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“A user interface is like a joke. If you have to explain it, it’s not that good” – HackerNoon 

If you are a Developer/Programmer in Sydney looking to work with a dynamic team with flexible work options, then check out our latest job post! We’re looking for someone who has an excellent technical aptitude, shows a willingness to learn and can work independently.  

Working as part of the Development Team in building and maintaining the next generation IAA Member Services Portal, so having a good working knowledge of the telecommunications industry is desirable.  

If this sounds like a career opportunity you or someone you know would be interested in, then head over to our careers page to apply. Applications close Friday 14th March 2022. 

Completed Submissions
We’ve had a busy month in February, responding to four consultations, three of which were for the Minister of Home Affairs! 

Draft Rules Register of Critical Infrastructure & Mandatory Reporting Scheme | 1 February 2022
These Draft Rules would introduce additional security obligations for select industry members who are deemed as critical infrastructure assets. In our response, we emphasised the need for a measured approach that will reduce the obligatory burdens for businesses on behalf of our members in the domain name system and data processing or storage sectors who could become subject to the new rules. 

Exposure Draft Security Legislation Amendment (Critical Infrastructure Protection) Bill | 1 February 2022
This Bill, forming part two of the Security Legislation Amendment (Critical Infrastructure) Act enacted in December 2021 would introduce a Risk Management Program and enhanced security obligations for industry members. We requested that thresholds and definitions be clearly and appropriately regulated to ensure only necessary entities will become subject to the likely burdensome obligations under the new Act. 

Electronic Surveillance Framework Discussion Paper | 11 February 2022
In addition to the joint organization letter, we responded to the proposed major overhaul of Australia’s electronic surveillance system, particularly on behalf of our members. In our response, we focused on the potentially adverse impacts, particularly for smaller businesses as well as advocating for the broader public interest in ensuring government powers remain balanced and subject to appropriate oversight. 

Telecommunications Service Provider (Customer Identity Authentication) Determination 2022 | ACMA | 15 February 2022
Following our submission to the Customer Identity Authentication Determination last December, ACMA has invited us for further consultation on the revised Draft Determination along with other targeted stakeholders. We responded to their queries regarding existing systems on behalf of our members and requested greater time to be provided to businesses prior to the Determination coming into effect so that members can implement the requisite systems and processes. Furthermore, we opposed the inclusion of the Determination into the revised Telecommunications (Listed Infringement Notice Provisions) Declaration following its sunset in April 2022. We expressed it would be unfair to impose penalties on entities for failure to comply with new systems in the near future whilst systems were still being implemented. 

 

Open Submissions

2022 Broadband Speed Claims Guidance Consultation | ACCC | 25 February 2022
ACCC is seeking to review its Broadband Speed Claims – Industry Guidance 2020 (Guidance). This updated Guidance includes six principles regarding expectations for network operators, RSPs and consumers, and is part of ongoing periodic reviews by the Commission.  

 

A big thank you to all those members who responded to our survey on where our next IX should go. The survey is still open, and we are still keen to hear from you. We’re seeing good growth across all the exchanges, so it is definitely time to expand the footprint some more. Even if you aren’t likely to join us in Darwin or Hobart, please let us know which additional content or data centres on existing IXes you’d like to see. Our aggregate traffic is creeping closer and closer to daily heights of 800Gbps, so if there’s anything we can get on board that will boost us even further, let me know. VIC-IX participants have already noticed the recent increase in Google availability! 

More thanks also go to the members connected to NSW-IX that suffered through the rolling firmware upgrade we put through last weekend. Our technical team are most certainly glad to see the last of that bug (touch wood!) as it was darned inconvenient. It will be progressively rolled out across the rest of the exchanges as need, resourcing and notice allows. 

Over the last month, we’ve managed to hit our advocacy targets and coordinated a joint letter to the Minister for Home Affairs on the review of electronic surveillance legislation. With the upcoming election likely to have national security as a major theme, we thought it important to make sure industry took a united stance, so we teamed up with Communications Alliance, AIIA, Internet Australia, IoTAA, Digital Rights Watch and EFA. Other organisations were also approached who couldn’t make the short time frame for the letter, but as in the case of the ACS took an even stronger stance in their own submission. There are a number of issues with the proposal, from definitional problems with the meaning of ‘communications’ to the approaches to granting access to content and metadata. I’m sure we all agree the current regimen is fragmented, out of date and ridiculously complex, with holes the size of the last big pwnage. It’s a topic I’m sure we’ll hear more about over the coming months, so expect more FUD and noise. 

We’re also expanding the team some more to make sure we can deliver on the software development we have planned with the Member Portal. Check our careers page if you are looking for a coding job or know someone good to refer. This is a truly great place to work and makes a genuine contribution to the internet! 

Speaking of appointments, I have just joined the Advisory Board of the Electrical Engineering School at the University of NSW where I will contribute to the training program for telecommunications engineering and related disciplines. Apparently the number of students in this area has been going backwards (and not just for UNSW) for some time, despite the growth in industry need. It’s a discipline that has given me great joy and genuine career satisfaction, so how do we make it more attractive to students? 

Don’t forget to nominate for the Public Policy Advisory Panel, too. It’s a great way to give back to the association and the industry more broadly. Nominations are still open. 

Drop me a line if you want to follow up on anything. Or why not drop by our North Sydney office if you’re in the area? 

All the best
Narelle 

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