Submissions


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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.

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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.

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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.

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In December 2019, ACCAN submitted to the Senate Environment and Communications Legislation Committee consultation on the telecommunications legislative reform package. The consultation focused on two Bills under consideration by the Federal Parliament – the Telecommunications Legislation Amendment (Competition and Consumer) Bill and the Telecommunications (Regional Broadband Scheme) Charge Bill.

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ACCAN recently submitted to the ACCC’s inquiry into NBN Access Pricing. The inquiry examined the possibility of ACCC regulating the price of entry level NBN services, in order to facilitate consistent pricing for services that are equivalent to legacy ADSL internet services.

ACCAN is supportive of measures being taken to allow for consumers to smoothly transition to NBN services without facing material increases in the price of their existing service.

Although broadly supportive of the ACCC’s inquiry, ACCAN argued that:

  • The best approach to providing pricing relief is through the introduction of a funded concessional broadband service for low income households;
  • If pricing regulation of the NBN is implemented, it should be applied to the 25/5Mbps speed tier rather than the 12/1Mbps speed tier;
  • The proposed retail price point of $60 for (a 12/1Mbps service) was well in excess of what many consumers can afford to pay.

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The telco industry peak body, Communications Alliance, is reviewing the Integrated Public Number Database (IPND) Code. The IPND is a secure database that stores all listed and unlisted public numbers assigned to communications services. These include numbers assigned to a telephone, fax machine, or connected device like a tablet or car that can make and receive calls via Bluetooth. The IPND includes information about the service, including the name of the customer, the telco that provides the number, and the where the ‘service address’ is (that is, the street address where the customer lives or where telephone service is located).

The IPND Code sets out rules for telcos that supply information to the IPND, and for anyone that uses information from the IPND. In a 2018 review of the IPND, the ACMA found that a large portion of information was inaccurate. The IPND Code is being updated to make sure that telcos frequently compare their customer information with information in the IPND, and correct any discrepancies that are discovered.

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The ACMA is reviewing rules about international mobile roaming (IMR) for Australian telcos. They have proposed that International Mobile Roaming rules should be applied via a service provider determination, rather than an industry standard. This makes the rules administratively simpler to change and increases the maximum penalty for non-compliance. The ACMA has proposed a few other updates to mobile roaming regulation with the intention of making the rules more flexible for customers and telcos.

ACCAN supports of some, but not all, of the proposed changes. We agree with the tightening of existing International Mobile Roaming rules. However, we are concerned that some flexibility measures are too discretionary, and fail to provide appropriate consumer protections.

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ACCAN made a submission to the House of Representatives inquiry into 5G in Australia. ACCAN highlighted the need for whole of community engagement in the roll-out of 5G across Australia, emphasising the role that the telecommunications industry and government agencies need to undertake to ensure that consumer information is easily accessible, reliable and evidence based.

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ACCAN participated on the review of the industry code, C625 Information on Accessible Features for Telephone Equipment Code. The Code requires handset manufacturers to provide information about the accessibility features on their handsets to telcos. It also requires that handset manufacturers make this same information freely available to consumers. The updated Code also includes ACCAN’s Accessible Telecoms service as an alternative way for consumers to get information about accessibility features for handsets.

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The Office of the Australian Information Commissioner (OAIC) recently sought feedback on its Draft Privacy Safeguard Guidelines for the Consumer Data Right (CDR) regime. The Guidelines explain the Information Commissioner’s interpretation of the privacy safeguards and Consumer Data Rules, and provide examples of how the privacy safeguards and Consumer Data Rules may apply in certain situations. As the CDR regime will be extended to the telecommunications sector in the future, after first being implemented in the banking and energy sectors, ACCAN provided a response to the OAIC’s Guidelines.

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ACCAN has submitted to the ACCC’s consultation concerning its draft decision on Wholesale Service Standards. The purpose of the inquiry is to determine whether NBN wholesale service levels are appropriate and to consider whether a determination on service levels is required to improve customer outcomes. ACCAN has long advocated for reform of existing customer service guarantees surrounding connection timeframes, fault rectification and network reliability.

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NBN Co is consulting on options to change its wholesale prices to lift the demand for its broadband services, and on options for managing network usage to make services more attractive for retailers and consumers. Unusually, NBN Co has published its consultation paper, a move supported by ACCAN.