DNC & Data Handling
Your lead database is a business asset and other people's personal data at the same time. Here's how we treat both responsibilities — in plain language.
Do Not Call (DNC) compliance
Singapore's Do Not Call provisions under the PDPA restrict telemarketing messages and calls to numbers registered on the DNC Registry, unless valid consent applies. Our calling workflow is built around this:
- Screening before outreach. Calling lists are checked against DNC Registry requirements before voice outreach, except where an applicable exception (such as clear and unambiguous consent) has been established and documented.
- Consent context per lead. We record where each lead came from and what consent context applies — for example, a lead who submitted an ad enquiry asking to be contacted about a specific project.
- Respecting withdrawal. If a lead asks not to be contacted again, that instruction is logged immediately and honoured across future campaigns.
- Old databases reviewed first. Before re-engaging a legacy database, we review its age, source and consent context with you and re-screen numbers as required.
Respectful calling practices
- Calls are made at sensible hours suited to working professionals.
- Callers identify who they are calling on behalf of and why.
- No pressure tactics, misleading claims or manufactured urgency.
- A "no" is accepted politely and recorded — your brand ends every interaction well.
How your lead data is handled
- Purpose-bound. Your lead data is used only to deliver your engagement — calling, qualification, CRM organisation, appointment setting and follow-up. Never for any other client, never for our own marketing, never sold.
- Access-controlled. Only team members working on your account can access your data, under confidentiality obligations.
- Segregated. Each client's database is kept separate. There is no shared "pool" of leads.
- Secured. Data is stored on access-controlled systems with reasonable technical and organisational safeguards, in line with the PDPA's Protection Obligation.
Ownership and clean exits
- Your database — including statuses, notes and outcomes generated during the engagement — belongs to you.
- You can export your data at any time during the engagement.
- At the end of an engagement, your data is returned to you and our working copies are deleted within a reasonable period, subject to any legal retention requirement.
Shared responsibility
Compliance is a partnership. As the client, you're responsible for ensuring the leads you supply were collected lawfully and may be used for follow-up contact; we're responsible for screening, respectful outreach and secure handling from there. During onboarding we walk through both sides so nothing is assumed.
Questions or requests
For any data protection question — including access, correction or deletion requests — contact admin@midnightshift.sg. See also our Privacy Policy.
This page describes our operating practices in plain language and is not legal advice. Regulatory obligations under the PDPA and DNC provisions apply as set out in the legislation and PDPC guidelines.
Questions about compliance?
Ask them in the demo — we're happy to walk through the screening workflow and data practices in detail.