Submissions


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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.

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The ACCC requires nbn to report quarterly on the number of services operating on its network. The data provides transparency about the types of service sold by nbn (for example, by technology and speed level) and which telecommunications providers are buying what. The ACCC releases some of the data collected to the public. (to understand why this data is so useful see our blog). The ACCC recently consulted about the usefulness of this reporting and if it should continue.

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Communications Alliance, the telecommunications industry association, is proposing that the industry code ACIF C609:2007 Priority Assistance For Life Threatening Medical Conditions be replaced with a guideline. ACCAN opposes replacing this long-standing consumer protection Code with a guideline. ACCAN asserts that consumer and community safety and certainty are better protected by maintaining the Code which can be monitored and enforced by the Australian Communications and Media Authority (ACMA). Our submission makes a number of recommendations to maintain the Code instead of replacing it with a guideline.

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ACCAN has submitted to the review of the Mobile Premium Services (MPS) Code, conducted by Communications Alliance. MPS deliver paid information and entertainment to your mobile using 19xx text messaging, which is then charged to your mobile phone bill. The MPS Code sets out industry rules and consumer safeguards for mobile service providers (for example, Telstra, Optus and Vodafone) and 19xx third party providers (for example, Oxygen8 Australia, Mobile Embrace).

ACCAN’s research, Third Party Charges: Consumer Experiences and Expectations, shows that stronger consumer safeguards for MPS and other third party services are needed. Current arrangements are not adequately protecting consumers from unsolicited third party charges, and poor industry practices.

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ACCAN does not believe that the current framework governing the delivery of broadband services is in the interest of consumers. Too often consumers have no transparency or assurance over their service, get passed between retailer and wholesaler and could potentially be left without access to any network. ACCAN strongly supports the Statutory Infrastructure Provider legislation. We encourage the introduction of the legislation as quickly as possible so the powers within the legislation can be used to protect consumers and their services.

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The Telecommunications Industry Ombudsman (TIO) is required by section 133A of the Telecommunications (Consumer Protection and Services Standards) Act 1999 to undergo an independent review. The review is being conducted by private consultancy Cameron.Ralph.Khoury and is to be completed by 17 August 2017. ACCAN submitted to the review after consulting with its members about their experiences with, and opinions of the TIO.

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ACCAN recently submitted to the Communications Alliance on its consultation paper, Industry Managed Numbering Arrangements. Communications Alliance is proposing to take over all responsibilities for the management of telecommunications numbering, which is currently undertaken by the ACMA, Communications Alliance, and Industry Number Management Systems Ltd.

Numbering is important as telephone numbers let consumers know what type of service is being called (i.e. a mobile, national, international, toll or free number) and how much a call is likely to cost. This has important accessibility and affordability implications.