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Providing compliance enforcement for manually dialed wireless

1. eoueilduio onuo YOUMS 19 oat 009 SCA SEZ 3 UNMS uonejs om s4uaby U S Patent US 8 738 076 B1 Sheet 10 of 11 May 27 2014 U S Patent 6 Sls asealoy 2D aseajoy LD aseajay I2 12D suonisodsig jueby a NISd 58185 e uaiejuo5 6 7 e 92uaJsjuoo gto 691 jep e2u219jJu02 JequinN SS9jeJIAA OL 12D eyeuibuo JequinN SSejeJIM 40 SHS peieia JequinN SSAIM Jo Jdladsy 10J vedasid juaby oj dies Ile jueBy 0 dnyag jie P RRS Wa PHO JequinN juasaidg eseojey eo JeAlas eoueljdulo pue euoug SjueDy ueewjeg Ai ioe4 Duis peusiiqeis3 lep AeAA OM anjeg HPD SUNAM 006 puc JequinN JUuasald X8d Vv sz aoueldwo5 SEL LOL Jequinu xeu 10 yeodoy euoud dO y uones WOM s1ueBy US 8 738 076 B1 Sheet 11 of 11 May 27 2014 U S Patent Ol Sls 6001 ainpoy soueldwoy 8001 wa sks BuneJedo ZOOL 9001 Kiowa e IjejoA UON Kowa LA SOOT ZO0r TOOT 1 1 0 U09 s ve Ul JOSSOD01g q3ndinonduj suoneoiunuJuo sjeeuduegd OL YIOMJON OL Se 0001 US 8 738 076 B1 1 PROVIDING COMPLIANCE ENFORCEMENT FOR MANUALLY DIALED WIRELESS NUMBERS IN A CONTACT CENTER RELATED APPLICATIONS This application claims priority to provisional U S patent application No 61 813 713 entitled Compliance Enforce ment for Manually Dialed Wireless Numbers in a Contact Center which was filed on Apr 19 2013 and the contents of which are incorporated by r
2. BRIEF DESCRIPTION OF THE DRAWINGS FIG 1 illustrates one embodiment ofa contact center archi tecture incorporating a compliance server providing compli ance enforcement when an agent originates a call to a wireless number FIG 2 illustrates one embodiment of an architecture com prising a compliance server and a PBX in a contact center used to provide compliance enforcement when an agent origi nates a call to a wireless number FIG 3 illustrates one embodiment of a message flow between various components for providing compliance enforcement when originating a call to a wireless number US 8 738 076 B1 3 FIGS 4A and 4B illustrate one embodiment of a process flow of the compliance server when used for providing com pliance enforcement FIG 5 illustrates another embodiment of a message flow between various components for providing compliance enforcement when originating a call to a wireless number FIG 6 illustrates another embodiment of a process flow of the compliance server when used for providing compliance enforcement FIG 7 illustrates another embodiment of an architecture comprising a PBX in a contact center used for providing compliance enforcement when an agent originates a call to a wireless number FIGS 8 9 illustrate additional embodiments of a message flow between various components for providing compliance enforcement when originating a call to a wireless number FIG 10 illustrates one embodiment of a syste
3. US 8 738 076 B1 Page2 56 References Cited Noble Systems Corporation Maestro 2010 1 1 Manual vol 4 IVR Oct 27 2010 pp 1 318 Noble Systems Corporation Atlanta GA Office Action received for U S Appl No 13 958 011 dated Dec 13 OTHER PUBLICATIONS 2013 Office Action received for U S Appl No 13 958 011 dated Mar 26 Noble Systems Corporation Maestro 2010 1 1 Manual vol 3 2014 Reports Aug 18 2010 pp 1 124 Noble Systems Corporation Atlanta GA cited by examiner US 8 738 076 B1 Sheet 1 of 11 May 27 2014 U S Patent SZ aJoys ejeq SF Ger JeAleg eo2uer duio2 lOLL L Sls eech jeuJoju qez 1 u49 U 00L e JL U S Patent May 27 2014 Sheet 2 of 11 US 8 738 076 B1 200 Q e mE FIG 2 Compliance Agent Workstation Old MAS 8s 11eD eseajay M parowy yed oipny V 96 jep eseajay CGE snes jueby eyepdr US 8 738 076 B1 jje2 suonisodsig usby m 0 o 1 0 EE Cpe S8U0 POJWOD puequ gt SVE snes Neo i uojuioo PUEqU 1 Q 1ueBy eyepdn em e ig 1 m peusiqejs ujeg oipny 1x e dmes ie TUE en EE BEE smeis E E jueBy apd A N Vries HE c z vee mes quaby Yt ejepdp Buisse old EE eougi dui02 8jny ue TP i N S U0 YOJWOD puequ f ierg 0 Aeyo Aang l N leig 0 jequinN ssajam sJejua juaby 1 m R zm Bld 0 jequinN SSAIM 1X9N 1U9S84d 9ct 4 snes
4. interpreted code machine code executable instructions and or the like also referred to herein as executable instructions instructions for execution program code and or similar terms Such tangible non transitory computer readable stor age media include all the above identified media including volatile and non volatile media but does not include a tran sitory propagating signal Non volatile computer readable storage medium may specifically comprise a floppy disk flexible disk hard disk magnetic tape compact disc read only memory CD ROM compact disc compact disc re writable CD RW digital versatile disc DVD Blu ray disc BD any other non transitory optical medium and or the like Non volatile computer readable storage medium may also comprise read only memory ROM programmable read only memory PROM erasable pro grammable read only memory EPROM electrically 20 30 35 40 45 50 55 60 65 28 erasable programmable read only memory EEPROM flash memory and or other technologies known to those skilled in the art Conclusion Many modifications and other embodiments of the con cepts and technologies set forth herein will come to mind to one skilled in the art having the benefit of the teachings presented in the foregoing descriptions and the associated drawings Therefore it is to be understood that embodiments other than the embo
5. local time zone of the called party limiting the number of attempts per telephone number individual or account holder limiting the number of messages left voice mail or answer ing machine messages associated with a telephone number and ensuring there is a minimum amount of time between call attempts per telephone number individual or account holder Relying on human operator skill to meet all the applicable compliance requirements is likely to result in a compliance violation sooner or later For example an agent in a contact center may be located in the Eastern Time zone At 9 00 a m in the Eastern Time zone it is 6 00 a m in the Pacific Time zone Regulations may allow the agent to dial a number terminating in the Eastern Time zone but not in the Pacific Time zone Given a particular number it may be difficult for the agent to know what time zone the called party is in While this may be manually determined computerized approaches are faster and more accurate Predictive dialers have safe guards that ascertain the time zone of the target telephone number and or compare this with the corresponding person s residential location to determine whether the call can be origi nated An agent may make an error and call an individual in the Pacific Time zone at 6 00 a m Further complicating meeting the compliance require ments is that typically a group of agents is involved in dialing the target parties Coordination between
6. The communication may use a variety of data trans US 8 738 076 B1 27 mission protocols such as fiber distributed data interface FDDI Ethernet asynchronous transfer mode ATM or frame relay The input output controller 1003 may also communicate with one or more input devices or peripherals using an inter face 1004 such as but not limited to a keyboard a mouse a touch screen display input microphone pointing device etc The input output controller 1003 may also communicate with output devices or peripherals such as displays printers speakers headsets banner displays etc The processor 1001 may be configured to execute instruc tions stored in volatile memory 1006 non volatile memory 1007 or other forms of computer readable storage media accessible to the processor 1001 The volatile memory 1006 may comprise various types of memory technologies includ ing but not limited to random access memory RAM dynamic random access memory DRAM static random access memory SRAM and other forms well known to those skilled in the art The non volatile memory 1007 may comprise various technologies including but not limited to storage media such as hard disks floppy disks read only memory ROM programmable read only memory PROM electrically erasable read only memory EPROM flash memory and other forms well known to those skilled in the art The non volatile memory 1007
7. 2 the agent s workstation comprises the phone 161 which is a softphone and a computer 160 The computer is used to provide information to the agent relating to the account that theagent will dial The computer may have a communications channel 132 to the compliance server 125 for receiving such data and another communications channel 134 to the PBX 135 used for the wireless call origination This configuration may vary inother embodiments Further the communications channels 134 132 may represent different physical or logical channels in different embodiments The PBX 135 is connected to the PSTN 115 via facilities 123 which is turn is able to route calls to wireless numbers associated with a mobile phone 110c or calls to wireline numbers associated with a conventional telephone 110b 20 25 30 35 40 45 50 55 60 65 10 Although the PBX can be used to originate calls to wireline numbers the illustrations herein largely focus on originating calls to wireless numbers The compliance server 125 is illus trated as having facilities 121 to the PSTN This can be used to originate other calls to wireline numbers or receiving incoming calls In some embodiments the compliance server does not have any facilities 121 for conveying voice traffic to the PSTN 115 or the Internet Again since the illustrations herein largely focus on originating calls by the PBX to wire less numbers the communication facility 121 is not
8. 336 the PBX proceeds by establishing a 3 way call i e a conference call using a conference bridge 340 wherein a first call leg 342 1s estab lishedto the compliance server 125 This again can be accom plished using any well known protocol such as session initi ated protocol SIP integrated services digital network ISDN H 323 etc After the compliance server confirms to the PBX that the call may proceed at operation 336 the compliance server may start a timer in expectation of receiv ing the incoming call leg 342 from the PBX In one embodi ment information is conveyed in the ANI calling party num ber or DNIS called party number of the call leg 342 that may indicate the wireless number dialed by the agent to allow the compliance server to associate the call leg 342 with the agent and the number selected by the agent Other signaling mechanisms could be used in other embodiments The expiry ofthe timer indicates an exceptional condition such as aban donment of the entire process or a failure of the PBX Once the compliance server receives the incoming call leg 342 the compliance server will update the status associated with the agent in operation 345 Although not shown in FIG 3 the compliance server may further bridge the call leg 342 with a recording system not shown that may involves another call leg originating from the compliance server In other embodiments the recording ofthe call may involve the comp
9. agents is required so that duplicative efforts are avoided It is easy to imagine various scenarios where this can occur including for example where an agent dials a target party and leaves a message and is shortly followed by another agent calling that same number and leaving another message In certain con texts the result could be deemed harassment Further the set of requirements that are applicable to dial ing a particular call may change in the future Additional regulations may be imposed as well as changing contact center policies may have to be adhered to Thus the challenge is how to ensure that manually dialed calls to wireless num bers by agents in a contact center are still subjected to com pliance enforcement Further the infrastructure should be adaptable to future or changing requirements While dialers are well suited for processing a number to enforce compli ance aspects they cannot be used to dial the wireless number itself in certain situations in light of some interpretations of the applicable statutes and FCC regulations Thus an approach is required for coordinating the compliance enforcement mechanisms in a dialer with calls established by the PBX Contact Center Context FIG 1 shows one embodiment of a contact center archi tecture 100 illustrating the various technologies disclosed herein Although many aspects of contact center operations are disclosed herein in the context of voice calls the contact c
10. as originate or receive outside calls via facilities 123 to the PSTN or facilities 1167 local network 170 and 116 to the Internet 1230 Vari ous topologies and configurations are possible as to how the PBX may provide access Specifically an agent may dial a number to place a call such as to a wireless device 110c using a conventional VoIP or ISDN phone 161a c using facility 165 via PBX 135 In some embodiments the agent may dial the number to place the call via phone 161a using facilities 168 and 1167 via the PBX Normally agents may communicate using a phone with either a PBX or a dialer in a contact center but not both The PBX and dialer are typically configured so that each can complete their respective call processing functions for either incoming or outgoing calls as may be appropriate in a stand alone configuration without requiring cooperation with each other to complete a call In addition the contact center may incorporate a compli ance server 125 The compliance server 125 may connect via facilities 116 to the local network 170 which in turn may provide access to facilities 165 to phones as well as facilities 168 for voice and data depending on the contact center con figuration The compliance server may have facilities 127 to the PBX the role of which is discussed further below In some US 8 738 076 B1 9 embodiments the compliance server 125 may be a modified dialer or incorporate aspects of a diale
11. juaby eyepd onejs s jueBy 10 Buisssooig ue Buerg ejeAgov uo so jusby occ J9AIBS 7 euoud Jayndwog 7 NiSd a 094 att 00 ud sz 9ouepduo Ger Aud Hoh uonexs uom sque U S Patent U S Patent May 27 2014 Sheet 4 of 11 US 8 738 076 B1 Start 400 404 1 x Receive Agent Log On 406 Retrieve Agent Profile Information 408 Activate Dialing Plan for Agent in 450 PBX 410 Present Wireless Number s to Agent on Computer Workstation 412 Receive Agent s Selection Optional 414 Receive Query from PBX 418 No Deny Request 416 Okay to Dial Number Yes 420 Confirm To PBX 421 Receive Call Setup From PBX gt 425 FIG 4A U S Patent May 27 2014 Sheet 5 of 11 US 8 738 076 B1 422 Information Match Selected Number FIG 4B US 8 738 076 B1 Sheet 6 of 11 May 27 2014 U S Patent 8 Sls gsg le aseajay cn i jj 2 se j y i l CSS snes i juaby ejepdn l I a ie suonisodsiq jueby oss D j 8 GYS snes a3 juaby ayepdq i 9 t gt ESSE JEF l JAQWINN SSo 9JIM 1V g sBe7 129 i joeuuo2 12 OE 3 oOo OQ dnjes e2 1o pauio i Les 1 leig 0 JequinN ssaa S193u3 juoby I p Jeiq 0 JequinN SSM IXON JUGS 4 9cS 4 smes jue8y ajepdp z uo s607 jusby Des ied ee BuipiooeyM JAS TN 2 9U0ud Jayndwog E 7 em 09L SLL SOS gg BoueNdwuog 006 Vv GEL 194 uogejsoM sjueby U S Patent May 27 2014 Sheet
12. may store program code and data which also may be loaded into the volatile memory 1006 at execution time Specifically the non volatile memory 1007 may store one or more computer program modules such as a compliance module 1009 containing instructions for performing the process and or functions associated with the technologies disclosed herein and related data 1010 and or operating system code 1008 In addition the compliance module 1009 may generate or access the data 1010 in the non volatile memory 1007 as well as in the volatile memory 1006 The volatile memory 1006 and or non volatile memory 1007 may be used to store other information including but not limited to records applications programs scripts source code object code byte code compiled code interpreted code machine code executable instructions or the like These may be executed or processed by for example the processor 1001 These may form a part of or may interact with the compliance module 1009 and or data 1010 The technologies described herein may be implemented in various ways including as computer program products com prising memory storing instructions causing a processor to perform the operations associated with the above technolo gies The computer program product comprises a tangible non transitory computer readable storage medium storing applications programs program modules scripts source code program code object code byte code compiled code
13. processes the received digits and then may transmit a query to the compliance server 125 at operation 332 The query essentially asks the compliance server whether it is okay for the PBX to dial the call Or in other words have the appro priate compliance requirements have been met The query typically includes the number dialed by the agent as well as the station ID and or agent ID Other information may be included in the query The query can be structured according to a number of available protocols known by those skilled in the art including any of the Internet related protocols tele phony based protocols proprietary protocols including H 323 protocols Inter Asterisk Exchange Protocol IAX etc In some embodiments the query is optional as the com pliance server can confirm or deny authorization for the call to proceed upon receipt of a call leg from the PBX see below In one embodiment the PBX is not aware of the various compliance requirements nor does the PBX store the dialing list including the wireless number nor produce the wireless number to the agent Thus the PBX may not know if the number was just dialed by another agent but the compliance server may know Consequently the PBX relies upon the compliance server to perform the compliance processing and hence asks the compliance server whether the number can be dialed If the compliance server 125 has not already done so the compliance server 125 applies the
14. processors which can be executing within a common processing system The facilities 727 may bea signaling link so that that information about the wireless number and whether the call is allowed to proceed is indicated via a signaling link and no conference call leg is established between the switch and control module 735 and the compliance module 725 The agent may use a workstation comprising a computer 160 and a softphone 161 which are connected to the PBX 135 via facilities 738 The facilities 738 may carry data as well as digitized voice In operation the messaging flow may be as shown in FIG 8 In FIG 8 the messaging diagram 800 shows the agent s workstation comprising the computer 160 and phone 161 Further illustrated are the switch and control module 735 the compliance module 725 and the PSTN 115 The process may begin with the agent logging onto the compliance module 725 in operation 820 using their com puter 160 The compliance module 725 now knows that the agent is available to dial a call and may update agent status information in operation 826 Next the compliance module 725 may present the next wireless number for the agent to dial in message 828 This step may be optional in that the com pliance module may not offer the wireless number to dial but simply receive the wireless number to dial in message 830 Once the compliance module receives the number to dial then in operation 834 it performs the appropriate complian
15. received from the PBX The call is then received from the PBX in operation 421 The process continues to label A 425 on FIG 4B Turning to FIG 4B the incoming call may indicate via the calling called party number the wireless number dialed by the agent This allows the compliance server to know that the incoming call correlates to the prior query Other signaling mechanisms may be used A check may be made in operation 422 to ensure that the query for the indicated wireless number matches the calling party number in the call setup If not then in operation 424 an error message may be sent to the PBX If the wireless number is not indicated in the incoming call then this step may be skipped or may be accomplished in a differ ent manner Assuming there is a match in operation 422 the compli ance server may monitor and or record the call in operation 430 The compliance server may monitor the call process tones analyze the conversation record the speech etc Once the agent completes the interaction with the called party one of several options may be pursued In one option the compliance server receives a disposition code in operation 432 from the agent If so the compliance server then releases the call leg to the PBX in operation 434 The process then returns to label B 450 in FIG 4A Another option is that the remote party will have released their call leg to the PBX If so the PBX may then release the call leg to the compliance s
16. server may perform compli ance enforcement at a later stage see processing operation 334 below After receiving a message at operation 328 the agent reviews the account information on their computer screen It is presumed that if multiple accounts and or telephone num bers are presented that at least one number is a wireless number and that information is conveyed to the agent indi cating it is a wireless number Of course if the entire list comprises wireless numbers then the agent may be informed at the beginning when reviewing the list or otherwise under stand that all numbers are wireless numbers The agent may then manually dial the wireless number presented on the computer screen using the phone that is connected to the PBX 135 This is represented by the signal ing at operation 330 in FIG 3 Based on the phone technology used by the agent there may be a series of distinct inputs by the agents as they individually press a key or screen icon indicating a dialed digit of the called telephone number For simplicity a single message at operation 330 is shown Different phone technologies may be used by the agent The phone may be an analog phone in which the agent presses physical keys on the phone to generate dual tone multiple frequency DTMF tones The phone may be a physically distinct VoIP phone or an ISDN based telephone also having a keypad In this case the agent pressing a key may result in SIP or ISDN signaling
17. status or disposition code Thus the compliance server may have exposure to all of the audio data associated with the call in order to perform the complete suite of compliance enforce ment functions It should be appreciated that in this arrangement the agent has initiated the call via the PBX not the compliance server Further although the compliance server may have indicated to the agent one or more wireless numbers to be dialed the agent selected the number and manually dialed the wireless number using the PBX in a similar manner to that which the agent would use to perform any other manually dialed call using the PBX Further the PBX does not store produce or access a database for originating the call to the wireless user It should also be appreciated that the above steps may vary in different embodiments Specifically the call leg to the agent the call leg to the compliance server and the call leg to the called party may be variously established serially in par allel or in combination In some embodiments the audio path to the agent may be maintained between calls In other embodiments the audio path to the compliance server may be maintained and other signaling approaches are used to con vey the dialed number to the compliance server No doubt those skilled in the art can develop other variations for coor dinating the compliance server and the PBX upon reading this disclosure Once the agent has completed their interac
18. the dialed party is established mimicking the POTS opera tion In some embodiments the DTMF tones are not the basis for actually conveying address information between the PBX and the telephone network as that information may be con veyed by other forms of out of band signaling including SIP ISDN or MF However in other embodiments the PBX may be a TDM based system that does actually provide and use DTMF for conveying dialed digits It should be recognized that a wide variety of arrangements are possible for providing tones to the agent to reflect the manually dialed wireless number Once the dialed party answers the call leg 348 a three way or conference call is established between the agent the called US 8 738 076 B1 15 party and the compliance server The compliance server is largely listening and may not provide any audio to the conference The compliance server may perform recording quality analytics speech analytics etc similar to as if a predictive dialer had originated the call For example the compliance server may monitor any in band tones or signals provided by the PSTN or remote party such as a busy signal answering machine greeting or other special information tone SIT tone The SIT tone can indicate whether a num ber is disconnected ported etc This allows the compliance server to properly record the status of the call 1 e disposition the call as opposed to the agent manually entering the
19. to or from the contact center regardless of the type of protocol or technology used Specifically a trunk as referred to herein is not limited to time division multiplexing TDM technology Voice calls may also be received by a party employing a so called IP phone VoIP phone or soft phone 110a In one embodiment the soft phone may comprise a computing device 105 such as a laptop desktop or computing tablet which interfaces with a headphone microphone combination also referred to as a headset 106 An IP phone may use a digital voice control protocol and may process packetized voice data according to various Internet based voice proto cols such as session initiated protocol SIP The call may be conveyed by other types of Internet providers 123a such as a cable company providing Internet access services over a coaxial cable facility 116e Those skilled in the art will rec ognize that a variety of protocols and facilities may be used to convey voice calls In the contact center calls may be routed over facilities 165 to agents for servicing These facilities may be time division multiplexed TDM or voice over IP VoIP based After a call is originated by the dialer 155 and a called party answers the call may be connected with an agent using facili ties 165 The physical area at which the agent sits is often referred to as the agent s position and these positions are of
20. 5 20 25 40 45 22 Thus in some embodiments the dialing list is not integrated with wireline and wireless numbers since inefficiencies are introduced when dialing wireline numbers individually If the number is a wireless number in operation 625 then the compliance server establishes a connection between the agent s phone and the PBX using the facility 127 between the PBX 125 and compliance server 135 This facility could be analogous to a tie trunk between the two which is a perma nent connection for voice or a data connection The agent s phone is connected to the compliance server and connects the agent to the PBX In one embodiment the agent is connected to a tone receiver in the PBX In this case the agent may dial the wireless number to the PBX although the information may be relayed through the compliance server In another embodiment the compliance server may transmit the dialed digits to the PBX A bridge may be present in the compliance server so as to monitor and record the progress of the call For purposes of illustration it is presumed that the com pliance server connects the agent to the PBX that then allows the agent to originate the call by the PBX In operation 635 the facility 127 is used to connect the agent to the PBX Next the PBX may provide dial tone back to the agent s phone in operation 640 The agent in response manually dials the number displayed on the computer screen using the appropr
21. 7 ABSTRACT Related U S Application Data Systems and methods are disclosed for originating a call to a T T uh wireless number by a contact center while enforcing various 60 Provisional application No 61 813 713 filed on Apr compliance requirements In one embodiment a compliance 19 2015 server and a PBX cooperate to originate the call to the wire less number The agent logs into the compliance server and 51 Int Cl the compliance server provides the agent with a wireless H04M 1 00 2006 01 number to dial The agent manually enters the wireless num 52 U S CI ber using a phone connected to the PBX The PBX queries the USPC 455 555 455 426 2 455 462 455 554 1 compliance server regarding establishing the wireless call 455 554 2 455 556 1 Upon authorization the PBX establishes a first call leg to the 58 Field of Classification Search compliance server and a second call leg to the called party CPC H04W 84 14 HO4W 84 16 HO4M 3 42314 that is joined with the call leg to the agent s phone Upon HO4M 3 42323 HO4M 3 4234 completion of the call the agent dispositions the call to the USPC 455 412 1 426 2 428 460 519 527 compliance server which then releases the first call leg In ee 5 7 458 554 1 557 response the PBX then releases the second call leg See application file for complete search history 26 Claims 11 Drawing Sheets 1616 N lic 160a 160b lt gt 460c R Server 125 Data Store 175
22. 7 of 11 US 8 738 076 B1 oe Retrieve Next Set of Telephone Numbers for Potential Dialing 615 Display Records including potential telephone numbers ey Receive Agent Selection of Telephone Number 630 625 um f No Originate Calls Using s Number a wireless ni Conventional Predictive number oar Dialing Yes 635 Establish Connection Using Trunk between Dialer and PBX 640 Provide Dial Tone To Phone Via oS Receive Dialed Number as DTMF tones from Phone 650 Originate Call To Wireless Number By PBX 655 Agent Terminates Call Agent Dispositions Call Done US 8 738 076 B1 Sheet 8 of 11 May 27 2014 U S Patent A l4 uongjsyJ0A 1ueDy SEZ Sel anpo anpon JONUOD 9 YMS eoueiduo5 Sel X8d ech ed uo Lh 8 9lJ i US 8 738 076 B1 898 HE9 eseajay direc A2 i M parowy Yed oipny 098 I ieS eseejor pueuuo 998 88 smeg quaby eyepdr I leg suonisodsig jueby oss i 6re sneis 5 jueBy eiepd E 0 dnies ie5 IDIOT CC SERE Ms ovo p S900 Mojoo puequi i g 1 2 pousiqeis3 Wed oipny ree i SY8 smejs e jueBy aiepdn i e g g 1 8 o a 2 A IequnN leid 3 8 EB ei queby VS ayepdn Bussid x aouRldwo ainy So N j oeg eQ eig o Jequinw ssam saug jue 8v i S ezg BIG 01 JOQUINN SSAIM 1X9N 1u9 94d x 9c8 smes 1ueBy eyepdn uo sBo11ueDy Res SIDON ajnpoyy 777 3uOud Jejnduio2 gs NUS a
23. G 10 is an exemplary schematic diagram of a processing system 1000 that may be used in an embodiment to practice the technologies disclosed herein such as the PBX 135 orthe compliance server 125 In general the term processing sys tem may be exemplified by for example but without limi tation a personal computer server desktop computer tab lets smart phones notebooks laptops distributed systems servers blades gateways switches and the like as well as any combination of devices or entities adapted to perform the functions described herein As shown in FIG 10 the processing system 1000 may include one or more processors 1001 that may communicate with other elements within the processing system 1000 via a bus 1005 The processor 1001 may be implemented as one or more complex programmable logic devices CPLD microprocessors multi core processors digital signal pro cessors DSP system on a chip SOC co processing entities application specific integrated circuits ASIC field programmable gate arrays FPGA programmable logic arrays PLA hardware accelerators other circuitry or the like In one embodiment the processing system 1000 may also include one or more communications interfaces 1002 for communicating data via the local network with various exter nal devices In other embodiments communication may be via wired optical or wireless networks or a combination thereof
24. US008738076B1 az United States Patent 10 Patent No US 8 738 076 B1 Hitchcock et al 45 Date of Patent May 27 2014 54 PROVIDING COMPLIANCE ENFORCEMENT 56 References Cited FOR MANUALLY DIALED WIRELESS NUMBERS IN A CONTACT CENTER U S PATENT DOCUMENTS 2 5 850 433 A 12 1998 Rondeau 379 218 01 71 Applicant Noble Systems Corporation Atlanta 7 783 290 B2 8 2010 Kim GA US 8 606 245 B1 12 2013 Eccelston et al 2005 0048967 A1 3 2005 Hoglanderetal 455 426 1 a 2007 0015553 A1 1 2007 Siddiqui 72 Inventors Chad Hitchcock Johns Creek GA 2009 0003316 A1 1 2009 Leeetal ss 370 352 US Ellwood Neuer III Newnan GA 2011 0165858 Al 7 2011 Gisby et al o on 455 411 US 2012 0088475 Al 4 2012 Portman et al 455 412 1 2013 0065558 A1 3 2013 O Neiletal 455 411 2013 0143539 AI 6 2013 Baccay etal 455 416 73 Assignee Noble Systems Corporation OTHER PUBLICATIONS Notice Subject to any disclaimer the term of this Noble Systems Corporation Maestro 2010 1 1 User Manual vol 1 patent is extended or adjusted under 35 Aug 17 2010 454 pages Noble Systems Corporation Atlanta GA U S C 154 b by 0 days Noble Systems Corporation Maestro 2010 1 1 User Manual vol 2 Aug 3 2010 416 pages Noble Systems Corporation Atlanta GA 21 Appl No 13 902 130 jos Continued 22 Filed May 24 2013 Primary Examiner Dai A Phuong 5
25. a basic function of an autodialer as equipment having the capacity to dial numbers 20 25 30 35 40 45 50 55 60 65 2 without human intervention Id 4131 Thus it appears that equipment having the capacity to dial number without human intervention may be an autodialer regardless of whether such equipment is actually used in such a manner As can be expected it is not always clear whether an equipment configuration is considered an autodialer Thus the problem addressed by the present disclosure is ensuring that compliance related regulations and policies are adhered to while also complying with the mandate that prohibits the use of autodialers to call wireless numbers It is against this backdrop that the concepts and technologies disclosed herein are presented SUMMARY Various embodiments are disclosed for providing compli ance enforcement in a contact center when an agent originates a call to a wireless number In various embodiments a com pliance server and PBX cooperate to allow manual dialing by the agent using the PBX while allowing the compliance server to ensure that various compliance regulations and or policies are adhered to in conjunction with originating the wireless call The compliance server is able to maintain status information associated with the agent and or the wireless call even though the compliance server itself does not originate the call In one embodiment co
26. agent indicates to the compliance server that the wireless number they have selected in message 922 the com pliance server 125 will establish a call using messages 924 and 926 through the PBX 135 to the agent s phone This results in a voice connection between the compliance server and the agent s phone In some embodiments the compliance server may provide an audible announcement to remind the user to dial the wireless number The announcement could be e g Please dial 404 555 1212 This would correspond to the same wireless number previously selected by the agent in message 922 20 25 30 35 40 45 50 55 60 65 26 This call that is established through the PBX is slightly different than a conventional call in that the PBX is expecting to receive the wireless number from the agent and will use that to establish a conference call and a call leg to that number and then join that call leg to the established call This type of conference bridge allows the agent as the answering party to request a conference call Consequently in operation 928 the PBX prepares or expects to receive the wireless number from the agent The wireless number may be transmitted via DTMF tones SIP INFO messages or some other form as is well known to those skilled in the art in message s 930 The PBX must know that it should process the wireless number accordingly Thus for example if DTMF tones are used by the agent to convey th
27. all leg are connected to form a three way confer ence call between the phone being used by the agent the compliance server and the wireless device associated with the called party 2 The system of claim 1 wherein the compliance server is configured to establish the agent has logged in prior to informing the agent of the wireless telephone number 3 The system of claim 1 wherein the indication that the agent has originated the call comprises the agent manually dialing digits on the phone being used by the agent corre sponding to the wireless telephone number 4 The system of claim 3 wherein the compliance server is configured to determine the digits dialed by the agent corre spond to the wireless telephone number prior to establishing the first call leg 5 The system of claim 1 wherein the indication that the agent has originated the call comprises the agent selecting the wireless telephone number on a display being used by the agent 6 The system of claim 1 wherein the compliance server is configured to establish a voice path between the compliance server and a recording system upon receiving the indication so that the call can be recorded by the recording system US 8 738 076 B1 29 7 A method for ensuring compliance adherence for a call to be placed to a called party from a contact center using a wireless telephone number the method comprising the steps of determining by a compliance server whether the call to be
28. an indication that the agent has originated the call to be placed to the called party establish a first call leg between the compliance server and a phone being used by the agent and 20 25 30 35 40 45 50 55 60 65 30 establish a second call leg between the compliance server and a private branch exchange wherein upon receiving the wireless telephone number the private branch exchange establishes a third call leg between the private branch exchange anda wireless device associated with the called party using the wireless telephone number and the third call leg the second call leg and the first call leg are con nected to forma three way conference call between the phone being used by the agent the compliance server and the wireless device associated with the called party 14 The non transitory computer readable medium of claim 13 wherein the computer readable instructions when executed are configured to cause the at least one computer processor to establish the agent has logged in prior to inform ing the agent of the wireless telephone number 15 The non transitory computer readable medium of claim 13 wherein the indication that the agent has originated the call comprises the agent manually dialing digits on the phone being used by the agent corresponding to the wireless telephone number 16 The non transitory computer readable medium of claim 15 wherein the computer readable instructions when
29. and again there is no need to keep the bridge up Similarly if the agent terminates their call leg first then call leg to the called party should be terminated At that point there is no need for the call leg to the compliance server so it is released as well As evident there are a number of alternatives possible in the message flows shown above The exact sequent of events that occur when the 3 way call is established can vary from what is shown and there are various alternatives for releasing the three way call Other variations exist as to when certain compliance operations are performed how the outcome of the compliance testing is indicated to the PBX and how other operations are performed FIG 3 is not intended to limit the potential ways that the overall system may operate For example as shown in FIG 3 the coordination between the PBX and the compliance server is manifested via a query 332 and response 336 The query could be implicit when the PBX establishes the call leg 342 to the compliance server In such embodiments there may not be an explicit stand alone query 332 In some embodiments the calling party telephone number used by the PBX in the call to the compliance server could be the same value as the wireless number This allows the call leg to be correlated with a particular wireless number in the compliance server The compliance server then responds by accepting the call leg or rejecting the call leg as indications
30. and the called party In operation 856 the audio path to the agent s phone is removed or otherwise the call leg is disconnected and simi larly the call leg to the wireless call party is released in message 858 Embodiment Four Another embodiment is shown in FIG 9 At a high level this embodiment is based on the compliance server originat ing a call to the agent s phone through the PBX The agent then indicates the wireless number to the PBX which then originates a call leg to the wireless number and creates a conference call More specifically the call leg to the wireless number is added to the call between the compliance server and the agent This allows the PBX to monitor the progress status of the call Furthermore this embodiment allows the compliance server to function as a predictive dialer when the number to be dialed is a wireline number and function as a compliance server if the number is a wireless number Turning to FIG 9 the messaging diagram 900 illustrates in messages 910 918 the messaging that occurs if the number to be dialed is a wireline number Later messages 920 948 will be reviewed and this illustrates the messaging that occurs if the number to be dialed is a wireless number For sake of simplicity the various operations in the compliance server where it is able to update the agent s call s status is not shown in FIG 9 as it was shown in the previous diagrams In operation the agent may be present
31. ansmitted using the same facilities 168 used to convey data to the agent s workstation computer In other embodi ments voice may be conveyed on separate facilities 165 After completing a call the dialer 155 may generate call record data that is stored in the data store 175 and the data store may include a database The call record data indicates the progress and status of the call The call record data may indicate the time the call was originated the number dialed the call disposition when the call was answered whether an answering machine was encountered etc In some embodi ments call recording of the audio data of the call may also be stored in the data store 175 The audio of the call may be analyzed by a speech analytics system to ensure that the agents properly handled the call and followed the appropriate procedures and can be used to evaluate agent performance The contact center may also incorporate a private branch exchange PBX 135 This may be embodied as a TDM or VoIP based switching device for handling voice calls as well as incorporating other capabilities Other embodiments may use a private automatic branch exchange PABX Internet Protocol PBX IP PBX or other switching device The term PBX as used herein is intended to encompass these variations The PBX 135 may allow agents to use their phones 161a 161c to originate and or receive calls to other agents using facilities 165 or 168 as well
32. at operation 320 This process indicates to the compliance server 125 that the agent is available to handle calls and allows the compliance server 125 to perform various functions associated with an agent logging on The compliance server 125 knows which agent phone extension is associated with the agent what skill level the agent has schedule what campaigns the agent may par ticipate in etc As a result the compliance server 125 updates the agent s status and adds the agent to the pool of available agents for handling calls Next the compliance server 125 may activate a trigger on the PBX 135 associated with the agent s dialing plan via signaling at operation 322 The trigger is a process in the PBX that is involved when processing call origination requests from the agent In other words this defines how the call origination for that agent s phone is to be handled by the PBX When activated the PBX will automatically establish a conference call involving the compliance server The signal ing at operations 322 and 324 are optional in that some embodiments may provision the trigger in the PBX perma nently for the agent s phone However in this embodiment the trigger for the agent s phone is only activated when the compliance server 125 determines that the agent will be engaged in a campaign involving manually dialing wireless numbers Otherwise the PBX may interpret call setup from the agent s phone in a conventional manner The PBX
33. ate dispo sition code using the workstation computer in operation 660 The compliance server by receiving the disposition code knows that the call has ended and can appropriately update the status of the account and disconnect the agent s phone to the trunk The PBX may then release any remaining call legs associated with the conference The compliance server is able to maintain status informa tion for the agent and or call in that the agent indicates the number selected Thus the compliance server knows to con nect the agent s phone with the PBX The compliance server is able to monitor the dialed number indicated by DTMF tones and know that the called party is being dialed Further the compliance server knows the call is over when the agent dispositions the call Thus even though the compliance server is not processing or originating the call to the wireless number it is aware of the general status via the agent s indi US 8 738 076 B1 23 cations As with the previous embodiment the agent origi nates calls to the PSTN via the PBX not the compliance server Maintaining Agent State Information In both embodiments the compliance server tracks the agent s status Agent status covers various status informa tion related to the agent and or the call including the status of their desktop space their log in status their call origination status call progress call disposition status etc It may include status about t
34. ation is very precise Specifically in Embodiment One the compliance server receives a request from the PBX so that the compliance server knows that a callis attempted to a specified destination Further the compliance server then receives a call leg from the PBX This may be set up just before or just after the call leg to the agent and or the called party is established The compliance server thus has an accurate perspective of when the call was originated by the PBX and may know by moni toring the in band channel whether the call was answered by a human answering machine or received intercept treatment Similarly in Embodiment Two the compliance server can also monitor in band tones to maintain a precise and accurate status of the call Because the compliance server is able to maintain infor mation about both the agent s actions with respect to the agent s workstation computer and the call status the compli ance server is able to maintain detailed information about the agent s actions work statistics error handling call progress call statistics and perform other aspects necessary to monitor agent performance The compliance server is also able to know and update call establishment information to accurately ensure compliance regulations are followed For example because the compliance server knows whether a call origi nated by the agent encounters a no answer condition the compliance server is then able to ensure that the numbe
35. bodiments additional messaging may follow where the compliance server activates agent specific functionality in the PBX but these messages are not shown in this embodi ment The compliance server is able to then update the agent s status in operation 526 Next the compliance server transmits to theagent s computerthe next wireless number s that are to be dialed in operation 528 After reviewing the number s and related account information the agent enters the number to be dialed via their phone 161 in operation 530 The agent can indicate the number to dial by manually dialing the digits or by selecting a number in conjunction with a preview capability The compliance server then establishes athree way bridge 532 that connects the agent to a recording system 505 at operation 531 and the PBX 135 at operation 534 The recording system is shown as a separate entity in FIG 5 in order to illustrate various options The manner in which the call leg between the compliance server and the PBX is established may vary In one embodi ment the compliance server hotlines automatically con nects the call leg to the PBX The compliance server effec tively connects the call leg to the agent s phone to the call leg to the PBX Thereafter the PBX may provide audio tones and receive the dialed digits from the agent Although these in band tones or out of band signaling messages may be relayed by and through the compliance server the compliance serve
36. call they should be connected to an agent within a set amount of time 2 seconds and ifthis is not possible then the party should be presented with an identification message prior to the dialer abandoning the call or with a message for the next available agent Call Screening Telephone numbers may be defined in various databases as being excluded from certain types of calls These databases are frequently termed do not call databases or do not call lists and may be national state or business specific in scope Other do not call databases may identify numbers as wireless numbers as these may be excluded from being called for certain purposes In some instances exceptions may exist where the party has authorized contact despite being included on one of the do not call lists Further a party may provide authorization to be called on one number e g a home number but not on another num ber e g a wireless or work number Calling Window Call originations may be limited to occur within certain time periods relative to the local time of the called party For example calls may be limited between 8 00 a m and 9 00 p m according to the local time of the called party This may require using the called telephone number and or account records to ascertain the appropriate location and time zone of the called party In the case of wireless numbers which are mobile it may be difficult to ascertain which time zone or geography whe
37. ce processing to ensure that the call originating to the wireless number meets all the compliance requirements If so then in message 836 the compliance module 725 informs the switch and control module 735 to originate the call for the indicated agent by dialing the number The switch and control module 735 receives the message 836 and establishes an audio path 844 with the agent s phone and connects this with the call being established in message 848 using a conventional 2 way switching resource 840 Dur ing the call set up process various in band so called comfort tones may be provided to the agent in operation 846 so as to provide an indication to the agent ofthe call progress Assum ing the called party answers the call setup in message 848 the agent is connected to the called party During each step the compliance module 725 may update information about the status ofthe call and or agent in opera tions 845 and 849 The compliance module knows when a call is originated the call s status whether the agent is waiting for the call to connect to the called party etc After the agent and the called party complete their conver sation the agent dispositions the call in operation 850 Dis positioning the call indicates to the compliance module that the agent has completed the call and the compliance module US 8 738 076 B1 25 sends a command in message 854 to the switch and control module 735 to release the call to the agent
38. city A to store or produce telephone numbers to be called using a random or sequential number generator and B to dial such numbers U S C 227 a 1 At the time the statute was passed dialers were frequently configured to originate calls by dialing a random telephone number or dialing telephone numbers in sequence e g 404 555 0000 through 404 555 9999 Hence the definition of an autodialer incorporated aspects of pro cessing telephone numbers using a random or sequential number generator Over time the FCC has interpreted the scope of an auto dialer to include equipment that need only have the capac ity to store or produce telephone numbers See Rules and Regulations Implementing the Telephone Consumer Protec tion Act of 1991 Report and Order 18 FCC Red 14014 4133 2003 Coincident with this time period predictive dialers were increasingly being used to originate calls to wireline numbers Predictive dialers can originate calls using a list of numbers to be called with reduced agent waiting time There is little debate that many predictive dialers do not use ran dom or sequential number generators However the FCC has classified predictive dialers as autodialers in certain instances to ensure that the prohibition on autodialed calls was not circumvented by automatically dialing lists of num bers instead of creating and dialing 10 digit telephone num bers arbitrarily The FCC has viewed
39. compliance server from receiving and processing voice and audio data Embodiment One This approach incorporates the PBX 135 for originating calls to a wireless number that is manually dialed under the control of the agent using the phone 161 Although the embodiments herein are illustrated using a PBX other switching elements can be used including but not limited to an IP PBX optical switch voice switch router PABX ses sion border controller MPLS switch etc In short the prin ciples and technologies can be applied to any device capable of switching voice data The PBX 135 cooperates with the compliance server by bridging a k a conferencing the com pliance server 125 onto the call originated by the PBX 135 All dialing is manually under the control of the agent inter acting with the PBX 135 and the storage of the numbers to be dialed is in the compliance server 125 which is separate from the PBX The compliance server is able to maintain status information about the call and or agent to ensure that regu lations are complied with Turning to FIG 3 a messaging diagram 300 shows the message flow that occurs between various components namely the agent s computer 160 and phone 161 the PBX 135 the compliance server 125 and the PSTN 115 The computer 160 and phone 161 are co located at the agent s workstation or work position and are both operated and con US 8 738 076 B1 11 trolled by the agent Although the pho
40. d and may ensure that the new numbers presented to the agent do not result in compliance violations if dialed The compliance server can ensure that the agent completes a disposition code before additional numbers are presented to the agent or before another call is allowed to proceed if dialed by the agent The compliance server is able to maintain statistics of how long the agent was on the call duration between calls number of calls originated per time period status of the originated calls etc In short virtually any performance metric that is regu larly maintained by a conventional predictive dialer can be applied used and maintained by the compliance server At each step ofthe process the agent is controlling the call establishment by selecting the number to be dialed entering the dialed number and listening to the call progress tones generated by the PBX when generating the call Further the PBX is not originating the call automatically nor is the PBX dialing a number from a database Blended Operation Blended operation refers to a contact center handling both incoming and outgoing calls Blended operation may provide a benefit of allowing agents to originate outgoing calls when there are few incoming calls In many embodiments the incoming calls are handled by an automatic call distributor ACD that may be a stand alone device or integrated with the PBX orthecompliance server The ACD may offer the call to the agent u
41. diments disclosed herein are intended to be included within the scope of the appended claims Although specific terms may be employed herein they are used in a generic and descriptive sense only and not for purposes of limitation The invention claimed is 1 A system for ensuring compliance adherence for a call to be placed to a called party from a contact center using a wireless telephone number the system comprising a compliance server configured to determine whether the call to be placed to the called party is compliant with respect to at least one compli ance requirement and in response to the determining the call to be placed to the called party is compliant inform an agent of the contact center of the wireless telephone number so that the agent can originate the call to be placed to the called party using the wireless telephone number and in response to receiving an indication that the agent has originated the call to be placed to the called party establish a first call leg between the compliance server and a phone being used by the agent and establish a second call leg between the compliance server and a private branch exchange wherein upon receiving the wireless telephone number the private branch exchange establishes a third call leg between the private branch exchange and a wireless device associated with the called party using the wireless telephone number and the third call leg the second call leg and the first c
42. e agent This operation allows the agent to determine which number from the various accounts is to be dialed next The compliance server may have performed various compliance processing prior to displaying the records to the agent That is in one embodiment the fact that the number is presented to the agent by the compliance server means that the number is eligible to be dialed if so chosen by the agent In other embodiments the number displayed is not checked for compliance until the agent identifies the number that the agent would like to dial The agent selects one of the telephone numbers presented by the compliance service and the compliance server receives the selected number in operation 620 The agent may identify their selection by using a pointing device mouse touch screen keyboard etc The selection could be identifying the numbers individually or selecting the number as a whole The next operation is a test which presumes that the list incorporates both wireless and wireline numbers If the list only comprises wireless numbers then this test would not be required The test in operation 625 determines if the selected number is a wireless number If not e g a wireline number then the compliance server may function as a preview dialer and originate the call Inmany embodiments the list will only contain wireless numbers since it further avoids dialing wire line numbers ina manual manner similar to wireless numbers jak
43. e wireless number the PBX would have to attach a DTMF receiver to monitor those tones The PBX upon receipt of the wireless number from the agent s phone then originates a call leg to the wireless number in message 932 This is bridged on using a 3 way bridge in operation 934 The bridging of the wireless call leg can occur before the wireless call leg is originated or just after the wireless call leg is originated In either case the result shown is a three way call with call leg 938 between the agent and the 3 way bridge 934 a call leg 936 between the compliance server and the 3 way bridge and a call leg 937 between the wireless party and the 3 way bridge This arrangement allows the compliance server to record all aspects ofthe call from the origination of the wireless call leg including any DTMF tones originating from the agent s phone or comfort tones provided to the agent and call progress tones announce ments etc As in the other embodiments the call legs may be released in various ways In the illustrated embodiment the agent dispositions the call in message 940 which is received by the compliance server In turn the compliance server releases the callleg to the PBX and the PBX will release the call leg to the agent s phone The process may repeat 952 back to the next wireless number as shown in FIG 9 but which could also be a wireline number which is not depicted in FIG 9 Exemplary Processing Device Architecture FI
44. ecuted by at least one computer processor residing on a compliance server cause the at least one computer processor to determine whether the call to be placed to the called party is compliant with respect to at least one compliance requirement and in response to the determining the call to be placed to the called party is compliant inform an agent of the contact center of the wireless telephone number so that the agent can control origi nating the call to be placed to the called party using the wireless telephone number and in response to receiving an indication from that the agent originated the call to be placed to the called party 15 20 32 establish a first call leg between the compliance server and a private branch exchange and establish a second call leg between the private branch exchange and a phone being used by the agent wherein upon receiving the wireless telephone number the private branch exchange establishes a third call leg between the private branch exchange and a wireless device associated with the called party using the wireless telephone number and the third call leg the second call leg and the first call leg are connected to form a three way conference call between the phone being used by the agent the compliance server and the wireless device associ ated with the called party 24 The non transitory computer readable medium of claim 23 wherein the first call leg comprises a one way voice pa
45. ed with a number grid as shown in message 910 that may present various accounts and the numbers associated therewith An agent may view the list and indicate the particular number they plan to dial This is reflected in message 912 between the agent s computer and the compliance server 125 Because the num ber selected is a wireline number the compliance server operating as a dialer originates the call leg to the wireline number in message 913 A second call 914 is then established between the agent s phone 161 and the called party After the call is completed the agent may disposition the call in opera tion 916 to the compliance server which then releases the call leg in message 917 to the called party and the compliance server also releases the call leg to the agent s phone in mes sage 918 This process may be repeated if the next number selected by the agentis a wireline number This mode of dialing can be preview dialing Other embodiments may utilize other types of dialing appropriate for dialing wireline numbers Next the processing of a wireless number is examined Again the agent is presented in message 920 a grid of num bers from which the number to dial is selected in message 922 The selected number is a wireless number and if the agent is not already aware ofthis the compliance server may inform the agent via a message on the computer display that the number is a wireless number and must be manually dialed After the
46. eference for all that it teaches FIELD OF THE DISCLOSURE The concepts and technologies disclosed herein generally pertain to enforcement of compliance requirements for calls directed to wireless telephone numbers wherein the calls are originated by agents in a contact center BACKGROUND OF THE INVENTION The Telephone Consumer Protection Act TCPA passed in 1991 regulates in part aspects of originating certain types oftelephone calls Specifically the TCPA statute and Federal Communications Commission s FCC regulations inter preting the TCPA prohibit the use of an autodialer to place calls to certain types oftelephone numbers simply referred to as numbers herein including calls to any number assigned to a paging service cellular telephone service specialized mobile radio service or other radio common car rier service or any service for which the called party is charged for the call 47 U S C 227 b 1 A 47 C F R 64 1200 a 1 This covers what is commonly referred to as a wireless number that is assigned to a mobile phone For simplicity this term wireless number is used herein to refer to numbers that cannot be called under the TCPA using an autodialer The FCC regulates aspects ofthe TCPA and has considered the scope of the term autodialer The TCPA and FCC s rules have defined an automatic telephone dialing system auto dialer as equipment which has the capa
47. enter may process other forms of communication such as facsimiles emails text messages video calls chat messages and other forms The term party without any further quali fication refers to a live person as opposed to an answering machine or voice mail service associated with an instance of communication originated by the contact center The contact center shown in FIG 1 may process voice calls that are originated by a dialer 155 The dialer 155 is typically configured to dial a list of telephone numbers to initiate out bound calls The list of telephone numbers may be stored ina data store 175 that is accessible using a local network 170 The dialer 155 may directly interface with voice trunks using US 8 738 076 B1 7 facilities 116d to the PSTN 115 for originating calls After the calls are originated a transfer or connect operation by the dialer 155 may connect the call with an agent or place the call in a queue for a next available agent In the latter case announcements or music may be provided to the party while they are waiting In various embodiments the dialer 155 may be a predictive dialer that makes use of one or more pacing algorithms to determine how and when to dial a list of numbers so as to minimize the likelihood of a called party being placed in a queue while maintaining effective agent utilization The dialer 155 may dial ahead by originating more calls than there are available agents expecting tha
48. er does not need to connect to an external recording system than a bridge may not be required In this case the facility 132 to the agent s phone is connected to the PBX via facility 127 In one embodiment the agent s phone 161 gen erates the DTMF tones or these may be generated by a tone generator in the computer 160 responsive to the phone 161 representing the wireless number The information is con veyed over facility 132 through the compliance server and over facility 127 to the PBX 135 and the PBX originates the call as in the earlier embodiment In other embodiments the phone may pass signaling information e g SIP or ISDN signaling messages as opposed to in band tones to the com pliance server 125 that in turn relays the signaling to the PBX or passes it through to the compliance server such that the signaling is processed by the PBX In other embodiments the agent may request the compli ance server send the number to be dialed to the PBX and the compliance server then connects the agent to the PBX In this last embodiment the phone does not send the wireless num ber over the facility 132 In each of these embodiments the compliance server retains its functionality of ensuring com pliance is enforced and that the PBX originates the calls A message flow 500 of this embodiment is shown in FIG 5 The process begins in operation 520 with the agent logging into the compliance server 125 using their computer 160 In some em
49. erver and the compliance server may receive an indication of such in operation 436 The compliance server knows that the call is completed and may US 8 738 076 B1 19 prompt the agent in operation 438 to enter a disposition code for the call that just ended When it is received in operation 440 the compliance server then returns to the processing associated with label B 450 in FIG 4A If the agent does not enter a disposition code the compli ance server may block the presentation of the next set of wireless numbers to the agent in operation 410 or reject a request from the PBX to establish a call for the agent in operation 416 Thus the compliance server can track or shadow the status of the agent and the call as ifthe compliance server were originating the call and indirectly control the establishment of further calls by the PBX Combined Wireless and Wireline Call Originations In various embodiments the compliance server may be configured to only originate calls to wireless numbers or it may be configured to also originate calls to wireline numbers It may be configured to originate calls to wireline numbers as described above via manual dialing or in a predictive dialing mode If the compliance server 125 does predictively dial calls to wireline numbers using facilities 121 then the compliance server may function as a predictive dialer In this case the compliance server is accessing a list of numbers and dialing a call bu
50. esents various information on the account record s to the agent for review Thus the agent can pre view the information before the call is originated The agent can select a record and then control when the call is originated by selecting a screen icon pressing a key or some other form of input The telephone number associated with the record is then dialed In one embodiment the compliance server may then provide the digits to the PBX to dial The modifications ensure that the call is established by the agent interacting with the PBX and that the PBX does not store produce or otherwise access a database of numbers when originating the call Recall that in Embodiment One the agent s phone is connected to the PBX and the PBX creates a three way call to the compliance server allowing the com pliance server to receive audio and process and or record 20 25 30 35 40 45 50 55 60 65 20 audio data as necessary In this embodiment the compliance server creates the three way call Referring back to FIG 2 in Embodiment Two the agent s phone 161 may be connected to the compliance server 125 via facility 132 and the compliance server bridges or connects a callleg to the PBX using facility 127 Ifthe compliance server needs to add on a recording system to record the audio then a bridge may be required in the compliance server to bridge a call leg to an external recording system If the compliance serv
51. executed are configured to cause the at least one computer processor to determine the digits dialed by the agent corre spond to the wireless telephone number prior to establishing the first call leg 17 The non transitory computer readable medium of claim 13 wherein the indication that the agent has originated the call comprises the agent selecting the wireless telephone number on a display being used by the agent 18 The non transitory computer readable medium of claim 13 wherein the computer readable instructions when executed are configured to cause the at least one computer processor to establish a voice path between the compliance server and a recording system upon receiving the indication so that the call can be recorded by the recording system 19 A method for ensuring compliance adherence for a call to be placed to a called party from a contact center using a wireless telephone number the method comprising the steps of determining whether the call to be placed to the called party is compliant with respect to at least one compliance requirement and in response to the determining the call to be placed to the called party is compliant informing an agent of the contact center of the wireless telephone number so that the agent can originate the call to be placed to the called party using the wireless telephone number and in response to receiving an indication that the agent has originated the call to be placed to the called
52. he agent as reflected by the computer as well as reflected by the wireless call progress In regard to the agent s workstation computer the compliance server knows when the agent is logged in and ready to initiate another wireless call The compliance server knows if one or more numbers have been presented to the agent for dialing and whether the agent has selected one for dialing The compli ance server is able to monitor the progress of a call and determine whether it has been answered encountered busy disconnected or answered by an answering machine Further the compliance server also knows if and when the agent has dispositioned a call after the call is completed The compli ance server also knows if a call leg is released by the PBX With this information the compliance server knows when the agent is available to be presented with additional numbers to dial For example if the agent has not yet dispositioned a call that has completed then the compliance server will prevent the agent from initiating another wireless call If the agent attempts to do so the compliance server can display appro priate messages requesting them to disposition the previous call and can block the PBX from originating further calls With respect to the call originated by the agent although the compliance server does not originate the call it is able to maintain call state information about the status of the call In some embodiments the call state inform
53. i ate man machine interface provided according to the type of phone in operation 645 which are received by the PBX In some embodiments this may be a soft phone and the agent may use the numeric keypad on the computer keyboard to enter the wireless telephone number Depending on the embodiment the agent may enter a return enter or send to signify the end ofthe digits In other embodiments the PBX may employ timers or digits counters In one embodiment DTMF tones are generated by the soft phone to indicate the digits pressed by the agent In other embodi ments the soft phone may originate SIP signaling which is conveyed to the PBX At this point the compliance server is maintaining a con nection between the agent soft phone and the PBX Thus the compliance server can monitor the in band information and determines the DTMF digits being dialed by the agent to the PBX In this manner the compliance server is able to monitor the status of the call and any audio data being conveyed Further the agent s phone is interacting with the PBX for originating a call not the compliance server The PBX originates the call in operation 650 in a conven tional manner After conversing with the called party the agent may then terminate the call in operation 655 or the called party may terminate the call The compliance server may not know that the call is terminated However the agent then dispositions the call by indicating the appropri
54. liance server merely copying the audio data to a file or data store Co incident with this process the PBX also establishes an audio path 344 to the phone of the agent This could be considered another call leg of the conference call The details on how this is performed vary as to the type of phone used by the agent For example the phone used may be an analog phone a digital phone non VoIP a digital VoIP phone or a soft phone that is integrated into the computer In each case the phone is logically distinct from the computer even if integrated into the computer Appropriate signaling and pro cedures are based on the type of phone and are well known In some embodiments this audio path may be initially estab lished for the first wireless call and maintained until the agent logs out Next the PBX establishes another call leg 348 to the dialed party This may occur using various types of signaling such as POTS ISDN SIP etc The PBX may also provide option ally the aforementioned in band comfort tones 346 to the agent to inform the agent of the progress of the call The provision and form of the tones may vary based on the tech nology including the particular form of telephone used by the PBX For example the PBX may be a VoIP based platform so that there is no in band tones produced to the agent s phone as is found in a POTS system In other embodiments the PBX may generate a dial tone and DTMF tones as the call leg 348 to
55. m architec ture of a compliance server or a PBX used to embody the concepts and technologies disclosed herein DETAILED DESCRIPTION Predictive dialers are often used to generate calls by dialing a plurality of wireline telephone numbers with the expecta tion that many if not most calls will not be answered by the desired party Many calls originated by the predictive dialer expect to be unanswered answered by an answering machine forwarded to a voice mail system or disconnected Other conditions may be encountered where the call is not answered by the desired party Rather than consume an agent s time by originating calls in a serial manner and encountering the above conditions the predictive dialer will dial a number of calls simultaneously When a call is answered by a party that call is connected to an agent who can then speak with the party Thus the agent has less wait time before talking to the right party Predictive dialers allow the agent s time to be used with greater efficiency and offer many advantages over the agent manually dialing the call As with any technology there is the possibility of misuse Various regulations have been developed to ensure that con tact center operators do not abuse the usage of predictive dialers thereby creating an unreasonable nuisance to the pub lic For example when a predictive dialer determines that an agent is available it can simultaneously generate a large number of outgoing calls
56. may confirm back to the compliance server 125 that triggering for the agent s phone will occur at operation 324 At this point the compliance server 125 may update the status associated with the agent and or call in operation 326 since the compliance server now knows the agent is ready to originate calls As it will be seen the compliance server is able to track and update the status of the agent and or call throughout the various steps encountered by the agent call Although the compliance server does not originate the call to the wireless number the compliance server is timely notified in various ways so that itis ableto maintain current status information in a largely comparable manner as if it had originated the call The compliance server 125 at this point may update the appropriate status or state for the agent to reflect the opera um 0 an 5 25 40 45 50 12 tional status of the agent s phone and or computer The com pliance server 125 may include the agent in internal queues for handling calls associated with the campaign In this embodiment it is presumed that the agent is engaged in a campaign that involves initiating calls to wireless numbers The campaign may involve a list solely comprising wireless numbers or may involve a mix of wireless wireline numbers Once the compliance server 125 determines the agent is ready to originate a call the compliance server 125 sends informa tion at operation 328 to
57. ne may be a soft phone the principles apply to using a VoIP or conventional phone The PBX 135 is a well known device for originating calls that are manually dialed under the direction of the agent It is presumed that the PBX does not meet the autodialer requirements as considered by the FCC rules Specifically the PBX does not oris not configured to generate or store the number manually dialed by the agent as defined in the context of the TCPA Rather the agent manually enters the digits of the wireless number using the phone 161 that will cause the PBX to originate a call to that number Any number of approaches for the phone signaling to the PBX may be used The compliance server 125 may be a computing system as is well known in the art It may incorporate aspects of a dialer particularly the compliance enforcement functions found in certain commercially available dialers such as the Noble Systems Corporation Maestro predictive dialer The com pliance server is typically not used to originate calls to wire less numbers Finally the PSTN 115 is shown to convey the call origi nated by the PBX to the called party In other embodiments the Internet or other form of network may be used Reference to the PSTN should not be construed to limit any of the technologies used herein from using VoIP SIP or other forms of digital telephony The process begins with the agent using their computer 160 to log on to the compliance server
58. number 10 The method of claim 9 further comprising the step of determining by the compliance server the digits dialed by the agent correspond to the wireless telephone number prior to establishing the first call leg 11 The method of claim 7 wherein the indication that the agent has originated the call comprises the agent selecting the wireless telephone number on a display being used by the agent 12 The method of claim 7 further comprising the step of establishing a voice path between the compliance server and a recording system upon receiving the indication so that the call can be recorded by the recording system 13 A non transitory computer readable medium compris ing computer readable instructions for ensuring compliance adherence for a call to be placed to a called party from a contact center using a wireless telephone number the com puter readable instructions configured to when executed by at least one computer processor residing on a compliance server cause the at least one computer processor to determine whether the call to be placed to the called party is compliant with respect to at least one compliance requirement and in response to the determining the call to be placed to the called party is compliant inform an agent of the contact center of the wireless telephone number so that the agent can originate the call to be placed to the called party using the wireless telephone number and in response to receiving
59. of consecutive call attempts by the predictive dialer Such repeated call attempts by themselves may be deemed harass ing and may violate federal regulations in certain circum stances In many instances large fines may be assessed against the call center operator Thus there are various compliance related aspects that must be enforced during a campaign when originating calls As used herein compliance requirements may include state regulatory requirements federal regulatory requirements contact center policies or client requirements Thus a variety of restrictions or limitations on call origination may fall within the scope of compliance requirements Some of the compliance related aspects are described below which include some of those previously mentioned Target Abandonment Rate Various state and or federal abandonment rates may have to be complied with An abandoned call may be defined as a call answered by a person but which is not connected to an agent within two seconds The actual abandonment rate may be mea sured over a set time period for a particular campaign and cannot exceed a given percentage of calls as defined by the governing abandonment rate Attempt Counter A limit may be defined for the number of call attempts that can be made to a number over a time period e g day week or month as well as the mini mum time period that must occur between call attempts Identification Message If a party answers a
60. ordination is provided between the PBX and the compliance server so as to provide compliance enforcement when dialing a wireless number The coordina tion may involve various types of signaling between the PBX and the compliance server Specifically in one embodiment the compliance server provides compliance enforcement by responding to a query from the PBX regarding a call to a wireless number dialed by the agent In other embodiments coordination between the PBX and a compliance module occurs within a single processing system so as to provide compliance enforcement when dialing a wireless number As is discussed in greater detail below the subject matter disclosed herein may be implemented as a computer con trolled apparatus a method a computing system or as an article of manufacture such as a tangible non transitory com puter readable storage medium These and various other fea tures will be apparent from the following Detailed Descrip tion and the associated drawings This Summary is provided to exemplify concepts at a high level form that are further described below in the Detailed Description This Summary is not intended to identify key or essential features of the claimed subject matter nor is it intended that this Summary be used to limit the scope of the claimed subject matter Furthermore the claimed subject matter is not limited to implementations that address any or all disadvantages noted in any part of this disclosure
61. party establishing a first call leg between the compliance server and a private branch exchange establishing a second call leg between the private branch exchange and a phone being used by the agent establishing a third call leg between the private branch exchange and a wireless device associated with the called party using the wireless telephone number and connecting the third call leg the second call leg and the first call leg to form a three way conference call between the phone being used by the agent the compliance server and the wireless device associ ated with the called party US 8 738 076 B1 31 20 The method of claim 19 wherein the first call leg comprises a one way voice path from the private branch exchange to the compliance server 21 The method of claim 19 wherein the indication that the agent has originated the call comprises the agent selecting the wireless telephone number on a display being used by the agent 22 The method of claim 19 further comprising the step of establishing a voice path between the compliance server and a recording system upon receiving the indication so that the call can be recorded by the recording system 23 A non transitory computer readable medium compris ing computer readable instructions for ensuring compliance adherence for a call to be placed to a called party from a contact center using a wireless telephone number the com puter readable instructions configured to when ex
62. placed to the called party is compliant with respect to at least one compliance requirement and in response to the determining the call to be placed to the called party is compliant informing an agent of the contact center by the compli ance server of the wireless telephone number so that the agent can originate the call to be placed to the called party using the wireless telephone number and in response to receiving an indication that the agent has originated the call to be placed to the called party establishing a first call leg between the compliance server and a phone being used by the agent establishing a second call leg between the compliance server and a private branch exchange establishing a third call leg between the private branch exchange and a wireless device associated with the called party using the wireless telephone number and connecting the third call leg the second call leg and the first call leg to form a three way conference call between the phone being used by the agent the compliance server and the wireless device associ ated with the called party 8 The method of claim 7 further comprising the step of establishing the agent has logged in prior to informing the agent of the wireless telephone number 9 The method of claim 7 wherein the indication that the agent has originated the call comprises the agent manually dialing digits on the phone being used by the agent corre sponding to the wireless telephone
63. pliance server 125 may be integrated with a predictive dialer that dials wireline numbers via facilities 121 In this case the predictive dialer dials wireline numbers and performs compliance functions When wireless numbers are dialed the compliance server performs the compliance functions and the PBX originates the wireless calls In other embodiments originating calls to both wireline and wireless numbers can be accomplished by using a com pliance server and PBX as described herein for originating wireless calls and a predictive dialer for wireline calls To accomplish this segregated lists of wireline and wireless numbers need to be prepared loaded and managed for the predictive dialer and the compliance server respectively 20 25 30 35 40 45 50 55 60 65 18 Process Flow A process flow corresponding to the message flow of FIG 3 is shown in FIGS 4A and 4B Turning to FIG 4A the process 400 begins with the compliance server receiving the agent s log on in operation 404 The compliance server retrieves the agent s profile information in operation 406 and performs related operations such as updating the status to reflect the agent is available to handle calls The compliance server may inform the PBX that the dial ing plan procedures for the agent are to be activated in opera tion 408 This operation is optional and may not occur in every embodiment Next the compliance server presents to the agen
64. process depend on the type of phone being used Finally the PBX releases the call leg to the party at operation 358 The operation of the 3 way bridge may be slightly modified from the operation of a conventional 3 way bridge In a con 20 25 30 35 40 45 50 55 60 65 16 ventional 3 way bridge if an added leg to a conference is dropped the conference bridge may remain intact e g the other remaining call legs are retained However in this embodiment the 3 way bridge operates such that if any call leg is dropped the remaining call legs are also dropped This is because the compliance server is bridged to the call between the agent and the remote party to only listen to that call This allows the compliance server to perform any ofthe various recording and analytic functions mentioned above The compliance server only drops its call leg to the PBX ifthe agent dispositions the call e g indicates the call is com pleted The compliance server is configured so that when the agent dispositions the call the compliance server construes this action as the agent having completed the call with the called party and initiates releasing the call leg The agent could have alternatively released the call to the called party i e to the PBX and then disposition the call to the compli ance server If the called party terminates their call leg then there is no need for the agent to be bridged to the compliance server
65. r is not establishing the call Inanother embodiment when the agent selects the number to dial at operation 530 the compliance server connects to the PBX and sends the digits to the PBX In this case the digits to be dialed are conveyed by the compliance server to the PBX but the call origination is performed by the PBX The PBX connects in operation 536 the call leg from the compliance server with the call leg established for the origi US 8 738 076 B1 21 nating wireless call leg in operation 538 Alternatively the originating wireless call leg in operation 538 can be estab lished and then connected to the call leg between the PBX and compliance server In any case a connection is established from the agent to the compliance server back to the PBX and then out to the PSTN 115 and the called party The compliance server is aware that the call has been established and then updates the agent status information in operation 545 As before the compliance server is able to monitor and record the audio associated with the call progress as well as any conversation When the agent is finished talking with the called party the agent dispositions the call by signaling the disposition code to the compliance server at operation 550 The compliance server updates the agent status as appropriate in operation 552 and then may release the call leg back to the PBX in operation 554 The compliance server may also release the call leg to the agen
66. r with respect to accomplishing compliance enforcement The architecture shown in FIG 1 illustrates one possibility and does not limit application of other architectures of the principles and technologies presented herein Further not all aspects and components shown in FIG 1 are required in all embodiments Thus a contact center may have agent posi tions using only a workstation configuration 160a 161a involving soft phones whereas other contact centers may use other configurations In some configurations the phones may becapable of handling two lines and may have the capability of handling a dialer originated call on one line and a manually originated call via the PBX on another line Those skilled in art will recognize FIG 1 represents one possible configura tion of a contact center architecture 100 and that variations are possible with respect to the protocols configurations facilities technologies and equipment used The above components may be variously referred to as a computer processing device unit component or system and may incorporate therein a local data store or database or interface with an external database Use of the word server herein does not require the component to inter act in a client server arrangement using web based protocols with other components although that may be the case Fur ther the above components may be located remotely from or co located with othe
67. r components Furthermore one or more of the components may be implemented on a single processing device or platform to perform the functions described herein In addition the contact center architecture 100 may be provided as a hosted solution where the call processing func tionality is provided as a communication service a so called communication as a service or CaaS to a contact center operator Thus there is no requirement that the components identified above must be actually located or controlled by a contact center operator Inaddition the agent positions can be co located in a single physical contact center or in multiple physical contact cen ters The agents can be remotely located from the other com ponents of the contact center and may also be remotely located from each other sometimes referred to as a virtual contact center A virtual contact center may describe a sce nario where agents work at home using their own computers and telephones as workstations In some configurations a single physical location of the contact center may not be readily identifiable This may occur when the call processing functions are provided as a service in a hosted cloud comput ing environment and the agent positions are in their individual residences A simplified description of the architecture of the contact center as it relates to using the compliance server 125 and the PBX 135 is shown in the system 200 of FIG 2 In FIG
68. r is not re dialed within a prohibited window If the compliance server was unable to ascertain the status ofthe call attempt it would adversely impact the ability of the compliance server to ensure calls were compliant Embodiment Three The embodiments disclosed above are generally based on the architecture shown in FIG 2 The architecture of FIG 2 a 5 35 40 45 50 55 65 24 can be implemented using co located components geo graphically separated components or hosted components provided whole or in part by a service provider Another embodiment is shown in FIG 7 In FIG 7 the architecture 700 illustrates the mobile smart phone 110c which is shown as interconnected to the PSTN 115 which in turn is connected via facilities 123 to a PBX 135 In this embodiment the PBX 135 comprises a switch and control module 735 and a compliance module 725 The switch and control module 735 may be an open source switching fabric and control software or other form of switching and control capabilities The switch and control module 735 is able to communicate over data link 727 to the compliance module 725 that is configured to provide compliance control enforce ment This embodiment incorporates the functionality of the compliance server into a PBX and thus avoids having to use two separate processing devices The compliance module 725 and the switch and control module 735 may execute on the same processor or on different
69. re the called party is located in Call Recording Call Recording Exclusion Depending on the state certain calls may be recorded without the called party s consent to aid in quality control or to ensure that certain compliance requirements are met On the other hand certain states do allow recording without the called party s consent This may be further impacted based on the statutes of the state where the call origi nated from as well as the state the called party is located in Alternate Number Dialing If a call to a party is unan swered then alternative numbers associated with that US 8 738 076 B1 5 party may be used However various conditions and requirements may be associated with the usage of these alternate numbers since the conditions and require ments associated with using the first number are not necessary applicable for using the alternative number State Specific Reporting Requirements Calls originating from or terminating to a given state may have state specific reporting requirements Contact Center Specific Policies A contact center may modify any of the above requirements to make the requirements more restrictive For example whereas certain regulations may limit calls between 8 00 a m and 9 00 p m a contact center may chose to prohibit calls before 9 00 a m The application of the above compliance requirements may depend on the purpose and nature of the call or whether there is any form of pre exis
70. required in all embodiments The compliance server 125 may inter connected with the PBX 135 via facilities 127 This may be a signaling link a voice communication facility or a combina tion of the two EMBODIMENTS Various embodiments are possible to provide compliance enforcement for manually dialed calls to wireless numbers The embodiments generally involve cooperation between the compliance server 125 and a PBX 135 Although shown as two separate devices in FIG 2 these two components can be integrated into one device in some embodiments The com pliance server 125 may incorporate certain aspects of a pre dictive dialer as predictive dialers are typically used to enforce compliance when originating calls In the embodi ments disclosed herein the compliance server enforces com pliance for calls to wireless numbers but does not originate the wireless call The PBX 135 or other similar form of switching device originates calls to the wireless numbers that are dialed by the agent using the phone at the agent s position Note that in some embodiments the compliance server 125 receives and processes voice data from the PBX 135 as the compliance server may be involved in recording or process ing of audio data associated with the wireless call The audio data may be stored and or relayed to a data store by the compliance server Thus although the compliance server may not originate voice calls it does not necessarily exclude the
71. sing a separate phone Thus in some embodi ments the agent may have two phones e g a physical VoIP phone distinct from their computer for originating calls via the PBX to wireless numbers and a soft phone integrated into their computer for handling incoming calls In other embodi ments the agent may have a phone capable of handling two lines either physical or logical For example the agent may have a soft phone which is able to receive incoming calls from the ACD on one VoIP channel and originate outgoing calls to the PBX using another VoIP channel In other embodiments the agent may have one phone capable of only handling one call and this effectively prevents the agent from originating an outgoing call at the same time Wireline Call Origination The compliance server may be based on modifying a pre dictive dialer so that it does not originate calls However in other embodiments the compliance server may function as both a compliance server for wireless calls originated by the PBX and a predictive dialer for originating calls to wireline numbers In this case the same or different phone at the agent s work space may be used for predictive dialer origi nated calls In some embodiments a dialing list may com prise both wireline and wireless numbers and the processing of numbers on that list may involve a single agent handling wireline predictive dialing calls and wireless manual dialing calls Thus returning to FIG 2 the com
72. t in operation 556 The PBX in response to the call leg released in operation 554 releases the call leg to the called party in operation 558 The process may loop back in opera tion 560 and repeat as necessary Process Flow The process flow corresponding to the message flows of FIG 5 is shown in FIG 6 This embodiment presumes that a single list comprising both wireline and wireless numbers is processed by the compliance server In other embodiments different lists may exist one for wireline and one for wireless In the case where the list only comprises wireless numbers the process flow may be slightly different from that shown in FIG 6 Specifically operations 625 and 630 may be absent The process 600 begins in operation 605 with the compli ance server retrieving the next set of telephone numbers in the dialing list for potential dialing In this embodiment a group of records are retrieved however in other embodiments only a single record may be retrieved This operation may be the point of re entry when repeating the overall process Next the compliance server displays the retrieved records on the computer of the agent in operation 615 A number of graphical user interface formats may be used to present the information which may include other account information associated with the telephone number s Presumably if the numbers are of either a wireless or wireline type an indica tion of each type of number is provided to th
73. t some calls will not be answered by live parties or that an agent may become available in time The dialer 155 also ensures that applicable compliance requirements are enforced Outbound voice calls may originate from the contact center to parties using a variety of phone types A party may receive a call at a conventional analog telephone 1105 connected to a public switched telephone network PSTN 115 using an analog plain old telephone service POTS line 116a The call may be routed by the dialer to the PSTN 115 and may comprise various types of facilities including but not limited to T1 trunks SONET based fiber optic networks ATM net works PSTN trunks 1164 The dialer may also route calls to other networks such as the Internet 123a 1235 using facili ties 116e 116c Voice calls may also be received at a mobile device 110c such as a smart phone or tablet which wirelessly communi cates with a mobile service provider MSP 112 The voice calls may be routed to the PSTN 115 using an integrated services digital network ISDN interface 1165 or other types of interfaces that are well known to those skilled in the art The MSP 112 may also handle calls as packetized voice referred to herein as voice over IP VoIP to an Internet provider 1235 using Internet based protocols For conve nience unless indicated otherwise the term trunk refers to any type of communication facility providing voice calls
74. t the wireless number s that may be dialed in opera tion 410 This may mimic the screen layouts used for dialing wireline numbers by a predictive dialer so that that agent sees the number in a familiar screen Additional icons may inform the agent that the number is a wireless number that has to be dialed manually The compliance server receives the agent s selection of a number they will be dialing indicated by the agent via a mouse or cursor in operation 412 This operation is optional as this provides an advance indication to the compliance server as to the number selected by the agent The agent may simply dial the number using their phone that is signaled to the PBX at which point the PBX sends a query to the com pliance server At operation 414 the compliance server receives the query from the PBX The compliance server determines in operation 416 whether it is okay for the PBX to originate the call to the number The compliance server may have performed some compliance aspects previously or may have waited until this point to perform the compliance testing If the call is not in conformance with the requirements then in operation 418 the compliance server denies the request Assuming that in operation 416 the call may be dialed the compliance server may confirm to the PBX that the call may proceed in operation 420 The compliance server then updates the state information reflecting that it expects an incoming call will be shortly
75. t to a wireline number If the list contains a wireless number it can indicate this to the agent with instructions that the call is to be manually dialed In this case the compliance server presents the wireless number to the agent and the agent uses the phone to dial the call via the PBX such that the compliance server does not originate the wireless call in any way This embodiment also allows incoming calls to be handled Returning to FIG 2 the compliance server 125 can be inte grated into an ACD that also receives incoming calls As is well known for blended call center operations when the agent is involved in an outgoing call no incoming calls are offer to that agent That is any incoming calls received are only routed to the agent if the agent is not handling another call Embodiment Two This embodiment also involves a PBX interacting with a compliance server This embodiment is based on the compli ance server originating a three way call to the PBX as opposed to the PBX originating a three way call to the com pliance server The compliance server is able to monitor and record the call but dialing of the call originates from the agent and is directed to the PBX with the dialed digits handled by the compliance server in some embodiments In one embodiment the compliance server may incorpo rate aspects of preview dialing in presenting the number to the agent to dial Preview dialing selects one or more account records and pr
76. ten grouped into clusters that are managed by a supervisor who may monitor calls and the agents productivity An agent usually uses a computing device such as a computer 160a 160c and a voice device 161a 161c The combination of 0 jak 5 20 40 45 50 65 8 computer and voice device may be referred to as a worksta tion Thus the workstation collectively has a data capability and a voice capability though separate devices may be used In some instances workstation may be used in reference to specifically either the data or voice capability at the agent s position as appropriate to the context For example routing the call to the agent s workstation means routing a call to one of the voice devices 161a 161c at the agent s position Simi larly routing the call to the agent means routing a call to the appropriate equipment at an agent s position The voice device used by an agent may be a soft phone device exemplified by a headset 161a connected to the com puter 160a The soft phone may be a virtual telephone imple mented in part by an application program executing in a computer The phone may also comprise an Internet Protocol IP based headset 1615 or a conventional phone 161c Use of the term phone is intended to encompass all these types of voice devices used by an agent unless indicated otherwise In some embodiments the voice traffic to the soft phone may be tr
77. th from the private branch exchange to the compliance server 25 The non transitory computer readable medium of claim 23 wherein the indication that the agent has originated the call comprises the agent selecting the wireless telephone on a display being used by the agent 26 The non transitory computer readable medium of claim 23 wherein the computer readable instructions when executed are configured to establish a voice path between the compliance server and a recording system upon receiving the indication so that the call can be recorded by the recording system
78. that the call can proceed or not In some embodi ments this information may be conveyed by user user infor mation UUT in ISDN messages In other embodiments the PBX may not bridge on the compliance server via a three way call However not bridging the compliance server pre vents the compliance server from performing certain func tions such as call recording monitoring call progress tones etc Also it is evident that the compliance server is able to maintain current status information about the agent and or call based on agent interactions with the compliance server via the computer as well as updates from the PBX and by monitoring in band tones as the call progresses These inputs allow the compliance server to know the relative state of the agent and or the call and when the agent 1s ready to initiate another call The compliance server also knows what tele phone numbers the agent enters to the PBX Thus although the compliance server is not originating or controlling call establishment it is able to effectively monitor the call progress as if it had originated the call Once the 3 way bridge is released the entire process may loop back 360 and repeat The compliance server may present the agent with a new list of wireless numbers that may be US 8 738 076 B1 17 dialed and the agent can select the desired number and origi nate another call The compliance server may update its records as to which numbers were diale
79. the screen of the agent s computer 160 indicating one or more numbers to dial The presentation on the agent s computer of what number s that should be dialed may be presented to the agent in various formats The information may include the number as well as other related account information In one embodi ment a plurality of numbers is presented in a grid format This provides numbers on a variety of accounts where each account may have multiple numbers associated with that account This allows the agent to determine which of several numbers they will dial next The grid may be a series of rows with fields for account number account holder name amount due address and notes In other embodiments a single wire less number along with account information may be pro vided to the agent A variety of graphical user interface for mats may be presented in which the agent is informed of a wireless number to dial In various embodiments the graphi cal user interface presented may mimic the same format used to dial wireline numbers by a predicative dialer The compliance server may select or identify the number s that the agent may select from to dial In one embodiment the compliance server has already performed the necessary compliance processing before presenting the numbers to the agent to select from Doing so ensures that only allowable or compliant numbers are presented to the agent to dial In other embodiments the compliance
80. ting relationship between the parties The list of compliance requirements provided above is illustrative and is not intended to be exhaustive Some of these requirements may be applicable for dialing wireless numbers under certain context for certain regulations whereas other requirements may be applicable for other types of numbers or other regulations Other requirements may be applicable and may be regulated by the contact center itself via internal contact center policies or by local state or federal govern ment regulations The above demonstrates that there is a complex set of compliance requirements that may be applicable when dial ing a telephone number Additionally when dialing a wireless number additional compliance requirements may apply Spe cifically certain prohibitions apply when dialing a wireless number e g wireless numbers should not be dialed by an autodialer Complicating matters is that it is not always readily possible to detect with certainty by examining the telephone number itself whether it is a wireline number or a wireless number For example years ago wireless numbers were allocated using a unique area code and office code e g NPA NXX or the first six digits of a ten digit telephone number Thus individuals familiar with telephone numbers in a local area could ascertain whether a telephone number was wireless or wireline by examining the NPX NXX portion ofthe telephone number However that
81. tion with the called party the three way call is terminated This can occur in various ways The approach shown in FIG 3 illustrates the agent indicating a disposition code for the call using their computer The disposition code indicates the status of the call such as whether the right party was reached an issue was resolved a sale completed etc In some cases the agent is expected to indicate the disposition a k a dispositioning the call This is typically required when the agent has spoken with an answering party since the code depends on the sub stance of the conversation In some instances the compliance server can disposition the call For example the compliance server can listen to in band call progress tones and indicate whether the call encountered busy no answer a disconnect tone or was answered by an answering machine Allowing the compliance server to disposition the call in such cases relieves the agent from having to do so and often results in a more accurate disposition of the call The computer will convey the disposition code to the com pliance server at operation 350 In response the compliance server updates the agent s status in operation 352 At this point the compliance server knows that the call is over and releases the call leg 354 to the PBX In response the PBX also then removes the audio path 356 to the agent or otherwise release that call leg to the agent s phone Again the specific details of this
82. typically is no longer the case as an NPX NXX may be allocated to both wireline and wireless numbers Since contact centers may originate calls to any location in the United States it is unreasonable to expect an agent to be familiar with local telephone numbers Further a wireline telephone number can be ported to a wire less service provider Consequently it is generally not fea sible for an agent to determine by examining the telephone number itself whether it is a wireline or wireless number Having an agent manually dial a wireless number may avoid the prohibition of using an autodialer For purposes herein manually dialing refers to the agent indicating on a digit by digit basis the telephone number to a device which originates the call and it can be assumed that the device does not store or produce the number dialed and otherwise avoids the requirements for an autodialer In some embodi ments the agent may request that the numbers be dialed In one embodiment the device could be a PBX that can be used to manually dial a number and is generally considered to be outside the scope of an autodialer However having an agent manually dial a number increases the risk of failing to comply with current or future compliance requirements For example a predictive dialer can ensure that restrictions are met in regard to 10 25 40 45 65 6 dialing a number during certain hours of the day per the
83. using telephone numbers on a dial ing list The first call that is answered by a person may be connected to the available agent However if there are no other available agents then the remaining calls that are answered will not be immediately connected to an agent Under such circumstances the predictive dialer may simply hang up when the called party answers or play an announce ment asking the called party to wait for the next available agent However this practice is generally deemed undesirable and federal regulations may limit the abandonment rate of a contact center when operating a predictive dialer Another potential undesirable aspect involves re dialing an abandoned call In the above example if a call is answered but no agent is available the predictive dialer may simply terminate the call Thus the called party may rush to answer the phone only to hear silence The number may be flagged by the predictive dialer as being unanswered and included in the next dialing attempt when the next agent is available This process may be repeated a number of times during a day Without any safeguards in place it is possible to repeatedly call the same number and repeatedly hang up further aggra vating the called party Even if the called party is not home this mode of operation can result in the called party s caller 20 25 30 35 40 45 50 55 60 65 4 ID feature on their telephone to record a large number
84. various compliance pro cessing rules in operation 334 to determine whether the appli cable compliance requirements have been meet The require ments may be dependent on various aspects including contact center policies context purpose of the call govern ment regulations etc The compliance server 125 further updates the status information associated with the agent and or call Specifically the compliance server 125 now knows that the agent has initiated a call request and knows the number dialed as well as the list of numbers presented to the agent from which the number was selected The compliance server may verify that the number dialed by the agent is one of the numbers just presented to the agent Assuming that all the applicable compliance processing rules have been applied and the compliance server has determined that the call may proceed the compliance server confirms to the PBX that the call may proceed via a message at operation 336 An error or non compliant condition may instead result in signaling at operation 336 indicating to the PBX that the call should not be established or indicate the error condition The compliance server may update status information associated with the call agent in operation 338 For example 20 40 45 65 14 the compliance server now knows that the agent has manually dialed a wireless number via the PBX and the PBX is in the process of handling the call After receiving the response
85. when sending the one or more mes sages at operation 330 In other embodiments in band DTMF tones proprietary station set signaling or other forms of signaling may be used The phone could be a soft phone that is integrated with the computer and interfaces with the PBX using any of the above signaling protocols In one embodi ment the digit keys may be icons on the computer screen that US 8 738 076 B1 13 are selected by the agent or the keys may be indicated using the numerical keypad on the agent s computer keyboard Depending on the soft phone embodiment various human interface interactions may occur for the agent to dial the wireless number For example the agent may use a mouse a pointer a touch screen a separate keypad interfacing to the computer speech recognition etc Depending on the phone technology used the agent may hear in band tones In some embodiments the agent may hear a dial tone and DTMF tones which may occur if a conven tional phone is being used In other embodiments such as when using a VoIP phone comfort tones may be provided to the agent to emulate a dial tone and DTMF tones even though the signaling of the wireless number is conveyed via out of ban messages Thus the agent may be provided such tones in operation 333 Whether and how this occurs is defined according to the dialing procedures associated with the agent s phone and the PBX Upon receiving the wireless number to dial the PBX 135

Providing compliance enforcement for manually dialed wireless

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