Scrubbing Phone Numbers
How Companies “Scrub” Phone Numbers —
and What It Means for Your TCPA Rights
This is for educational purposes only. It is not legal advice.
What “Scrubbing” Means
In the telemarketing world, scrubbing means checking a list of phone numbers before making calls or sending texts to remove numbers they are not legally allowed to contact.
Scrubbing is meant to reduce legal risk for the caller by avoiding certain numbers.
Types of Scrubbing Companies Use
1. Do Not Call (DNC) Registry Scrub
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Compares numbers against the National Do Not Call Registry and state-specific lists.
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Businesses are prohibited from calling these numbers for sales purposes unless they have valid consent or an existing business relationship (EBR).
Consumer Insight:
If you’re on the DNC registry but still receive calls, either:
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They didn’t scrub properly, or
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They believe they have an exemption (e.g., “you gave consent” or “we have an EBR”).
2. Internal Do Not Call List Scrub
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Companies maintain their own internal DNC list of people who have asked them to stop calling.
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Telemarketers must honor these requests for at least five years.
Consumer Insight:
If you’ve asked them to stop and they call again, they may have failed to scrub against their own internal list — a common TCPA violation.
3. Litigation List Scrub
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Some companies subscribe to “litigator list” databases containing names/numbers of people who have sued or threatened TCPA action before.
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The goal: avoid calling people likely to file lawsuits.
Consumer Insight:
If you’ve previously asserted your rights, you might be on one of these lists — which means fewer calls from legitimate companies, but illegal/spoofed calls may still come from bad actors who don’t scrub.
4. Wireless/VoIP Scrub
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The TCPA has extra restrictions for calling cell phones without consent.
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Companies may scrub out wireless numbers or numbers associated with VoIP carriers to avoid higher-risk calls.
Consumer Insight:
Even with scrubbing, some calls slip through when number-type databases are outdated.
5. Time-of-Day/Geographic Scrub
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Calls must be made only between 8 a.m. and 9 p.m. in the recipient’s time zone.
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Companies may scrub by area code/time zone before dialing.
Consumer Insight:
If you get a marketing call outside these hours, they either skipped this scrub or miscalculated your location.
How Scrubbing Can Go Wrong
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Outdated data — scrub databases may be weeks or months old.
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Wrong match — numbers change hands; they may think you gave consent when someone else did years ago.
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Over-reliance on third-party vendors — if the vendor’s list is flawed, liability can still fall on the caller.
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Ignoring internal DNC — many violations happen because the company’s own records aren’t updated quickly enough.
Where Consumers Have Leverage
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Prove they had reason to know you were on the DNC list or had opted out.
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Request their scrub logs in discovery — these show whether your number was flagged and why it wasn’t removed.
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Highlight timing errors — if they called outside allowed hours, it’s evidence of noncompliance.
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Challenge consent — scrubbing doesn’t replace the need for proper, documented consent.
Tips for Protecting Yourself
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Register your number on the National DNC list (donotcall.gov) and keep the confirmation.
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Document opt-out requests — date, time, method (email, phone, text).
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Save call logs & recordings — especially post-opt-out calls.
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Don’t rely on scrubbing to protect you — illegal calls can still get through.
Bottom Line
Scrubbing is a compliance tool — not a consumer protection guarantee.
If you’re still getting calls after opting out or registering on the DNC list, it’s worth gathering evidence. Companies that fail to scrub correctly may face TCPA penalties of $500–$1,500 per call.
Scrub Check Request Letter Template
(For consumer use — not legal advice)
[Your Name]
[Your Address]
[City, State ZIP]
[Email Address]
[Phone Number]
[Date]
[Company Name]
Attn: Compliance or Legal Department
[Company Address]
[City, State ZIP]
Re: Request for Do Not Call & Scrubbing Records – TCPA Compliance Inquiry
To Whom It May Concern:
I am writing regarding telephone calls and/or text messages I have received from your company to my number: [insert your phone number].
Pursuant to my rights under the Telephone Consumer Protection Act (TCPA) and applicable FCC regulations, I am requesting:
1. **Confirmation** of whether my number appears on:
– Your **internal Do Not Call (DNC) list**
– Your **most recent scrubbed calling lists**
– Any third-party “litigator” or “exempt” suppression lists you maintain
2. **Documentation** of:
– The date my number was added to any DNC or suppression list
– The most recent date my number was scrubbed before a call/text was made
– The source of any consent you claim authorizes contact with me
3. **Description** of your scrubbing process, including:
– Frequency of scrubs (daily, weekly, monthly)
– Databases or vendors used for scrubbing
– How internal DNC requests are recorded and implemented
Please preserve all related records, including call logs, consent records, and scrubbing/suppression logs, from **[insert date range]**.
I request a written response within **14 days** of receipt of this letter. If you believe you are exempt from these requirements, please state the specific exemption and provide supporting documentation.
Thank you for your prompt attention to this matter.
Sincerely,
[Your Name]
[Signature, if mailing]
Tips for Using This Letter
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Send via certified mail (keep the receipt) or email to the compliance/legal contact if available.
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Do not attach your full call log at this stage — you’re gathering, not giving.
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If they respond, save all communications — even evasive answers can be useful in a TCPA claim.
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If they ignore the request, note the date — lack of transparency may help demonstrate willfulness.
