Safe Harbor — (reassigned numbers)
Was ist Safe Harbor?
Dieser Eintrag liegt derzeit nur auf Englisch vor.
Safe Harbor (reassigned numbers) is the FCC's TCPA shield (47 CFR § 64.1200(m)) that protects a caller from liability when a Reassigned Numbers Database check returned no permanent-disconnect record post-dating consent before the call — even if the number was, in fact, reassigned. On Orbit's GET /api/v1/compliance/rnd/check the mapping is exact: a verdict of status: "no" returns safe_harbor: true; every other verdict returns safe_harbor: false.
More detail
Safe Harbor is a pre-contact, tenant-owned control — the same ownership model as quiet hours and DNC scrubbing. You opt in per organization via organizations.settings.rnd_scrub_enabled, which is disabled by default; while it is off the check endpoint returns 403 RND_SCRUB_NOT_ENABLED rather than silently pretending to screen.
The verdict is tri-state. The registry can answer yes (a permanent-disconnect record post-dates your consent date — no Safe Harbor, do not contact), no (no disconnect record post-dating consent — the only Safe-Harbor-affirming verdict), or no_data (the database holds no usable record for the destination, so no Safe Harbor is asserted). Only no maps to safe_harbor: true; yes and no_data both map to safe_harbor: false.
The shield rests on the FCC RND snapshot being current. If the feed has not been ingested, enabling the scrub is rejected as 409 RND_FEED_NOT_CONFIGURED and the feed_synced flag stays false, with every verdict failing to no_data — the control reports its blind spot instead of returning a false all-clear.
Häufige Fragen
- Is Safe Harbor automatic?
- No. It is opt-in per organization through organizations.settings.rnd_scrub_enabled, which is disabled by default. While the flag is off, GET /api/v1/compliance/rnd/check returns 403 RND_SCRUB_NOT_ENABLED, so an org that never enabled the control can never mistake a skipped screen for a cleared one.
- What does no_data mean?
- no_data means the registry holds no usable permanent-disconnect record for the number — typically because the FCC RND snapshot (feed_synced: false) has not been ingested or simply lacks coverage for that destination. It does not affirm safety: no_data maps to safe_harbor: false, and a compliant sender treats it as a hold, not a proceed.
- Can I enable it without the RND feed?
- No. Enabling organizations.settings.rnd_scrub_enabled before the FCC RND snapshot is synced is rejected with 409 RND_FEED_NOT_CONFIGURED. The feed_synced flag on the check response reports whether the snapshot has been ingested; until it is, every verdict falls to no_data and no Safe Harbor is ever asserted.
See also
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