Submissions


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On 1 October 2021 the Digital Transformation Agency released the exposure draft of the Trusted Digital Identity Bill for public consultation.

ACCAN made a submission in response to the Bill welcoming the stronger privacy protections and enforcement and penalty provisions that have been introduced. However, ACCAN argued in favour of an oversight authority with more funding and a mandate to ensure consumers were compensated for breach of the legislation.

The Regional Telecommunications Review occurs every three years and is an opportunity to assess the issues impacting regional, rural and remote consumers of telecommunications services.

Since the last Review, regional communities have experienced natural disasters and the COVID-19 pandemic, both of which have highlighted and heightened the need for access to reliable, resilient and affordable telecommunications services. Whilst there has been significant investment in telecommunications infrastructure in recent years, ACCAN’s submission highlights that there remains room for improvement when it comes to accessing high quality services and having the digital skills to benefit from those services.

The Australian Communications and Media Authority (ACMA) is developing a Statement of Expectations (SoE) for the telco industry to guide the way it identifies and responds to customer vulnerability. The SoE sets out goals, outcomes and examples for telcos to adopt in different areas that impact consumers experiencing vulnerability, including customer service, selling and contracting, and disconnection.

ACCAN’s submission strongly supports the goals expressed in the SoE and makes a number of recommendations to expand the scope and improve the effectiveness of the SoE.

ACCAN has prepared a submission to the Communications Alliance regarding Telecommunications Industry Code DR C666-2021, Existing Customer Authentication.

This code is intended to protect consumers against fraudulent activity and outline how telecommunications providers with ensure that activity related to a customer’s account is properly verified and is actually authorised by the customer or their authorised representative.

Local number portability allows consumers to transfer – or ‘port’ – their local landline telephone number to a new service with a different telco provider. This allows consumers to switch providers without losing their number, which supports competition in the telco market.

Local number porting can be a complicated technical process. The Local Number Portability Code (the Code) outlines the procedures that telcos must follow in relation to local number porting. It is important that the Code is thorough and fair so that consumers do not lose their local number in the process, or face lengthy delays when switching providers.

ACCAN’s submission to the Code review makes recommendations to amend the Code to improve consumers’ experiences of local number porting, in line with changes in the market and providers’ technical capabilities. We also recommend that consumers’ rights during the local number porting process should be reviewed and strengthened.

The ACCC recently sought feedback on its position to declare the Wholesale Asymmetric Digital Subscriber Line (ADSL) service until 30 June 2024. The declaration will require Telstra to continue to provide other internet service providers access to Telstra’s copper network on request, allowing for retail competition on the network.

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.

On 13 July 2021, the Australian Government opened consultation on options for regulatory reforms and voluntary incentives to strengthen the cyber security of Australia’s digital economy.

ACCAN made a submission in response to the Strengthening Australia’s cyber security regulations and incentives discussion paper. ACCAN submitted that:

ACCAN responded to the Federal Government’s consultation on the grant guidelines for the Peri-Urban Mobile Program. The program is designed to deliver funding to improve mobile connectivity in bushfire prone areas on the peri-urban fringe of major cities.

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.

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.

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: