Before you text your customer list: a consent checklist

Does consent exist, and what does it cover?

Start here, contact by contact, because this is the question that decides everything downstream.

• Point to the moment: can you identify where and when this person agreed to receive text messages from you? An intake form or job authorization with a clear messaging clause is a record. "They gave us their number once" is a memory, and memories don't survive a dispute
• Check the scope: consent given to receive appointment reminders is not consent to receive promotional offers. Marketing messages generally require a higher standard of consent than operational ones, so re-read the language the customer actually agreed to and ask whether the message you're about to send fits inside it
• Check the age: a number captured five years ago on a form nobody kept a copy of is weak evidence, even if the consent was genuine at the time. Old consent with no record behind it should be treated as no consent
• Check who collected it: consent given to a lead vendor or a previous owner of the business may not transfer to you. Purchased lists are the clearest case of consent you do not have

Revocation: easy to honor, expensive to get wrong

A recipient can withdraw consent, and the withdrawal doesn't have to arrive in the format you'd prefer. The FCC's rules on consent revocation establish that consumers may revoke consent through any reasonable means, that senders must honor it promptly, and that a request to stop can't be limited to one narrow channel when the same sender is reaching the person several ways.

The operational consequence: a STOP reply to a text has to suppress that person everywhere, including email and calls, and it has to do so immediately rather than at the next list refresh. If someone replies "please stop emailing me" to an email, that's a revocation too, even though it isn't the magic word. Build the suppression list so it accepts messy human input, and confirm the current FCC rule along with any stricter state law that applies to you.

Timing and identification

Two rules that are easy to state and easy to breach at scale.

The federal calling window is 8am to 9pm in the recipient's local time. It appears in 47 CFR 64.1200(c)(1) for telephone solicitations to residential subscribers, and in the FTC's Telemarketing Sales Rule as the same 8am–9pm limit. It applies to the recipient's time zone, not your office's — which means a nationwide list needs per-contact local time, not a single send time. Several states impose narrower windows and additional restrictions on weekends and holidays, so the strictest applicable rule is the one to build to.

Identification is simpler: every message says who you are. A recipient should never have to work out which contractor is texting them, and an unidentified message is both a compliance problem and a bad first impression.

Records: the whole defense

• Keep evidence of consent — the form, the timestamp, the wording shown at the moment of collection, and the source
• Keep a send log — who received what, when, and through which channel
• Keep opt-out records — what was received, when it was honored, and across which channels it propagated
• Keep them for longer than feels necessary; disputes surface long after a campaign ends, and contemporaneous records are what carry the argument

In SignalBack, these checks are intended to live in the sending path rather than in a settings page: consent-gated channels, automatic opt-out propagation across every channel, recipient-local timing windows, and durable consent records. Being precise about state — sending is not built yet, so nothing is enforced today because nothing sends. The free CSV audit is what's live.

One more thing

The pattern running through every rule above is the same: the lead may be dead to your pipeline, but the person behind it has live rights that don't expire when your CRM marks a row inactive. Re-engagement that's identified, consented, and easy to stop reads as service. The same campaign sent sloppily generates complaints, and complaints are what turn a marketing budget into a legal one.

This is engineering guidance, not legal advice, and the rules move — the FCC revisits its TCPA interpretations regularly and states legislate independently. When in doubt, ask a lawyer who works in telecom compliance.