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ACCAN has made a submission to the Communications Alliance review of AS/ACIF S040: 2001   Requirements for Customer Equipment for use with the Standard Telephone Service — Features for special needs of persons with disabilities. While recognising the significant changes which have taken place across the telecommunications industry since 2001, ACCAN’s submission stressed the importance of maintaining these accessibility standards.

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As part of its ongoing commitment to fighting spam, the ACMA invited ACCAN to make a submission commenting on the necessity of maintaining regulatory control of unsolicited fax marketing. Since the introduction of the Fax Marketing Industry Standard 2011, the number of consumer complaints about fax marketing spam has declined dramatically, with only 146 complaints in the last ten years, and most of those prior to 2014. The 2011 Standard is due to sunset on 1 October 2021, and ACCAN agreed with the ACMA’s proposal to replace the existing 2011 Standard with a 2021 Standard which retains all the existing consumer protections.

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ACCAN is keenly following the scope of the ACCC’s Digital Platforms activities as there are clear implications, both positive and negative, for consumers in many of these areas under review. Unarguably, the increased convergence of digital technologies can provide significant benefits for both individuals and the broader community when the appropriate competition and consumer protections are in place. ACCAN is supportive of competitive and efficient markets that provide consumers choice and confidence.

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ACCAN recently submitted to the Digital Identity Legislation Phase 2 consultation. While ACCAN welcomed several of the provisions included in the draft legislation we had concerns about the following:

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NBN Co’s Special Access Undertaking (SAU) is a key part of the nbn’s regulatory framework. The SAU determines how much nbn can charge for wholesale phone and internet services and provides the framework for non-price issues to help ensure the nbn works in a way that protects the long-term interest of consumers.

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On the 18th June ACCAN attended an industry roundtable hosted by the ACCC. The purpose of this roundtable was to discuss the regulatory arrangements for the nbn that could be established under the revised SAU – Special Access Undertaking. The ACCC prepared a framing paper prior to the roundtable. In response to the framing paper, ACCAN:

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ACCAN recently submitted to the ACCC regarding an authorisation application for members of the Telco Together Foundation (TTF) to work collaboratively to reduce modern slavery.

The authorisation would allow TTF members to engage in conduct that would normally be viewed as anticompetitive and illegal. Under the authorisation, collaborative conduct would be allowed in relation to specific activities necessary to identify and address modern slavery within telecommunications industry supply chains.

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Nbn Co sought feedback on the second consultation paper of its wholesale pricing review. Earlier in 2021, ACCAN provided feedback to its first consultation paper.

In our response to nbn Co’s second consultation paper ACCAN explained that we would not like to see wholesale costs for residential customers increase, due to the flow on impact that wholesale price increases can have on consumers. As such, in our response ACCAN supported:

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ACCAN has responded to the Digital Transformation Agency’s consultation paper on proposed laws for the Australian Government’s Govpass digital identity platform.

ACCAN’s recommendations included:

  • All privacy and consumer protection safeguards in the Digital Identity Framework must be enshrined in law to ensure compliance;
  • The definition of Digital Identity should be harmonised with the revised Privacy Act to create a robust network of privacy protections for consumers; and
  • A charging framework should not be introduced as it will discourage some non-government organisations from using the Digital Identity system.

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ACCAN responded to the Department of Infrastructure, Transport, Regional Development and Communications’ consultation on the circumstances in which Statutory Infrastructure Providers are exempt from the obligation to connect and supply premises with wholesale communications services, via telecommunication retail providers. The Department has been consulting on the draft Telecommunications (Statutory Infrastructure Provider – Circumstances for Exceptions to Connection and Supply Obligations) Determination 2020 that would give effect to these arrangements.

It is important that premises are only refused connection and supply of telecommunications services in limited and reasonable circumstances. ACCAN considers that generally the draft determination proposed by the Department ensures this is achieved.

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ACCAN recently made a submission relating to the draft AS/CA S042.1:2020 Requirements for connection to an air interface of a Telecommunications Network— Part 1: General. The aim of this Standard is to provide requirements and test methodology for customer equipment used in connection with a Public Mobile Telecommunications Service (PMTS) or Satellite Service.

In our submission ACCAN argued that there is a need for improved consumer education around making emergency calls from different types of customer equipment.

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In December 2020, ACCAN submitted to the Australian Attorney General’s Department Issues Paper consultation on the review of the Privacy Act 1988. Our submission aimed to ensure privacy settings empower consumers and protect their data, and we worked closely with privacy advocates in developing our response. The review is part of the Australian Government's response to the Australian Competition and Consumer Commission's Digital Platforms Inquiry.

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