Submissions


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ACCAN recently made a submission to the eSafety consultation on the Draft Restricted Access System Declaration 2021. The Declaration updates the 2014 Declaration to align with the changes in the Online Safety Act 2021. ACCAN broadly supports the Draft Declaration. However, we did reiterate our concerns that aspects of the enforcement mechanisms are unlikely to result in the intended outcome of greater community protection.

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ACCAN recently made a submission to the Department of Infrastructure, Transport, Regional Development and Communications consultation on the Online Safety (Basic Online Safety Expectations) Determination 2021 exposure draft. The consultation provided an opportunity to comment on the government’s expectations on how online services should pro-actively act to protect Australians from online harm and abuse.

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ACCAN recently made a submission to the eSafety Restricted Access System (RAS) consultation. The consultation sought feedback on how the new RAS can best balance both the policy objective of keeping children and young people safe online, while not placing unnecessary financial or administrative burden on industry.

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The ACCC sought views on proposed amendments to the Audit of Telecommunications Infrastructure Assets – Record Keeping Rules. The record keeping rules require carriers and carriage service providers to keep records on the location of their infrastructure and provide this information to the ACCC. ACCAN is supportive of the amendments to these rules which ensure that the information collected is kept up to date with industry developments and assists the ACCC in its regulatory functions.

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The Australian Communications Consumer Action Network (ACCAN) has made a submission to the Department of Infrastructure, Transport, Regional Development and Communications in response to an issues paper regarding a new scheme for captioning on subscription (pay) television.

In our submission, ACCAN supported the proposal to simplify the current Pay-tv rules which are overly complicated and do not provide any clarity about which programs will be captioned.

 ACCAN strongly supports the current legislated mandate that subscription television providers caption 100 per cent of their programming by 1 July 2033., As such, we did not support the proposed averaging of caption targets nor the proposed freezing of annual captioning increases.

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The Federal Government has sought feedback on changes to Telstra’s carrier licence conditions. The proposed changes would increase Telstra’s level of reporting in regard to voice services that sit outside of NBN’s fixed line footprint.

Consumers living outside NBN’s fixed line footprint are heavily reliant on voice services provided over Telstra’s network, so it is important that the reliability of the services is transparent. It’s also essential that there is visibility of Telstra’s performance in meeting its obligations under the Universal Service Obligation regime, and how well it is meeting the Customer Service Guarantee standard.

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ACCAN provided a response to the Federal Government’s consultation on the Grant Guidelines for the Regional Connectivity Program Round 2. The program aims to use a place-based approach to telecommunications infrastructure investment that will respond to local priorities and maximise economic opportunities and social benefits for regional communities and businesses.

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The Senate Environment and Communications Legislation Committee recently sought feedback on the Telstra Corporation and Other Legislation Amendment Bill 2021. This Bill proposed amendments to different pieces of legislation to ensure that key regulatory obligations continue to apply to Telstra after its restructure.

In our response to this inquiry, ACCAN welcomed the Bill as it ensures that important consumer safeguards that currently apply to Telstra will continue to apply to the restructured Telstra companies. This includes things like the Universal Service Obligation, Consumer Service Guarantee and Network Reliability Framework arrangements, and Telstra’s obligation to provide Priority Assistance.

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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.

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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.

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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.

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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.