ACCAN recently submitted to the Australian Communications and Media Authority (ACMA)'s consultation on the Telecommunications (Domestic, Family and Sexual Violence Consumer Protections) Industry Standard 2025 (the DFSV Standard).
The introduction of the DFSV Standard is a generational step forward in the consumer protections available to communications consumers in Australia.
ACCAN thanks the Minister of Communications Michelle Rowland, the Department of Infrastructure, Transport, Regional Development, Communications and the Arts and the ACMA for progressing the development of these protections.
This submission recommends the ACMA:
- Expand the DFSV Standard to include requirements for credit and debt management protections for affected persons and measures to prevent DFSV related debt to appropriately reflect the objectives of the Telecommunications (Domestic, Family and Sexual Violence Consumer Protections Industry Standard) Direction 2024 (the DFSV Direction).
- Include upfront provisions in the DFSV Standard which reflect ACCAN’s key compliance outcomes. This would strengthen the DFSV Standard and preserve flexibility for providers to provide tailored support to affected persons.
- Introduce a positive obligation on Carriage Service Providers (CSPs) to take a tailored and appropriate approach to ensure and maintain the privacy of personal information and the security of accounts to appropriately reflect the requirements of the DFSV Direction.
- Require CSPs to provide support in the form of product or service customisation, customer awareness and education, staff training measures, safe communications measures, information protection measures and product or process design measures.
- Include a more proactive compliance monitoring and reporting framework consistent with the shift away from voluntary code-based framework to direct regulation of DFV protections via an industry standard.
- Extend the requirements under section 8(1)(j) of the DFSV Standard and introduce a positive obligation on CSPs to design and review systems, processes and products to prevent harm to affected persons.
- Amend the DFSV Standard to ensure that CSPs must not require evidence or supporting material which demonstrates that an individual is an affected person.
- Amend the DFSV Standard to ensure that CSPs with more than 30,000 services in operation (SIO) must undertake their own consultation with DFV experts. Consultations with DFSV experts need to be appropriately remunerated and carefully planned.
- Expand section 10 of the DFSV Standard to ensure that email is always provided as a contact method by CSPs.
- Amend section 7(b)(ii) of the DFSV Standard to ensure CSPs comply with the DFSV Standard and support the ACMA’s compliance activities.
- Extend section 8(c) of the DFSV Standard to prohibit CSPs from suspending an affected person’s telecommunications service, unless requested by the person. Where an affected person’s service is restricted, it must not put the affected person’s safety at risk. Where the DFSV Standard makes mention of disconnection, the ACMA should draft rules that take the impact of suspension and restriction of the affected persons’ telecommunications service into account.
- Expand the DFSV Standard to explicitly include provisions related to supporting affected persons’ authorised representatives.
- Engage with the Australian Energy Regulator’s Family Violence Rules: Guidance for Energy Retailers when considering the requirements on CSPs to limit or prevent the disclosure of information on invoices, bills and other customer-facing materials.
- Make minor amendments to the Telecommunications (Financial Hardship) Industry Standard 2024 to ensure the effective operation of the instrument when supporting affected persons.
- Amend the DFSV Standard to ensure that where a breach of an individual’s privacy has occurred, CSPs must be required to notify the affected person of the breach and possibility of inadvertent disclosure in addition to providing a referral to a specialist DFV service for safety planning assistance.
Download: ACCAN Submission - Supporting telco customers experiencing DFSV.pdf646.53 KB
Download: ACCAN Submission - Supporting telco customers experiencing DFSV.docx308.04 KB