Disclosure Matching Logic

Summary

To determine a TCPA disclosure match, Jornaya's TCPA Guardian compares the language contained within the Jornaya TCPA label(s) present on the page, to the languages the company querying the LeadiD has approved and uploaded into their Jornaya profile. The list of approved and uploaded languages is maintained exclusively by the company querying Jornaya, who must be a TCPA Guardian customer.

Results

The API response will always return the best possible results for the matching language that meets the requestor's visibility, prominence, and contrast requirements.

Dynamic Text

In certain cases, the TCPA language presented to the consumer may dynamically change. Examples of this include different calls to action (by clicking “submit”, “yes”, “continue” etc.), changing list of brands a consumer may be contacted by, or including consumer PII in the language.

When faced with dynamically changing text, lead providers should provide their TCPA language to the lead buyer with an indication of where the TCPA language may change.

Wildcard

To account for changing TCPA languages, the company querying the LeadiD should add a wildcard character, called a pipe ( | ), in place of the dynamic part of the language when uploaded to their profile. Below are examples of what a company should add to their profile if a lead seller indicates the call to action, list of companies, or personal identifying information.

Dynamic Call to Action

Disclosure Text
By clicking “XXXX” you agree to be contacted by phone or text at the number provided by Company A, B, and C.

Updated with wildcard
By clicking | you agree to be contacted by phone or text at the number provided by Company A, B, and C.

Dynamic List of Company Names

Disclosure Text
By clicking “Submit” you agree to be contacted by phone or text at the number provided above by {DYNAMIC LIST OF COMPANIES}.

Updated with wildcard
By clicking “Submit” you agree to be contacted by phone or text at the number provided above by |.

Dynamic List of Company Names

Disclosure Text
Thank you for your time here today First-Name Last-Name. Soon agents will contact you at your phone number (999) 999-9999.

Updated with wildcard
Thank you for your time here today |. Soon agents will contact you at your phone number |.

Letter Case

The case is NOT taken into account during the matching logic.

Spacing

If the removal of a space turns two adjacent words into one word, a mismatch will result. 

However, if two adjacent words remain separate, it does not matter how many spaces are between them.

Punctuation

The TCPA matching process disregards non-connecting punctuation. ‘Non-connecting’ is defined as punctuation NOT having another character before and after.

Example of 'connecting' punctuation:

• “… receive communications via pre-recorded message …”.
• Therefore if “prerecorded” is included in the approved TCPA language, but “pre-recorded” is what is present within the TCPA labels, Jornaya will respond with a mismatch.

Example of 'non-connecting' punctuation:

• “By clicking ‘Get My Quotes’ you provide …”.
• In this case, the quotes are stripped and would match against “By clicking Get My Quotes you provide …”

Example of 'non-connecting' punctuation:

• “… including through automated means; e.g. auto dialing …”
• In this case, the semi-colon is stripped and would match against ‘… including through automated means, e.g. auto dialing …”, as the comma in the 2nd statement would be stripped.

Disclosure Appearing as Hidden

• If the code within the TCPA labels or the label itself contains "display: none" then Jornaya will register the entire disclosure as being hidden.
• The disclosure text appears in a 0x0 container.
• The elements below are hidden by default in HTML5 and should not be included
  • area
  • base
  • basefont
  • datalist
  • head
  • link
  • meta
  • noembed
  • noframes
  • param
  • rp
  • script
  • source
  • style
  • template
  • track
  • title

Additional Resource - TCPA Glossary

Check out the TCPA Glossary article which covers the data responses in TCPA Guardian that provide insight into whether a lead you purchased meets your team's TCPA compliance standards.