As we said earlier, we're not always going to send a company a warning letter to tell them that we see complaints about their situation, but in the course of an investigation we're going to be collecting records from any company we're looking at, asking them for compliance details and what their record of consent is; we look at all their record-keeping. For any company, that's an opportunity—it's a bit of a red flag—to come to talk to us, ask what we're looking at, and settle an undertaking with us on a voluntary basis before the investigation goes any further.
On November 9th, 2017. See this statement in context.