Handling Opt-Outs and Opt-Ins - Contact Center Compliance

Consumers change their minds. A person may ask to be placed on your Do Not Call list today and opt back in next month through a web form. This guide explains how DNCScrub’s Internal DNC list and EBR/Consent records work together so the scrub result always reflects the consumer’s most recent choice — and the exact API calls to make for each event.

The two lists involved

List	What it represents	API
Internal DNC (IDNC)	The consumer asked your organization not to call them	Internal DNC List
EBR / Consent	You have an exemption to DNC rules — a purchase, an inquiry, or the consumer’s express permission	EBR and Consent

A phone number can have records on both lists at the same time. When that happens, the scrubber decides which one wins using the rules below.

Use a Permission (P) EBR for opt-ins backed by express written consent — for example, a signed web consent form, a checked consent box with the required disclosures, or a recorded verbal agreement where allowed. Sale (S) and Inquiry (I) EBRs represent business activity, not consent, and they do not override an Internal DNC entry.

How the scrubber decides: dates matter

When a number is on your Internal DNC list and has a Permission EBR, the scrubber compares dates:

If the Permission EBR’s dateOfLastContact (the consent date) is later than the date the number was added to your Internal DNC list, the consent wins. The number is returned as callable with an EBR Override result code (O).
If the Internal DNC entry is newer than the consent, the opt-out wins and the number is returned as Internal DNC (P result code) — not callable.

In other words: the most recent expression of the consumer’s intent wins, as long as the dates you send are accurate.

Sale and Inquiry EBRs never override an Internal DNC entry, regardless of dates. Only a Permission EBR — express consent — can do that.

Recommended lifecycle

A typical sequence, using a consumer who opts out through your dialer or CRM disposition and later opts back in through a web consent form:

Consumer opts out (e.g., dispositioned as DNC in your dialer)

Add the number to your Internal DNC list:

curl --request GET \
  'https://www.dncscrub.com/app/main/rpc/pdnc?phoneList=5039367187&actionType=add' \
  --header 'loginId: YOUR_API_KEY'

Scrubs now return the number as Internal DNC (P) — do not call.

Consumer opts back in (express written consent on a web form)

Do two things:1. Add a Permission EBR with dateOfLastContact set to the actual date the consumer gave consent:

curl --request POST 'https://www.dncscrub.com/app/main/rpc/ebr' \
  --header 'loginId: YOUR_API_KEY' \
  --header 'Content-Type: application/json' \
  --data '{
    "ebrList": [
      {
        "phoneNumber": "5039367187",
        "type": "P",
        "dateOfLastContact": "07/15/2026",
        "referenceNum": "consent-form-84213"
      }
    ]
  }'

2. Remove the number from your Internal DNC list:

curl --request GET \
  'https://www.dncscrub.com/app/main/rpc/pdnc?phoneList=5039367187&actionType=remove' \
  --header 'loginId: YOUR_API_KEY'

Scrubs now return the number as callable under the Permission EBR.

Consumer opts out again later

Add the number back to your Internal DNC list (same call as step 1). The new Internal DNC entry is dated later than the consent, so the opt-out wins again.

Why remove the Internal DNC entry on opt-in?

Strictly speaking, a Permission EBR dated after the Internal DNC entry already overrides it — the scrubber’s date comparison handles that. But we still recommend removing the Internal DNC entry when the consumer opts back in, for one important reason: Adding a number that is already on your Internal DNC list does not refresh its added-on date. The add is idempotent — the record keeps its original date. So if you leave the stale Internal DNC entry in place and the consumer later opts out again, your new “add” would be a no-op against the old entry, the Permission EBR would still look newer, and the number would keep scrubbing as callable. That is a compliance risk. Removing the entry on opt-in and adding a fresh one on the next opt-out keeps the dates truthful in both directions.

Keep the Permission EBR in place when the consumer opts out again — there is no need to delete it. The newer Internal DNC entry takes precedence, and the EBR record preserves your audit trail of the earlier consent.

Rules of thumb

Opt-out → add to Internal DNC.
Opt-in with express written consent → add a Permission (P) EBR and remove the number from Internal DNC.
Purchase or inquiry → add a Sale (S) or Inquiry (I) EBR. These create DNC exemptions for numbers on the National/state registries but never override your Internal DNC list.
Always send true event dates. dateOfLastContact must be the date consent was actually given — not the date you happened to load the record. The scrubber’s precedence logic is only as accurate as the dates you send, so load opt-outs and opt-ins promptly.
Keep records for your audit trail. Use referenceNum on EBR records to tie the consent back to the form submission or recording that proves it.

​The two lists involved

​How the scrubber decides: dates matter

​Recommended lifecycle

​Why remove the Internal DNC entry on opt-in?

​Rules of thumb

The two lists involved

How the scrubber decides: dates matter

Recommended lifecycle

Why remove the Internal DNC entry on opt-in?

Rules of thumb