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ACCAN has made a submission in response to the Australian Human Rights Commission’s Human Rights and Technology Discussion Paper. This follows our 2018 submission in response to the Human Rights and Technology Issues Paper.

The Discussion Paper considers possible responses to the human rights challenges and opportunities brought about by new and emerging technologies. It consolidates the responses to previous rounds of consultation, and outlines the Australian Human Rights Commission’s thinking on a range of issues. In the Discussion Paper, the Australian Human Rights Commission offers a range of proposals designed to address the impact that new and emerging technologies have on human rights. This includes discussion of the impact of Artificial Intelligence (AI) and AI-informed decision making, and of accessible technologies.

ACCAN has made a submission to the South Australian Fire and Emergency Service Commission in response to the independent review of the 2019/20 bushfire season. ACCAN’s submission focused on the impact of bushfires on communications infrastructure and reliability, and how this affected communications consumers.

The ACMA is reviewing the Telecommunications (Provision of Pre-Selection) Determination 2015 to assess whether it remains fit-for-purpose. The Determination outlines the requirement for telco service providers to allow consumers to use ‘pre-selectable services’. Pre-selection allows consumers with landline phones on the copper network to use one telco service provider for local calls to other landline phones, but another provider for other types of calling, to mobile or international numbers for example.

ACCAN has no objection to the ACMA taking steps to withdraw the Determination, so long as the ACMA is certain there will be minimal impact on residential and small businesses consumers. Should the Determination be withdrawn, any consumers with pre-selectable services activated on their account need to be provided with adequate information and support while transitioned away from these services.

ACCAN recently submitted to the Department of Home Affairs consultation on the draft voluntary Internet of Things (IoT) Code of Practice. The Department of Home Affairs drafted the voluntary Code to help protect consumers from the potential security and privacy threats posed by IoT connected devices.

The lack of effective security and privacy protections often found in IoT devices mean they are a gateway for hackers to gain unauthorised access to private in-home Wi-Fi networks. Connected devices also collect vast amounts of sensitive personal data for advertising and other purposes which can be accessed by fraudsters.

The Department of Infrastructure, Transport, Regional Development and Communications is seeking feedback on the design and implementation of an online Digital Technology Hub. The Digital Technology Hub will support regional, rural and remote Australians to make the most of their phone and internet services. The Digital Technology Hub is intended to provide information and resources to people in non-metropolitan areas, to help them solve issues with their phone and internet.

ACCAN supports the introduction of a Digital Tech Hub for people in regional and remote areas of Australia. Our submission listed a number of recommendations for the Department to adopt, so that the Digital Tech Hub targets the diverse needs of regional Australians, builds on existing knowledge, and is widely publicised.

The Department of Infrastructure, Transport, Regional Development and Communications, previously named the Department of Communications and Arts, is looking to trial alternative ways of delivering voice (home phone) services in regional, rural and remote (RRR) areas. The Department is focusing particularly on areas in the high capacity radio concentrator (HCRC) footprint, where voice services are delivered via radio technology, rather than copper or via the Internet.

The Department is seeking feedback on how the trials should be designed, run and evaluated. ACCAN supports the trials as a welcome step towards delivering quality and reliable voice services in regional, rural and remote areas. We argued that a number of improvements could be made to the Department’s proposal, including: introducing performance benchmarks for trial services, developing minimum service assurances for participating consumers, and developing robust feedback mechanisms for all trial participants.

The Australian Communications and Media Authority (ACMA) conducted a consultation regarding proposed amendments to the Telecommunications (Emergency Call Service) Determination 2019. This Determination imposes requirements on carriers, carriage service providers and emergency call persons (Telstra and the National Relay Service provider) regarding access to the emergency call service (000, 112, 106). This consultation was in response to issues raised by the Senate Standing Committee for the Scrutiny of Delegated Legislation.

ACCAN recently submitted to the ACMA’s review of the NBN consumer experience rules.

The rules focus on improving the way the telco industry handles consumer complaints about the NBN, provides information about the NBN to consumers, and ensures consumers have access to a working service. The consumer experience rules also provide for the regulation of the migration of services from the legacy network onto the NBN.

ACCAN has provided a brief submission to the Communications Alliance review of Guideline G660:2018, Assisting Customers Experiencing Domestic and Family Violence. This Guideline offers education to telco providers about the impacts of domestic and family violence and how they can help customers who are experiencing domestic or family violence.

In our response, ACCAN outlined that more information is needed about whether the Guideline is currently being used by telcos. Once more is known about the use of the Guideline, ACCAN believes that the intended audience of certain parts of the Guideline could be reviewed to make it more user friendly for telco staff. We also suggested that the length of the Guideline could be reviewed given the length of other industry guidance notes regarding domestic and family violence.

ACCAN recently submitted to ACMA’s Draft Telecommunications (Mobile Number Pre-Porting Additional Identity Verification) Industry Standard 2020. ACMA drafted the Standard to help prevent the unauthorised porting of mobile service numbers and reduce the damage done to consumers from this activity.

Mobile number fraud is a gateway to identity and financial theft. ACCAN is aware of numerous reports by victims of fraudulent number porting which reinforce the need for stronger protections.

ACCAN recently submitted to the Department of Communications and the Arts review of the 2015 Telecommunications in New Developments (TIND) Policy. The policy governs the development of telecommunications infrastructure in new greenfields sites and competition between private sector infrastructure providers and NBN Co.

ACCAN is regularly contacted by consumers residing in non-NBN networked new areas that are experiencing poor service outcomes through slow or intermittent services, while facing higher than competitive retail prices for services that are often lower value than their NBN alternative. However, systematic evidence of poor outcomes is limited due to the opacity of current reporting arrangements.

ACCAN recently submitted to the Joint Parliamentary Committee on the NBN inquiry into the business case for the NBN and experience of small businesses.

The Committee is inquiring into the rollout of the NBN and the performance of NBN Co. in relation to its key financial and economic forecasts, coverage, the delivery of services to small and medium businesses, as well as pricing and in particular the effect of pricing on low-income and rural and regional consumers.