Two duties in 28 TAC § 34.616 are owed to people who are not the firm’s customer, which is what makes them easy to overlook. The first concerns disclosure. A registered firm SUBCONTRACTING MONITORING SERVICES to another registered firm must advise the monitoring services subscriber of the IDENTITY AND LOCATION of the registered firm actually providing the services — unless the firm’s contract with the subscriber contains a clause giving it the right, at its SOLE DISCRETION, to subcontract any or all of the work or service. So the disclosure is the default and the contract clause is the exception, which is the reverse of how most firms assume it works. A firm with no such clause owes the subscriber a name and a place.

The second concerns what a central station says when it picks up the phone. A REGISTERED MONITORING FIRM REPORTING AN ALARM OR SUPERVISORY SIGNAL to a municipal or county emergency services center must provide, AT A MINIMUM, five things: the TYPE OF ALARM, the ADDRESS of the alarm, the NAME OF THE SUBSCRIBER, the DISPATCHER’S IDENTIFICATION, and a CALL-BACK PHONE NUMBER. That is a floor rather than a script — at a minimum are the rule’s words — and every item on it is something the responding service will need before anyone arrives.

One further item is supplied only on request, and it exists because of the subcontracting the first duty covers. IF REQUESTED, the firm must also provide the NAME, REGISTRATION NUMBER AND CALL-BACK PHONE NUMBER OF THE FIRM CONTRACTED WITH THE SUBSCRIBER to provide monitoring service, IF OTHER THAN THE MONITORING STATION. Read the two duties together and the design is clear: a subscriber is entitled to know who is really watching, and an emergency services center is entitled to ask the same question at the moment it matters. Neither duty is discharged by the firm that holds the customer relationship being reachable; both point at the firm actually providing the service.