Summary

  • The CRTC issued a C$350,000 notice to ZenLeads on 16 October and a C$215,000 notice to Cognism on 19 October for violations of the rule governing disclosure of the National Do Not Call List.
  • The list may be used to comply with calling rules. Section 10 controls its release outside an organisation, including to affiliates; section 11 permits a narrow confidential supplier arrangement.

A company subscribes to Canada’s National Do Not Call List so it can avoid calling people who do not want the call. The list is useful precisely because it contains the people a telemarketer must leave alone. Give that file a second career as a contact product, and the compliance tool starts working for the wrong side of the phone.

The Canadian Radio-television and Telecommunications Commission has now issued two separate October notices under Part II, section 10 of its Unsolicited Telecommunications Rules. On 16 October it imposed a C$350,000 administrative monetary penalty on ZenLeads Inc. Its notice says the company disclosed portions of the list between 1 October 2025 and 1 September 2026. On 19 October the regulator imposed C$215,000 on Cognism Limited for conduct between 1 February 2024 and 31 January 2026 that resulted in section 10 violations. Those figures add to C$565,000. They are two cases, not one joint order.

The rule has teeth because access has a purpose. Section 9 confines use of the list to compliance with the calling rules. Section 10 restricts selling, renting, leasing, publishing or otherwise disclosing all or part of it outside the subscriber’s organisation; an affiliate counts as outside. Section 11 provides a narrow path for confidential disclosure to a service supplier when necessary for compliance, while section 12 requires reasonable efforts to stop that supplier from passing it on or using it for another purpose. The law allows work to be delegated. It does not turn the suppression file into a free-floating asset.

The public notices leave a practical hole in the record: neither gives a recipient or a count of numbers disclosed. ZenLeads’s notice names disclosure of portions; Cognism’s establishes section 10 violations without describing the same mechanism. The CRTC enforcement index records both as notices of violation or settlement. The regulator has identified the broken boundary and priced each case. The route by which the data travelled remains the next question.

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