How do we get agent matching through our compliance review?
Hand your compliance team the documents before any data moves, starting with the Order Form’s line on what changes: BestPair changes only which agent works an account, it does not contact consumers, and it does not change whether an account is worked, what a consumer is offered, or any collection terms. The data is pseudonymised only, and collection activity, including FDCPA, Regulation F, TCPA and state law compliance, stays with your agency. Your counsel decides whether the terms fit, because BestPair does not provide legal or compliance advice.
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Start with what changes, and what does not
Settle first what BestPair touches. The Order Form puts it in one sentence: BestPair changes only which agent works an account. It does not contact consumers, and it does not change whether an account is worked, what a consumer is offered, or any collection terms.
People make every call. BestPair does not dial, call, text or contact consumers. Under the Standard Terms, your agency stays solely responsible for its collection activity, including compliance with the Fair Debt Collection Practices Act, Regulation F, the Telephone Consumer Protection Act, state collection and licensing laws, and its agreements with its clients. Your dialer’s contact rules stay where they are.
The work also comes in two steps, which helps a cautious team. During the Floor Assessment (Stage 1) nothing changes on your floor and no accounts are rerouted: it is an analysis of your history. Live pairing comes after the readout, and in it 20% of accounts stay on your current routing as a control group.
What a compliance team checks, and what the documents say
| Question | What BestPair’s documents say | Where |
|---|---|---|
| Does the vendor contact consumers or decide treatment? | No. It changes only which agent works an account | Order Form, Standard Terms |
| Who is responsible for collection law? | Your agency: the FDCPA, Regulation F, the TCPA, state collection and licensing laws and your client agreements | Standard Terms |
| What data is sent? | Pseudonymised only. BestPair never asks for consumer names, Social Security numbers, phone numbers, email or street addresses, or bank or card details. Account IDs are your own, so BestPair cannot tell who a consumer is | Order Form, Data Processing Addendum |
| Gramm-Leach-Bliley Act | Where the data is nonpublic personal information, safeguards consistent with the FTC Safeguards Rule | Security Overview, Data Processing Addendum |
| State privacy laws | BestPair acts as a service provider, contractor or processor. It does not sell or share the data, use it outside the service, combine it with personal information from other sources except as the law permits, or try to re-identify anyone | Security Overview, Data Processing Addendum |
| Consumer requests | Forwarded to your agency within five business days. BestPair does not respond except on your instructions | Data Processing Addendum |
| Medical accounts | A Business Associate Agreement applies where protected health information is provided | Business Associate Agreement |
| Your clients | Your agency confirms it holds the rights, notices and consents needed, including under its client agreements, and BestPair acts as its sub-processor | Standard Terms, Data Processing Addendum |
| Security assurance | SOC 2 Type 1. A SOC 2 Type 2 audit is under way | Security Overview |
| Legal advice | BestPair does not provide legal or compliance advice | Standard Terms |
The Data Processing Addendum also says BestPair will tell your agency if it believes an instruction breaks data protection law. For medical accounts, see the BAA for medical accounts, and for creditor approvals, whether your clients have to approve a vendor.
The document pack to hand them
Send these before any data moves, so the review sets the date the first file arrives:
- The Order Form, the Standard Terms and the Data Processing Addendum, which one signature accepts together.
- The Business Associate Agreement, if your agency collects healthcare debt.
- BestPair’s Security Overview: hosting, encryption, access, incidents, sub-processors, retention and deletion.
- The SOC 2 Type 1 report, under NDA. BestPair also answers your written security questionnaire.
Add the field list, so the team sees exactly what leaves your systems: the data agent matching needs. For where the data is held and who can reach it, see where your data is hosted. What agencies sign, and in what order shows how the documents fit together.
What stays with your counsel
BestPair’s documents state what BestPair does and what it commits to. Whether that fits your agency is a separate question, and it belongs to your counsel and compliance lead: your licences, the laws in the states you collect in, and what each placement agreement allows. BestPair does not provide legal or compliance advice, and nothing on this page is legal advice.
Two answers set the timetable: whether any client agreement requires approval before account data goes to a vendor, and whether any of your files count as protected health information. Settle both before the Order Form is signed, because the Floor Assessment fee is paid before any data moves and is not refundable.
Common follow-up questions
Does anything change on the floor during the Floor Assessment?
No. The Floor Assessment (Stage 1) is a standalone report built from your history. Nothing changes on your floor during it, and no accounts are rerouted. A compliance team can review it as a data transfer first and look at live pairing before Stage 2 starts. Stage 2 starts unless you opt out in writing within ten business days of the readout, so plan that review to fit the window.
Do our collectors’ scripts or contact rules change?
No. People make every call. What collectors say, what they offer and the contact rules in your dialer stay as they are. BestPair changes only which collector works which account.
Does BestPair sign off that our agency is compliant?
No. BestPair does not provide legal or compliance advice. Its documents say what BestPair does and commits to, and your counsel decides whether that fits your licences, your client agreements and the laws that apply to you.
Do we need an NDA before sharing the documents with compliance?
No separate NDA is needed to start: the Standard Terms cover confidentiality, and a mutual NDA is available for the SOC 2 report.
What it could mean on your floor
Two minutes
Watch the explainer
What your dialer does with the next account, what pairing changes, and what the Floor Assessment measures. With captions.
Watch the videoYour floor
Try the calculator
Four numbers off your dialer and collections reports give an illustrative figure for your floor. It is at best informed guesswork until your own history is measured.
Open the calculatorA live test
Read the case study
170,000 telecom accounts split at random before the first call, and how the result was counted.
Read it
Would it be a bad idea to spend 45 minutes finding out?
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