Do not launch automated outbound sales calls merely because the recipients were customers before. Establish the applicable calling rules and evidence of permission before allowing the campaign to run.
The ICO says automated marketing calls playing a recorded message require consent specifically covering automated marketing calls from the organisation. General marketing consent or permission for live calls is insufficient, and the rules cover individual and corporate subscribers. (ico.org.uk)
An important evidence gap: the guidance reviewed describes recorded-message automated calling. It does not conclusively resolve every implementation of interactive, dynamically generated AI speech. Do not turn that uncertainty into a claimed exemption.
Our conservative purchasing position is to require specific permission and specialist review before deploying AI marketing calls. Keep an inbound receptionist pilot separate from outbound selling.
Ask the supplier to show how it records permission, identifies the business, honours objections and prevents further attempts after an opt-out. Do not assume that an email soft opt-in authorises an automated telephone campaign; permissions are channel-specific. (ico.org.uk)
Sources cited on this page
- ico.org.uk ↗ico.org.uk