ACCAN has provided a brief submission to the Communications Alliance review of Guideline G660:2018, Assisting Customers Experiencing Domestic and Family Violence. This Guideline offers education to telco providers about the impacts of domestic and family violence and how they can help customers who are experiencing domestic or family violence.

In our response, ACCAN outlined that more information is needed about whether the Guideline is currently being used by telcos. Once more is known about the use of the Guideline, ACCAN believes that the intended audience of certain parts of the Guideline could be reviewed to make it more user friendly for telco staff. We also suggested that the length of the Guideline could be reviewed given the length of other industry guidance notes regarding domestic and family violence.

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.

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.

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.

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.

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.

ACCAN recently submitted to the Australian Treasury’s consultation about the implementation of the recommendations of the ACCC’s Digital Platforms Inquiry Final Report. The Final Report provided recommendations to:

  • Promote competition among the services offered by digital platforms;
  • Enhance privacy protections for consumers;
  • Provide for a dedicated external dispute resolution body for consumers seeking to make a complaint about digital platforms; and
  • Prohibit certain unfair trading practices and terms currently faced by consumers.

ACCAN strongly supports the contents of the final report and our submission outlines how we believe that the recommendations can be progressed over the coming months.

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.

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.

The Regional Connectivity Program is part of the Government’s $220 million Stronger Regional Digital Connectivity Package. It was announced in the Government’s response to the 2018 Regional Telecommunications Review.

The Regional Connectivity Program will complement the NBN, the Mobile Black Spot Program and commercial investment plans of telco providers. The $60 million funding of the Regional Connectivity Program includes:

  • A competitive grants program
  • A digital technology hub
  • Alternative voice service trials in remote areas
  • Further development of the Universal Service Guarantee

The Department of Communications and the Arts is consulting on the application framework for grants to build communications infrastructure in rural, regional and remote communities.

This consultation focused on the design of the competitive grants program.

ACCAN wrote a submission supporting the Department’s approach and made a number of additional suggestions in order to ensure the program provides money to the communities that most need it.

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.

The Department of Home Affairs has been undertaking consultation around the development of Australia’s next Cyber Security Strategy. The current Cyber Security Strategy was written in 2016 and set goals to be completed over four years.

ACCAN has responded to the Department of Home Affairs’ discussion paper, to ensure that the experiences of consumers, including small businesses, are reflected in the 2020 Cyber Security Strategy. In our submission we focused on consumer concerns about cyber security, including the impact that cybercrimes have on consumers, including small businesses; the information asymmetry that can exist between consumers and manufacturers; and the threats to consumer privacy that can occur due to cyberattacks or insecure connected devices.

The Department of the Treasury, as one of the agencies involved in the implementation of the Consumer Data Right (CDR) regime, recently appointed Maddocks lawyers to conduct an independent privacy impact assessment regarding the initial implementation of the CDR. Maddocks has completed their draft privacy impact assessment report and requested stakeholder feedback on this draft.

Given that the CDR regime will be extended to the telecommunications sector, after first being implemented in the banking and energy sectors, ACCAN has been engaging with issues relating to the CDR and its implementation. This includes a short response to Maddocks’ draft privacy impact assessment.

ACCAN has made a submission to the Australian Competition and Consumer Commission (ACCC) Mobile Terminating Access Service (MTAS) inquiry, about the ACCC’s Final Access Determination (FAD) on price and non-price terms.

‘Standards Australia is reviewing the ways in which it distributes and licenses its standards. Standards are documents that set a benchmark for how something should be done or made by an individual, company, or industry. They can be adopted into regulation or legislation. Standards Australia has been investigating how to license and distribute standards in a way that delivers:

  • Greater reach for Standards Australia’s content,
  • Better awareness and use of standards,
  • Financial sustainability.

ACCAN has made some submissions to the Australian Communications and Media Authority (ACMA) regarding caption exemption draft orders for Fetch TV, Foxtel Cable Television, Optus Vision Media, Selectra and Telstra Pay TV.

In our submissions we urged the ACMA to deny the exemption applications, as Australians who rely on closed captions should be ensured the same functional access to television services as other Australians. We continue to call for equitable access to video programming, including subscription television services, for people who are Deaf or have hearing impairment.

The Australian Communications and Media Authority (ACMA) has conducted a second-round of consultation on the Emergency Call Service (ECS) Determination. A draft ECS Determination 2019 was provided for comment, in which a number of changes have been made based on the results of the first consultation process (completed in November 2018). It also outlines options for a trial of alternative call handling methods for SIM-less calls to the ECS.

The Department of Industry, Innovation and Science undertook a public consultation on Australia’s Ethics Framework in relation to Artificial Intelligence (AI).

ACCAN made a brief submission to this consultation. We outlined that consumer safeguards must be put in place to protect consumers from any unintended outcomes of new technology such as AI. We stated that compliance and enforcement procedures in relation to the ethical use of AI are necessary to protect consumers, as existing human rights, legislative and regulatory frameworks alone cannot completely protect consumers against unethical behaviour.

The Telecommunications Industry Ombudsman (TIO) is investigating options for internal reform in the wake of recommendations from the Consumer Safeguards Review Part A: Complaints handling and consumer redress. The first part of this investigation relates to possible changes to the TIO Constitution to reform the structure and selection of its Board. ACCAN’s response to the TIO Option Paper proposed a number of changes to enhance the independence of the TIO Board and strengthen the consumer perspective in Board matters.

The peak body for the telecommunications industry, Communications Alliance, has conducted a preliminary consultation on a Draft Industry Guidance Note about appointment of Authorised Representatives and Advocates. Authorised representatives are usually lawyers, financial counsellors or family members of customers who need assistance managing their telco affairs.

The Draft Guidance Note provides recommendations about how telcos should go about authorising representatives who act on behalf customers.

Communications Alliance will be consulting further on the Guidance Note in September 2019.

In our written feedback, ACCAN proposed that substantial adjustments be made to improve the efficiency and fairness of the authorisation process.

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