One list, three channels: building an unsubscribe register that holds up across SMS, email and calls

Most dealerships treat opt-outs as three problems: one for email, one for SMS, and one for the phones. That split is exactly how a customer who unsubscribed from your EDM still gets a service reminder text, then a call about a trade offer. Under Australian law, those slips are not just annoying. They are the kind of thing the regulator fines businesses for. The fix is one shared unsubscribe register that every channel checks before a message or call goes out.

Why one shared opt-out list beats three separate ones

A customer does not think in channels. When they say stop, they mean stop everything, and a siloed CRM is the usual reason that intent gets lost between systems. A single suppression list, owned centrally and honoured by SMS, email and your BDC dialler, is the simplest way to make sure an opt-out in one place is respected everywhere.

It also protects the customers you keep. Someone who opts out of finance-maturity marketing may still want service booking reminders, so your list needs to record what was withdrawn, not just that something was. Getting that granularity right keeps useful, wanted messages flowing while shutting off the ones the customer declined.

What the Spam Act asks of your unsubscribe process

The rules for SMS and email marketing sit in the Spam Act 2003, administered by the ACMA. The core obligation is plain: every commercial electronic message must contain a working way to opt out, it must be easy, clear and at low or no cost, and you cannot force the person to log into an account or hand over extra personal information beyond the address or number being removed. A return SMS reply counts as an acceptable low-cost option.

Two details trip dealers up. First, the ACMA states the unsubscribe facility must stay functional for at least 30 days after the message is sent, so a link that expires the next day will not do. Second, the ACMA notes that alphanumeric or branded SMS sender headers generally cannot receive return messages, so if you send from a branded sender ID you must give another opt-out path in the body. On timing, the ACMA advises that businesses must generally stop sending marketing within 5 business days of a request, which means your list has to update fast enough to catch the next scheduled send.

The cost of getting this wrong is real and public. According to Chambers and Partners, the Commonwealth Bank incurred a $3.5 million penalty in May 2023 for sending around 65 million emails without functional unsubscribe facilities, and Luxottica Retail Australia was fined $1,512,500 in April 2024 for breaches including messages sent without unsubscribe facilities. These are industry findings about other businesses, not Dealerloop outcomes, but they show where the regulator is looking.

Calls are a separate rulebook: the Do Not Call Register

Unsubscribing from your emails does not cover your phones. Outbound sales and marketing calls fall under the Do Not Call Register Act, and the obligation is to screen, or wash, your call lists against the register. Per the Do Not Call Register, telemarketers and fax marketers have 30 days to recognise a number's registration and stop contacting it, and a call to a registered number is not a breach only if the list was washed against the register in the 30 days beforehand and the number was not shown as listed, or the person has given consent.

For a dealership, that means two things. Wash any cold or prospecting list inside a rolling 30-day window before you dial, and keep your own internal do-not-call entries for customers who have asked your team directly not to be called. The register handles strangers. Your internal list handles the people who told your salesperson at the desk.

Keep the records that prove it

An opt-out list is only as good as your evidence that you honoured it. The ACMA can ask you to produce your records, and as the law firm Addisons summarises, those records should capture the method used to provide consent, the terms of that consent, and the date and time it was obtained. Addisons also notes that if you outsource marketing or calling, you remain responsible for keeping reliable consent records, and so does your provider.

Translate that into daily practice: log every opt-out with a timestamp, the channel it came through, and what was withdrawn; keep your list-washing dates; and make the suppression list the single source of truth that every send and every dialler session checks first. Do that, and a compliant unsubscribe list stops being a legal chore and becomes proof that your dealership does what its customers ask.

Sources: ACMA: Avoid sending spam, ACMA: Dealing with spam, ACMA: Email and SMS unsubscribe rules (fact sheet), Do Not Call Register: Using the register, Chambers and Partners: The latest prosecutions under the Spam Act, Addisons: The ACMA's expectations for using consent to conduct e-marketing and telemarketing. Figures are industry findings, not Dealerloop results.