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Check the background of those you contract with

As a phone-paid service provider operating under the Code of Practice, you must check the background of organisations that you intend to contract or enter into commercial arrangements with. This is known as ‘due diligence’. You also need to have safeguards in place during the contract.

What to check for before you contract

It’s up to you to decide what information you gather when checking a company, but this could include:

  • contact details for a client’s place of business
  • copies of each client’s entry or entries in the Companies House register
  • names and addresses of all owners and directors
  • the names and details of any parent or holding company which the client is a part of

You may also want to check the company’s history to see:

  • if they have breached the Code of Practice in the past 
  • whether any individuals associated with the company have been personally subject to a Tribunal sanction

Tip: You can double-check the information a company gives you by logging into your Registration Scheme account and selecting the ‘Due Diligence’ tab.

Useful documents:
General guidance note: due diligence and risk assessment and control on clients (pdf)

After you have entered into a contract

You must have safeguards for assessment in place during the contract to prevent harm to consumers.

These could include:

  • inspecting their due diligence and risk assessment processes
  • testing and monitoring risks associated with the service
  • putting in place internal checks if there are spikes in traffic or lots of consumer complaints
  • having a procedure to address problems or complaints

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