Do you need to check the CTPS before cold calling UK businesses?

In general, yes. The ICO's guidance on live marketing calls says you may call a business without prior consent, but you must not call a number that is registered on the Telephone Preference Service (TPS) or the Corporate Telephone Preference Service (CTPS), and you must not call anyone who has told you they object. In practice that means screening your call list against the registers before you dial. This guide is general information, not legal advice, and the ICO has said its business-to-business guidance is under review following the Data (Use and Access) Act, so check the current text.

Who counts as a business under the rules

The Privacy and Electronic Communications Regulations (PECR) distinguish corporate subscribers from individual subscribers. Corporate subscribers are bodies with a separate legal status, such as limited companies, limited liability partnerships, Scottish partnerships and some public bodies. Sole traders and some other partnerships are individual subscribers, and PECR gives them the same protection as private individuals.

The consequence for a seller is simple. A limited company's main line is screened against the CTPS. A sole trader's number is screened against the TPS. A list that mixes both needs checking against both. Companies House covers limited companies and LLPs, which is useful: if the company is on the register, it is a corporate body, but the phone number you hold for it still needs screening.

What about a director's direct line or mobile?

The ICO's guidance treats a direct line for an employee as a corporate subscriber, because the subscriber is the employer. That means the CTPS applies to it as well. A mobile number that belongs to the individual personally, rather than to the business, raises a different question, and personal data rules under UK GDPR also apply to named people. If you are unsure whose number it is, do not assume it is exempt.

A practical routine before a call session

Keep it short enough that people actually follow it.

First, screen the numbers you plan to call against the TPS and CTPS, and keep a record of when you did so. The registers are updated regularly, so a list screened months ago is not safe. Second, keep your own do-not-call list and add anyone who says they object, immediately. Third, identify yourself and your company at the start of the call, and give a contact number or address if asked. Fourth, record why you called that company and what you relied on, which also makes the conversation better.

Where a public record helps

A call that opens with a specific, checkable record, such as a newly registered charge, a contract ending or a first hire in a function, is more relevant than a generic pitch, and relevance is what a business owner reacts to. It does not change the legal position. A strong reason to call does not remove the need to screen the number first.

Lockley gives a short list of UK companies with the public record behind each, and links every finding to its source. It does not sell contact lists, so the numbers you dial come from your own sources, and the screening duty stays with the caller.

Questions