and data as described above.

Name: _______________________

Signature: _______________________

Date: _______________________

Who Should Receive the Hold

Department/Role Why Data They Control
IT / Systems Admin Controls backup, retention, and system access Server logs, backups, platform access
Marketing Ran the campaigns; knows lead sources Campaign records, lead lists, vendor contacts
Sales May have contact records, CRM data CRM records, call notes, customer files
Customer Service May have opt-out requests, complaints Support tickets, call recordings, complaint logs
Compliance/Legal Policies, training, prior issues Policies, procedures, prior complaints
Individual custodians People who directly worked on campaigns Personal files, emails, notes

System-Specific Retention Overrides

Actions by Platform Type

  • Email (O365/Google) - Place legal hold on relevant mailboxes; disable auto-archive
  • CRM (Salesforce/HubSpot) - Export relevant records; disable deletion permissions for relevant contacts
  • SMS Platform (Twilio, etc.) - Export all message logs immediately (may have 30-90 day retention)
  • Dialer Platform - Export CDRs and recordings before they expire
  • Backups - Preserve current backups; extend retention for relevant backup sets
  • Web forms/landing pages - Archive current form versions; preserve submission logs

Documentation of Preservation Efforts

Create a preservation log documenting:

  • Date hold issued and to whom
  • Acknowledgments received from each custodian
  • Systems identified as containing relevant data
  • Exports completed with dates and data descriptions
  • Retention overrides implemented and confirmed
  • Any data that could not be preserved and why (e.g., already deleted before hold)

Ongoing Obligations

  • Monitor compliance - Periodically check that hold is being followed
  • Update as needed - If scope expands, issue supplemental hold
  • New custodians - If new people become involved, add them to hold
  • Document everything - Keep records of all preservation activities
  • Lift when appropriate - Only after matter is fully resolved and documented

Attorney Services

Need Help With Evidence Preservation?

Proper evidence preservation and consent documentation can make or break a TCPA defense. Get professional guidance on your preservation strategy.

Contact: owner@terms.law

California State Bar #279869