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Join us as our panel of experts explore the requirements of lawful intercept within the Australian context and demonstrate an open source approach to meeting your obligations.  

During this online session, you will hear about the creation of the OpenLI project, ETSI lawful intercept standards and how they are implemented through OpenLI software, and hear from a leading network consultant as he shares his experience deploying OpenLI in ISPs.  

The session will conclude with an engaging discussion in which the panellists present their current unknowns about the Australian intercept landscape allowing attendees to share their unique intercept challenges.  

Lawful Intercept on the Cheap 
Date: Tuesday, 16 August 2022 
Time: 1:00pm – 2:00pm AEST / 11:00am – 12:00pm AWST 
Location: Online via Zoom  

Moderator
Narelle Clark – Internet Association of Australia Ltd
Narelle Clark is Chief Executive Officer of the Internet Association of Australia, a not-for-profit telecommunications carrier operating internet exchanges across Australia and New Zealand. Ms Clark has a broad technical and strategic view of Internet scale ICT delivery, having been a user, builder, operator and researcher of Internet networks through her extensive career with major telecommunications companies, research agencies and consumer bodies, as well as a leadership and governance background in the not-for-profit sector. She is an Honorary Fellow with the University of Wollongong and holds a seat on the board of the Public Interest Registry, which operates the .Org top-level domain. Ms Clark was also a Trustee of the global Internet Society from 2010-2016.

Panellists
Dave Mill – SearchLight Ltd
Dave Mill is a Network Consultant at SearchLight Ltd, but also cameos as the token figurehead and industry advocate for the OpenLI project.

Dave has worked in the NZ ISP industry for 20 years. For his main day-to-day role, Dave is a network consultant to ISPs and Enterprises, part of which includes the deployment of OpenLI. Dave has unique experiences to share from deploying intercept software in a variety of different ISPs with unique set-ups and requirements.

Richard Nelson – University of Waikato 
Richard has been a researcher in the networking area for 30 years and led the network research group (WAND) at the University of Waikato. He founded the OpenLI project with funding from NZ ISPs to develop the software. Richard has now left the University and is working on ensuring the longterm success of the OpenLI project, among other things.

Shane Alcock – University of Waikato 
Shane has been the lead developer of the OpenLI software since the project began in 2018. He has been a research programmer with the WAND network research group at the University of Waikato since 2005, specialising in writing open-source software to passively capture, analyse and understand Internet traffic. The software written by Shane is used by a number of highly renowned researchers in the Internet measurement field, including researchers at UCSD/CAIDA, Georgia Tech and ISI/USC. 

Sophia Joo – Internet Association of Australia Ltd 
Sophia Joo is IAA’s Policy Officer, responsible for everything that happens in the advocacy corner. Joining IAA in 2021, she brings previous experience as a paralegal for Yahoo Australia and further experience from an internship with the Environmental Defenders Office. Sophia has a Bachelor of Arts, majoring in Political Economy, and is awaiting to receive her degree in Bachelor of Law. She is currently completing her Graduate Diploma of Legal Practice to be admitted as a lawyer. 

Mark Parncutt – Australian Federal Police
Mark is the Officer-in-Charge, Surveillance Integration Delivery, with responsibility for the collection, processing and presentation of lawful intercepts at the AFP. He has a background as a software developer, systems administrator and digital forensic analyst in law enforcement for the past 7½ years and in the private sector prior to that. Mark is passionate about the difference that lawful intercepts make to law enforcement operations and has contributed to innovation in both technology and policy through inter-agency and industry forums.

Watch Now
 

How do ISPs meet their lawful intercept obligations? In this online session we will hear from Richard Nelson, Shane Alcock (Uni of Waikato) and Dave Mill (Searchlight), as well as IAA’s Sophia Joo, where they will explore the requirements of lawful intercept within the Australian context and demonstrate an open source approach to meeting your obligations. 

Date: Tuesday, 16 August 2022
Time: 1-2pm AEST / 11-12pm AWST
Location: Online via Zoom (registration opens 18 July) 

This month’s Meet the Member segment features our wonderful Deputy Chair, Brett O’Hara, who is employed as a Senior Network Engineer at Vocus in the Platform Engineering Group.  Brett joined IAA in 2019 after attending IAA events as a guest of a Corporate member to meet and network with people in the industry.  

Brett’s interest in the Internet industry was an extension of his early hobby: messing around with modems and other network gear. Working out how to exchange international email via UUCP locally rather than expensive international calls was a real thrill – he was lucky enough for this to then become a career! 

Throughout his career, Brett has achieved many things. From starting out in a dial-up ISP in the 90s that quickly evolved from PSTN to ISDN to Frame Relay, ATM and ever upwards. Moving from kilobits to megabits and then gigabits in just a few years. These days working at Vocus, he evaluates, selects and deploys new network platforms into their network, as well as manages new features and lifecycles on existing platforms to help Vocus stay on top of new and developing technologies.  

Earlier last week, we released a report “Benefits of the Internet Association of Australia” by Michael Kende – a globally recognised expert economist and thought leader on issues relating to Internet interconnection and Internet Exchange Points (IXPs). The report outlines the benefits of Internet Exchange Points, particularly the peering network we provide and other ancillary services that significantly benefit the Australian Internet ecosystem. It considers our broader services and offers an economic perspective on their contribution to the Internet market through cost reduction and much more. If you want to read the full report, you can access it through our website.   

One of our staff members caught up with Michael Malone while hiking on the El Camino de Santiago in Europe! Michael was one of the owners of iiNet when the Association was formed and was one of the significant contributors of hardware and expertise that helped build WA-IX. He recounted what connectivity and the market were like back in the early days of the Internet in Australia and described WA-IX as a cooperative effort more than a profitable venture.   

When asked about initial discussions regarding the exchange, Michael recalled that many WA techs had been talking about it as a peering point for a long time, and everyone knew it would be a good thing. One sticking point was the actual physical location, as the closest organisation would pay less to connect to the IX. He said the most obvious place was in the city as Wantree, OIS, and iiNet were all there, but others like Omen and DialIX were in the suburbs. After much going around, the QV1 location was finally agreed upon!  

Michael recalled that people like Michael O’Reilly, PRK and Patrick from iiNet; Mark and Mick from Omen; Roger Yerramesetti from Wantree; David Luyer at UWA and many others rolled up their sleeves to set up WA-IX. They all volunteered their time to build and maintain the new IX. He also explained that once the IX was built, it became an essential service because the core ISPs and universities were already connected and given that it was mutually beneficial, it was even more compelling for others to join it – pretty much the definition of a network effect.

Michael explained that the IX survived because of good decisions at the beginning, many of which were really just good luck and the power of engineering consensus. The uptake of it increased because of goodwill, the good it did for the community and approaching those who were not connected and asking them, “why not?”. Initially, they ran a couple of conferences that brought people into the same room, which seemed to help, too.  

Michael hopes to see the Association properly funded and continues to bring the Internet engineering community together – to make decisions based on what’s good for the connected community. He would also like to see a place of learning where members can get together and exchange war stories in a fun and casual setting.  

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.  

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