[LINK] Do-not-call uses list washing

[Robin Whittle]

Hi Stewart,

In "Re: [LINK] after the DNCR" you wrote, in part:

> My guess is that the government's release of the no-call list has given
> Telstra's international associates in the call business, a new defined list
> of who to call, and that this approach may be a new way to get around the
> legislation.

The Australian Do Not Call Register differs in one important respect
from its US counterpart - http://www.donotcall.gov - on which it was
modelled.

The US DNCR makes available lists of numbers not to be called.

The Australian DNCR does not release the numbers.  It always operates
via a list washing system.  There are costs in proportion to the number
of numbers to be tested and which remain unflagged as "do not call".

  https://www.donotcall.gov.au/dncrtelem/info.cfm

While someone could derive a list of numbers not to be called in this
way, it is a more difficult and expensive thing to do than with the US
system.  Another benefit is that it is much more difficult to
aggressively create a day-by-day or week-by-week 'delta' of the DNC
list.  This would be a powerful tool for criminals and detectives trying
to find people who have changed their telephone number in a certain
timeframe, or who have moved to a new locality.

I argued very strongly for the list washing approach to be used
exclusively for the DNCR. http://www.firstpr.com.au/issues/dnc/

While ADMA used to provide to its members the complete "do not contact"
list, complete with names, addresses and phone numbers, it also offered
a list washing service.  This probably meant the industry could hardly
argue against list washing.

I don't know who else argued for list washing.  Maybe this is a rare
instance where my privacy advocacy work actually made a difference.

  - Robin