Submissions


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The Department of Communications and the Arts recently commenced a review of Australia’s management of the .au domain by the Australian Domain Authority (auDA). ACCAN submitted its comments on the management framework of auDA and ways to ensure the .au domain continues to serve the needs of the online Australian community.

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Communications Alliance, the communications industry peak body, is proposing to deregister and repeal the Call Charging and Billing Accuracy Code (C518). This Code sets out requirements for providers to test the accuracy of their call charging and billing for the standard telephone service (STS).

ACCAN believes the Code contains important detailed provisions to support accurate billing, such as requiring providers to develop and implement a test plan; to use performance indicators for accuracy testing; and compliance reporting requirements. In our submission, we acknowledge that the Code may have declining applicability, but argue that its principles are still relevant. It is important that consumers have confidence that their billing is correct, and reflects actual usage.

Complaints data from the Telecommunications Industry Ombudsman (TIO) illustrates that billing for communications services is a significant consumer issue, with 41.9% of the 2016-17 financial year complaints relating to billing and payments.

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ACCAN and Internet Australia have jointly submitted to industry peak body Communications Alliance’s consultation on the deregistration and repeal of the End to End Network Performance for the Standard Telephone Service (STS) Code.

The Code sets out technical rules for the performance of standard voice services. These rules mean that voice services operate within acceptable standardised levels of echo, delay and loudness, supporting positive consumer experience. Our submission argues that consumers both need and deserve the high quality of voice telephony supported by the Code.

Communications Alliance considers that C519 no longer holds currency and practical value due to frequently evolving telecommunications technology and the declining use of the STS, and the current scope of the Code.

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ACCAN provided comments to the Communications Alliance on the Prepaid Calling Card Guideline. The original purpose of the Guideline was to ensure that consumers were adequately informed when making a decision on which calling card to buy. ACCAN submitted that the current Guideline no longer achieves this purpose and that its objectives should be redrafted to reflect its actual content. This is because a 2015 review of the Guideline removed a majority of content that was replicated in the Australian Consumer Law and by the Telecommunications Consumer Protections Code. The Guideline now only contains two sections; one on Emergency Services Requirements, and another on general rules. ACCAN submitted that if the Guideline were to be withdrawn, it should be on the condition that these two sections are moved to a new enforceable instrument.

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The Australian Competition and Consumer Commission (ACCC) has powers to request information from providers in the telecommunications market about telecommunications infrastructure. These powers are an important tool to inform the ACCC’s work. As an example, the ACCC could use these powers to request information about infrastructure like the mobile networks owned by Telstra, Optus and Vodafone.

The ACCC is consulting on improvements and revisions to the information it requests from telco infrastructure providers. ACCAN welcomes the proposed changes to these rules as they benefit competition in the telecommunications markets.

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Recently, auDA, the body responsible for Australia’s domain name system agreed to introduce ‘direct registrations’. This is where your chosen internet domain name does not use the familiar “.com.au”, “.net.au”, “.org.au”, and new names will be simply “orgname.au”.

Many Australian not-for-profit organisations and businesses currently have domain names for their internet presences under the second level domains. For example: *.com.au and *.org.au. Domain names are used to find resources and services on the internet such as web pages (eg www.accan.org.au) and email addresses (This email address is being protected from spambots. You need JavaScript enabled to view it.).

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ACCAN contributed to the Financial Rights Legal Centre’s  joint consumer submission on the Review of the Privacy (Credit Reporting) Code 2014 (CR Code). The other contributors included the Australian Privacy Foundation, the Consumer Action Law Centre, the Consumer Credit Legal Service (WA), and Financial Counselling Australia.

The CR Code makes up part of Australia’s credit reporting scheme, and is important as it strengthens consumer privacy protections.  The joint consumer submission makes 34 recommendations on a wide range of consumer issues including: Repayment History Information and financial hardship; the need for independent code governance; the inclusion of credit scores on free credit reports; ongoing problems with accessing free credit reports; and many others.

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ACCAN recently provided feedback to the Digital Transformation Agency on the draft documents for the Trusted Digital Identity Framework.

The documents set out the rules (policies, standards, and requirements) for all organisations and agencies that want to take part in the Government’s digital identity project. When the project is complete, consumers will be able to create a single online identity called ‘Govpass’ to login into all services provided by the participating agencies and organisations.

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As a member of the Broadband for the Bush Alliance (B4BA), ACCAN contributed to a response to the NT Government’s discussion paper, Towards a digital strategy for the NT. The paper clearly outlines many of the benefits of increased connectivity and ICT innovation for Territorians. However,  B4BA argues in its submission that in order to design and implement an effective digital strategy, current barriers to affordable, accessible, and reliable telecommunications services must be addressed.

Importantly, B4BA has recommended that the NT Government’s digital strategy should prioritise achieving basic levels of access for all Territorians. This would include providing reliable and affordable broadband internet in the 44 communities where it is not yet available, and mobile services in the 30 communities where there currently are none.

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Since May 2016 nbn has been attempting to change the rules under which it operates in a document called the Special Access Undertaking (or SAU). These changes need to be approved by the ACCC. Primarily, this is to include other technologies (HFC, FTTN and FTTB) in the SAU. After the ACCC refused to accept its last proposed changes, nbn has revised the document again.

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5G mobile broadband services are expected to deliver many benefits and increased capacity services for consumers. The ACMA is examining the use of a spectrum band (3.6GHz) for this use in the near future.

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Migrating to the National Broadband Network (NBN) is a complex process. It requires the coordination of a number of parties including Telstra, nbn, consumers and retail service providers. The Department of Communications and the Arts has revised its migration framework principles, to try to ensure that consumers and businesses experience a smooth transition.