How Zero-Persistence
Scrubbing Works
A five-step process that verifies every contact against the FCC's national database, removes reassigned numbers automatically, and generates court-ready Safe Harbor documentation — without ever storing your data.
Submit Your Contact List
Secure IngestionUpload your outreach list via our encrypted portal or connect directly through our REST API. Your data is transmitted over TLS 1.3 and never written to permanent storage — it exists only in memory for the duration of the verification session.
- Accepts CSV, XLSX, or direct API payload
- TLS 1.3 encryption in transit
- No permanent storage of raw contact data
- Supports lists from 100 to 10M+ numbers
Consent Date Cross-Reference
FCC Database QueryEach phone number is queried against the FCC's Reassigned Numbers Database (RND) alongside your original consent capture date. The system determines whether the number was reassigned to a new subscriber after you obtained consent — the exact legal threshold under TCPA.
- Direct API integration with FCC RND
- Consent date matched per-record
- Millisecond-level query response
- Carrier-level reassignment data included
Zero-Persistence Scrubbing
Automated RemovalNumbers flagged as reassigned after your consent date are automatically removed from your active campaign list. No human ever reviews or touches your contact data. The scrubbed list is returned to you immediately — clean, verified, and campaign-ready.
- Fully automated — no human PII exposure
- Flagged numbers removed in real time
- Original list never stored post-session
- Clean list returned via same channel
Safe Harbor Documentation
Audit Trail GenerationA timestamped, cryptographically signed compliance record is generated for every verification session. This document — including query timestamps, FCC response codes, and scrub results — constitutes your good-faith Safe Harbor defense under FCC regulations and is admissible in TCPA proceedings.
- Cryptographically signed audit record
- FCC response codes logged per number
- Court-admissible documentation format
- Stored securely for 7 years
Continuous Re-Verification
Ongoing ProtectionPhone numbers are re-verified automatically before each campaign cycle. Because reassignment happens continuously — the FCC reports over 100,000 numbers reassigned daily — a list verified last month may already contain new violations. Our platform keeps your Safe Harbor defense current without manual intervention.
- Automatic re-verification before each send
- Configurable verification cadence
- Alerts for newly flagged numbers
- Continuous Safe Harbor coverage
The Legal Standard You Must Meet
Under the TCPA, a business can be held liable for contacting a reassigned number — even if it had valid consent from the original subscriber. The FCC's Safe Harbor provision offers a defense, but only if the business can document a good-faith effort to verify reassignment status before each contact.
"Good faith" is not a vague standard. The FCC requires evidence of an actual query to the Reassigned Numbers Database. Our platform generates that evidence — timestamped, signed, and formatted for legal proceedings.
Important: A Safe Harbor defense is only available to businesses that query the RND before making contact. Retroactive verification does not qualify.
Frequently Asked Questions
What is the FCC Reassigned Numbers Database?
The RND is a national database maintained by the FCC that tracks when phone numbers are disconnected and reassigned to new subscribers. Under TCPA, contacting a reassigned number — even with prior consent from the original subscriber — can constitute a violation.
What does "Zero-Persistence" mean exactly?
It means your contact list data is never written to disk or stored in any database on our end. It exists only in volatile memory during the verification session and is purged immediately after your clean list is returned. This eliminates data breach risk and satisfies strict data minimization requirements.
How is the Safe Harbor documentation used in court?
The FCC Safe Harbor provision protects businesses that can demonstrate a good-faith effort to verify number reassignment. Our cryptographically signed audit records — timestamped and tied to specific FCC RND query responses — provide that documented good-faith effort. Courts have accepted similar records as a complete defense in TCPA class actions.
How often should I re-verify my contact list?
The FCC reports over 100,000 numbers are reassigned daily. For active outreach campaigns, we recommend verification before every campaign send. For dormant lists, re-verify any list older than 30 days before reactivating it.
Can I integrate this into my existing CRM or dialer?
Yes. Our REST API integrates with most major CRM and dialer platforms. We provide SDKs for common environments and can support custom integrations for enterprise clients.
Ready to Get Protected?
Tell us your contact volume and we'll build a tailored protection quote — delivered within 24 hours, at no cost.