This is a published operating standard for covered campaigns. It does not establish permission to call a particular person or authorize a buyer to use a lead outside the disclosure and consent that were actually presented.
01. Obtain the right permission
Where prior express written consent is required, the collection experience must clearly disclose the authorized seller, contact number, marketing purpose, and covered calling or messaging technology. The consumer must take an affirmative signing action, and consent cannot be a condition of purchase. An inquiry or click alone must not be treated as unlimited marketing permission.
Policy requires recipients to be identified clearly and consent scope to be preserved. A generic reference to unspecified “partners” is not a substitute for a campaign-specific review.
TCPA calling and consent rules ↗02. Keep consent evidence
A covered lead’s evidence package must preserve the collection URL, disclosure text and version, affirmative action, UTC timestamp, authorized recipient information, and relevant transaction identifier. Capture technical evidence only as necessary and disclosed. Any third-party consent certificate is supporting evidence, not a legal guarantee.
Delivery records must connect the lead to the evidence that existed at collection. Later edits to a landing page must not overwrite the historical disclosure. Required telemarketing records must be kept for five years where the FTC rule applies; other retention depends on the applicable law, contract, and documented purpose.
FTC telemarketing recordkeeping rule ↗03. Respect Do Not Call and local restrictions
Before outreach, the responsible caller must apply national, state, and entity-specific suppression rules; verify any claimed exception; and observe applicable local-time calling windows, frequency limits, and licensing requirements. Where required, the National Do Not Call Registry version used must be no more than 31 days old. Suppression data must not be repurposed as a marketing list.
Lead delivery speed does not excuse these checks. Federal requirements are a floor; stricter applicable state requirements must also be met.
FTC Do Not Call and telemarketing guidance ↗04. Make withdrawal practical
Consumers may communicate a clear withdrawal through reasonable methods, including a reply to the sender or a request to Blue Bench Media. The operating requirement is prompt suppression and routing to affected recipients, without unnecessary identity barriers for marketing opt-outs. Applicable TCPA requests must be honored as soon as practicable and within the applicable ten-business-day limit. A new marketing message must not be used to confirm an opt-out.
For help with a lead associated with Blue Bench Media, use Your Privacy Choices. A request sent here cannot directly change an unrelated company’s systems; we will assess our involvement and the appropriate recipient.
05. Commercial email
Covered commercial email must identify the sender accurately, use a truthful subject line, provide required advertising identification and a valid postal address, and include an easy unsubscribe method. Opt-outs must be honored within ten business days; the mechanism must remain available for at least 30 days after sending. Vendors acting on a company’s behalf must be supervised.
FTC CAN-SPAM guidance ↗Current rule context
The Eleventh Circuit vacated the FCC’s attempted one-to-one and logically/topically related consent restrictions in January 2025. That decision did not eliminate existing written-consent obligations or separate state and sector rules.
Court decision on the FCC one-to-one consent rule ↗The FCC’s January 2026 order delays a limited cross-topic revocation requirement for unrelated informational communications until January 31, 2027. It does not suspend the other consent-withdrawal rules. Our standard remains to act promptly on the consumer’s expressed request.
FCC 2026 limited revocation waiver ↗Medicare marketing has separate entity-specific data-sharing consent requirements. The FCC decision must not be treated as removing those requirements.
Medicare marketing and TPMO requirements ↗