Publisher Compliance for TCPA Guardian
  • 04 Apr 2023
  • 6 Minutes to read
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Publisher Compliance for TCPA Guardian

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Article Summary


Jornaya’s TCPA Guardian enables lead buyers to verify if TCPA consent has been established before making an automated phone call or sending a text message to a potential customer. TCPA Guardian also enables lead buyers to identify specific characteristics of the TCPA disclosure text itself and make operational decisions based on those characteristics.

As a publisher, you want to ensure the leads you are selling meet your clients TCPA Compliance standards.

How Is Compliance Measured Through TCPA Guardian?

The Jornaya campaign script identifies TCPA Disclosure text in a web form, using the label ‘leadid_tcpa_disclosure’. The text and style characteristics are captured and compared to the lead buyer’s requirements.

The lead buyer maintains an audit profile within Jornaya’s portal. The audit profile is used to perform a query against the data captured in the lead event. During the query, a number of responses and calculations are determined. The lead buyer’s audit profile contains rules to apply against each of the returned responses.

What Are the Characteristics of a TCPA Disclosure?

Jornaya determines if a Disclosure label was present on the form, and if the Disclosure text matches any of the approved texts maintained by the lead buyer’s Jornaya profile. When a Disclosure match is made, Jornaya calculates the following responses:

• Prominence Value
Jornaya created score based on the size of the Disclosure text.

Pixel / Point SizeProminence Value
Below 9 px / 6.75pts0
9px / 6.75pts12.5
10px / 7.5pts25
11px / 8.25pts37.5
12px / 9pts50
13px / 9.75pts62.5
14px / 10.5pts75
15px / 11.25pts87.5
16px / 12pts and above100

Contrast Value
The percentage difference between the color of the Disclosure text and the text background color. The Contrast score is determined by averaging the values of Luminance, Lightness, and Color difference.

Using a combination of these calculations produces an objective assessment of the consumer perception of the foreground and background colors.

Visibility Value
Visibility is a composite score of the Prominence and Contrast scores. Visibility is calculated by multiplying Prominence and Contrast and then taking the square root of that value.

Jornaya’s TCPA Guardian also identifies the Consent Type (Checkbox, Radio button, Yes/No dropdown menu, or ‘No user interaction required’), and the action taken by the consumer (Active Consent, Passive Consent, Active Decline, Passive Decline, and ‘No interaction required on the form’). Additionally, Jornaya determines if a ‘Visual Playback’, a visual representation of the lead event, has been captured.

Why Are My Lead Buyers Getting Multiple Prominence Value Responses for the Same Funnel/Landing Page/Presentation?

Even though you may have specified the exact font size in pixels you want your consumers to experience, Jornaya may return multiple Prominence Values for the same "presentation". Our research suggests the variation results from changes consumers make to their device/browser settings and the Jornaya response is a reflection of consumers' actual experience.

How Do Lead Buyers Decision Based on TCPA Data?

Jornaya provides a portal where lead buyers can create and configure an audit profile. The audit profile is used to assess the TCPA responses, among other Jornaya responses, regarding the lead event. Jornaya allows lead buyers to set rules in their audit profile for each of the Jornaya responses, including the TCPA responses. The buyer can set the threshold for response values that are associated with each of their rules. Jornaya allows ‘flag colors’ (green, yellow, or red) to be assigned to each rule, and an assigned threshold value (or range of values) to each flag color. The lead buyer can then act on the flag colors Jornaya returns (i.e Accept/Review/Reject).

These rule settings allow lead buyers to establish their definition of TCPA compliance.

How Do I Meet My Lead Buyer’s TCPA Visibility Acceptance Criteria?

The best way to meet your lead buyer’s TCPA acceptance criteria is to ensure your TCPA Disclosure text matches the lead buyer’s required language. Once a TCPA disclosure text match is made, there are three additional visibility factors that you should consider: Prominence, Contrast and overall Visibility.

Matching TCPA Disclosure text
When a TCPA Disclosure label is found on the lead form, the associated text is compared against a list of acceptable Disclosure texts maintained within the query profile by the lead buyer in the Jornaya portal.

Default Flag Colors for Disclosure

Green flag – A matching TCPA disclosure was present on the lead form.
Yellow flag – The disclosure found on the lead form does not match a specified TCPA disclosure.
Red flag – Jornaya cannot confirm that a specified TCPA disclosure was present during the lead event.

Jornaya will return a Prominence score based on the size of the disclosure text. A font size greater than or equal to 16 pixels (12 points) will result in a Prominence Score of 100. Disclosure text identified as being less than 9 pixels (6.75 points) will return a score of 0.

Default Flag Colors for Prominence

Green flag – Disclosure font size is at least 16 pixels (12 points).
Yellow flag – Disclosure font size is between 9 and 15 pixels (6.75 and 12 points).
Red flag – Disclosure font size is less than 9 pixels (6.75 points).

Jornaya will return a Contrast score based on the Disclosure font color and the background color. This score is the percentage of contrast between the text color and the background color.

Default Flag Colors for Contrast

Green flag – The calculated Contrast score is at least 40.
Yellow flag – The calculated Contrast score is between 25 and less than 40.
Red flag - The calculated Contrast score is less than 25.

Jornaya will return a Visibility score based on the combination of Prominence and Contrast.

Default Flag Colors for Visibility

Green flag – The calculated Visibility value is greater that 50.
Yellow flag – The calculated Visibility value is between 20 and 50.
Red flag – The calculated Visibility value is less than 20.

How Can I Ensure a Specific Visibility Score?

There are numerous ways to meet any specific Visibility score by adjusting Prominence (font size) and Contrast (font color & background color). Below are three examples of how to ensure a Visibility score of at least 50 while maintaining a consistent background color (white) using Jornaya’s Visibility Sandbox.

#1 - What is the minimum Prominence score I need to generate a Visibility score of 50?

When Contrast is 100 (black text on white background, or white text on black
background), the minimum Prominence score needs to be at least 25, or 10 pixels (7.5 points).


#2 - What is the minimum Contrast score I need to generate a Visibility score of 50?

When Prominence is 100 (16 pixels / 12 points, or greater), the minimum Contrast score needs to be at least 25.

#3 - What is the smallest combination of Prominence and Contrast I need to generate a Visibility score of 50?

A Prominence score of 50 (12 pixels / 9 points) and a minimum Contrast Score of 50 will produce a Visibility score of at least 50.

I’m Doing Everything Right, Why Would I Be Missing TCPA Data?

Jornaya witnesses the consumer’s interaction with a lead form, in real time, throughout the lead event. During the event, the consumer’s browser sends numerous pieces of data across the internet to Jornaya. The context in which consumers interact with your form can impact Jornaya’s ability to capture data in some instances. Unreliable networks, especially when using devices on cellular networks, can occasionally prevent Jornaya from receiving all the data from a consumer event.

Additionally, the browser itself can result in some data to not get captured. Older browsers may not support more robust transport protocols, causing Jornaya to use transport protocols that are less reliable.

Also, older browsers may have limited support to detect DOM mutations which can cause Jornaya not to capture every consumer interaction.

Need Further Assistance?

Please visit our Frequently Asked Questions page for TCPA Guardian or reach out to our support team (

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