Outpero

Is it legal to cold call a purchased phone number database in India?

Short answer

It is very risky and often unlawful. Purchased databases rarely come with valid consent from the people listed, which matters under the DPDP Act 2023, and promotional calls to them must still be screened against DND under TRAI's TCCCP Regulations 2018 and made through registered 140-series routes. Data obtained through a breach or leak can also expose the buyer to liability under the IT Act 2000.

Three separate problems

First, consent. Under the DPDP Act 2023, using someone's personal data for marketing generally needs their consent for that purpose. A list sold as 'HNI contacts in Gurugram' or 'NEET aspirants in Kota' almost never carries consent that names your business.

Second, telecom rules. Even a lawfully sourced list must be screened against DND, and promotional calls must go through registered telemarketers on 140-series numbers. Third, provenance. Data taken in a breach, or carried out by an employee from a former employer, can lead to liability under the IT Act 2000 and police complaints.

Buyers often assume the seller carries the risk. In practice the business that dials the numbers is the sender in TRAI's eyes and the data fiduciary under the DPDP Act, so the consequences land on the brand whose name is on the call.

What it does to a campaign

  • —Heavy DND overlap, so much of the list cannot be called for promotion anyway.
  • —High complaint rates, which is what triggers TRAI enforcement against senders.
  • —Stale and wrong numbers, wasting paid talk time.
  • —Spam labels on your number that hurt calls to genuine customers.

Lawful alternatives that work

  • —Call your own enquiries the moment they arrive from Meta lead ads, Google Ads and your website.
  • —Reactivate past customers who have a relationship with you, with DND screening for promotional offers.
  • —Use leads from IndiaMART, JustDial or property portals under their terms, where the enquirer chose to share details.
  • —Run consent-first campaigns, then call.

How Outpero fits

Outpero is built around calling your own enquiries fast, and bulk campaigns screen uploaded lists against DND before dialling. DND screening does not make a purchased list lawful under the DPDP Act; it only removes one of the three problems.

Not legal advice

If your business already relies on bought data, take advice from counsel on how to wind it down safely.

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