How Power Dialer Collects and Enforces Consent

Last updated: March 27, 2026

This page describes how the Power Dialer platform ensures that all outbound calling activity is conducted with proper consent and in compliance with the Telephone Consumer Protection Act (TCPA), the Telemarketing Sales Rule (TSR), and applicable state telemarketing laws.

The platform uses Twilio for telephony services. This document is intended to demonstrate our consent collection and enforcement practices to Twilio's compliance team and any other regulatory reviewers.

1. Consent Collection

Before any user can place calls through Power Dialer, they must complete a mandatory consent flow during onboarding. This flow requires acknowledgment of four explicit consent items. Each item is presented as an individual checkbox that must be checked independently -- bulk acceptance is not permitted.

Each consent acknowledgment is individually timestamped and recorded along with the user's IP address at the moment of interaction. No calls can be placed until all four consent items have been acknowledged.

Consent form

Below is a representation of the consent form presented to every user during onboarding:

Before you begin calling

Please review and acknowledge each of the following items. All four are required before you can place calls.

The "Continue to Dashboard" button remains disabled until all four checkboxes are individually selected. Once submitted, the consent record is written to an immutable store and cannot be modified or retracted.

2. What Users Agree To

The four consent items are carefully worded to cover the key compliance obligations. Each user explicitly agrees to the following statements, verbatim:

1. "I confirm that all contacts in my lists have given prior express consent to be called."

This ensures the user takes responsibility for having obtained valid consent from every contact before uploading them to the platform. The platform does not collect consent from end contacts on the user's behalf -- the user must have obtained it through their own processes.

2. "I will honor all Do Not Call requests and maintain an internal DNC list."

This obligates the user to respect opt-out requests. While the platform automatically manages a DNC list for calls placed through the Service, the user must also honor DNC requests received through channels outside the platform.

3. "I agree to the Power Dialer acceptable use policy and will not use the service for illegal or abusive purposes."

This binds the user to our Acceptable Use Policy, which prohibits unsolicited calling, harassment, fraud, DNC bypass attempts, and other abusive practices.

4. "I agree to the Power Dialer terms of service and privacy policy."

This binds the user to our Terms of Service and Privacy Policy, which cover billing, data handling, liability, and account obligations.

3. Technical Enforcement

Beyond consent collection, Power Dialer enforces compliance through multiple automated, server-side mechanisms that cannot be bypassed by users:

DNC checking on every dial attempt

The platform checks the Do Not Call list on every single dial attempt, not just at the time of contact upload. This means that even if a contact is added to the DNC list after being uploaded to a campaign, the system will block the call at dial time. DNC checking is performed server-side and cannot be disabled or overridden.

Calling hours enforcement

All calls are restricted to 8:00 AM to 9:00 PM in the contact's local timezone. The platform determines the contact's timezone based on their phone number's area code and geographic data. Calls attempted outside this window are blocked server-side. Users cannot override this restriction.

Attempt limits

The platform enforces per-contact attempt limits to prevent excessive calling:

  • 3 attempts per day per contact
  • 10 attempts per month per contact

These limits are enforced server-side. Once a contact has reached the daily or monthly limit, additional dial attempts are blocked until the relevant period resets.

Automatic SMS STOP handling

When a contact replies STOP (or any standard opt-out keyword) to an SMS sent through the platform, the contact is automatically added to the organization's DNC list. This happens immediately and without user intervention. Subsequent call and SMS attempts to that contact are blocked.

Immutable consent records

All consent records are stored in an append-only, immutable data store. Records cannot be modified, deleted, or backdated. This ensures a complete and tamper-proof audit trail for TCPA compliance.

4. Audit Trail

Power Dialer maintains comprehensive audit trails for both consent collection and DNC enforcement. These records are available for compliance review and legal proceedings.

Consent records

Every consent acknowledgment includes the following fields:

Field Example
user_id usr_a1b2c3d4e5
org_id org_x9y8z7w6v5
consent_type prior_express_consent
timestamp 2026-03-27T14:32:09.447Z
ip_address 203.0.113.42
user_agent Mozilla/5.0 ...

Consent records are stored with the following consent types:

  • prior_express_consent -- Affirms contacts have given consent to be called
  • dnc_compliance -- Agrees to honor DNC requests
  • acceptable_use -- Agrees to the acceptable use policy
  • terms_and_privacy -- Agrees to terms of service and privacy policy

DNC check logs

Every DNC check performed by the platform is logged with the following fields:

Field Example
phone_hash sha256:e3b0c44298fc...
campaign_id camp_m4n5o6p7q8
result blocked_dnc
timestamp 2026-03-27T14:35:22.891Z
org_id org_x9y8z7w6v5

Phone numbers are stored as SHA-256 hashes in DNC check logs to protect contact privacy while maintaining a verifiable audit trail. The result field indicates whether the call was allowed (allowed), blocked by DNC (blocked_dnc), blocked by calling hours (blocked_hours), or blocked by attempt limits (blocked_limit).

Record retention

Consent records and DNC check logs are retained permanently. This ensures compliance with TCPA requirements, which impose a statute of limitations of up to four years for willful violations. Our permanent retention policy ensures records are available for any future compliance inquiry or legal proceeding.

5. Contact

For questions about our consent practices, compliance enforcement, or to request access to audit records, contact our compliance team:

For general questions about the platform, see our Terms of Service, Privacy Policy, and Acceptable Use Policy.