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Another month has passed and work on the new portal continues. We’re not far from launch with final internal testing kicking off this month – we want to make sure it’s smooth, user friendly and looks fabulous! Over the next month, keep an eye out on our social media channels for sneak previews of the interface and what you can look forward to.  

Closer to the cutover time, you will receive communications from us via email to ensure your transition onto the new portal is as easy as possible. If you haven’t already, please ensure that your details are up to date, so you receive all the information you need.   

Back in 1995, a group of Internet enthusiasts rallied together to advocate for the interests of the Internet community in Western Australia. Two years on, they made one of the most unlikely moves for competitors to make and collaborated on a project that would not only help each others’ businesses, but helped everyone’s customers and improved Australia’s Internet – they formed WA-IX. It was described as a laudable show of cooperation as iiNet, Wantree, and Omen first connected on the exchange: built from donated hardware and put together by the hands of volunteers. At the time, the cost of domestic traffic sent and received was $1.46 PER MEGABYTE and definitely far too costly to be sustainable for many businesses.  

Not only did WA-IX make connectivity more affordable, but it also helped to fund the good works of the Association. WAIA was formed to be a representative voice of the Internet community and was run by volunteers; however, it did incur ongoing operational costs. With the combination of genuine care for the Internet community, users, and its members, WAIA (now known as IAA) has continued to grow and provides the longest-running peering network in Australia.  

Part of the ongoing success of WA-IX can be attributed to the fact that it stood alone and no longer ran on the goodwill of volunteers. As the first employee of WA-IX, Peering Engineer Gavin Tweedie recounted that before he was employed, to get access to the POP in QV1, you had to rely on your fellow competitor at another company to show up with the key! An exchange was also conducive to competition by lowering operational costs, which kept the cost of connectivity down for end users.   

Our association was built and continues to operate on goodwill as we continue to work for the Internet community and Australia’s Internet more broadly. Although peering is not as widely adopted in Australia as it is in other parts of the globe, it is definitely integral to its success. Cheers to 25 years of good connectivity, and may there be many more years of it to come! 

The UK Government’s response to the UK General Data Protection Regulation (GDPR) was released earlier this month following consultation regarding the UK’s response to the EU GDPR. Carrying hefty fines, GDPR regulates the data processing activities of businesses in an effort to protect the data and privacy of consumers and apply to all Europeans whether they reside in the EU or not. 

Here in Australia, the Attorney-General’s review of the Privacy Act 1988 is still ongoing, tackling issues of privacy and data protection. The discussion paper framing consultation for the review heavily referred to the UK Information Commissioner’s guidance and it is likely that the AG Office will be following the development of the UK Data Reform Bill and whether it passes through Parliament. 

IAA responded to the Privacy Act review, emphasising the need for a balanced privacy regime that protects the privacy of individuals in a reasonable, and legitimate manner while not disproportionately burdening industry. Read our full response.  

The Australian National Audit Office (ANAO) released its report on the Department of Home Affairs’ administration and regulation of critical infrastructure protection policies on 21 June 2022, and we’d have to say their assessment isn’t particularly positive. The report made seven recommendations, identifying improvements needed in the Department’s engagement of stakeholders, risk assessments and reporting obligations, performance measurement, and compliance management. 

Regulation of critical infrastructure has been a great focus for the Department in recent years with ‘critical infrastructure’ expanded to include more sectors, and they have been granted greater powers, even including direct intervention with an entity’s systems in certain circumstances.  

IAA has been actively involved in the consultation process for the implementation of critical infrastructure legislation. In our submissions, we consistently called for greater meaningful stakeholder engagement, including sector specific consultation. We also raised concerns that the implementation of the new powers and obligations was premature, and required greater review and thorough analysis to ensure the legislative reforms would ensure real benefits and outcomes. 

ANAO has since found the Department to lack an engagement strategy, and that despite sector specific strategies being developed prior to legislative reforms, “these strategies were discontinued before the reform engagement had concluded.”  

In addition, the Department’s performance measure was found inadequate, due to the measure not establishing targets supported by a verifiable method, not free from bias, and lacking detail on how performance against the standards contribute to achieving their purpose.  

The Department has accepted all seven recommendations to address the issues raised by the audit.  

Telecommunications is one of the sectors newly captured as critical infrastructure as of 2021. In addition to the critical infrastructure legislation, telecommunications is also regulated through the Telecommunication Sector Security Reforms (TSSR) as part of the Telecommunications Act 1997. As such, while the Systems of National Significance declaration power and enhanced cyber security obligations apply to the telecommunications sector under the critical infrastructure legislation, the Department of Communications is developing specific rules and obligations for the telecommunications sector. The sector can also anticipate a review into the TSSR later this year.  

IAA will continue to participate in consultation with government to ensure the implementation of rules for the telecommunications sector that are measured, effective and fit for purpose. 

On 1 June, Communications Compliance Ltd (CommCom)opened the TCP Code compliance attestation page. Currently live, lodgements are due on 1 September 2022, and Carriage Service Providers who provide telecommunications services to consumers (as defined in the Code) are required to submit an annual attestation of their compliance with the Code.  

CommCom is an independent body responsible for overseeing the conduct of the Code Compliance Framework outlined in Chapter 10 of the TCP Code that also promotes compliance with the Code through industry guidance and educational initiatives.  

This last month I’ve enjoyed a brief holiday, and in my absence the team have been just brilliant! Racks have been rearranged, submissions lodged, and our new portal has a shiny new layout. We’ve even cracked a new traffic milestone over the last week, so now 900Gbps is the new normal across the exchanges. Well done everyone, it looks like the IXes are delivering what you want.  

We also quietly observed the 25 year anniversary of WA-IX, and notice has gone out for a bigger birthday party later this year alongside our AGM. I hope we can get a good number of you along, as this will make up for the party we couldn’t have in 2020 to mark the 25th of WAIA itself! It has been great to see the preparation taking shape and we have some lovely messages already to hand from colleagues and friends around the world. 

One of the exciting pieces of reading during my holiday was the Australian National Audit Office (ANAO) report on the Dept of Home Affairs. I’d have to say it is one of the more critical – even scathing – reports I’ve read for a while. Statements such as “The department’s administration and regulation of critical infrastructure protection policy was partly effective” and “The department’s performance framework as it related to critical infrastructure was not adequate” echo our own observations and it would seem the department has a lot of work to do before the system becomes useful to any of us. Thankfully, they have accepted ANAO’s recommendations, but call me cynical, I await the implementation.  

The team also released two great research reports we commissioned that examine the value of our services and look at the impact we have on the internet ecosystem and the Australian market generally. I trust you enjoy the reading, and take as much pride in the contribution of your association as we do. 

All the best 

Narelle 

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