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From mid-September 2024, the Telecommunications Industry Ombudsman (TIO) will be implementing changes to its reclassification approach. The TIO have also released Guidelines about its approach to ‘reasonable first contact’ as well as a Member Briefing Pack to provide further information about the changes, both of which can be found on the TIO Member Portal.
From mid-September, reclassification requests made by a provider will only be granted if the provider can demonstrate that the complaint was resolved prior to the consumer making contacting with the TIO about the complaint. This means that reclassification requests will be declined if the complaint was resolved only after consumers contacted the TIO. In addition, the TIO will be increasing the “chance to consider” timeframe from 6 months to 2 years. Under this new approach, consumers can bring an unresolved complaint they raised with their provider in the last 2 years.
In addition, according to its Guidelines, the TIO will consider the following as reasonable attempts to make contact with their provider, before the consumer can raise the matter with the TIO:
- Where a consumer is unable to speak to a telco representative after being on hold for what is an ‘unreasonable period of time’;
- Where a consumer is redirected between multiple departments during a phone call, without having their issue addressed;
- Where a consumer is forced to contact the provider via multiple methods (e.g. webchat, in-store, by phone call) without having their issue addressed;
- Where a consumer is told the provider will make contact with the consumer by a certain time, and the consumer does not hear from the provider by the scheduled time; and
- Where a consumer with special needs is unable to contact the provider as the provider does not provider alternative methods of contact.
In light of these changes, it is important that you ensure your complaints handling processes align with these expectations and your staff are aware and well trained to deal with complaints. Remember, a consumer does not have to explicitly say they would like to make a “complaint” to invoke the complaints handling process.
IAA has raised concerns with the TIO about its new approach. In particular, its new guidelines on what constitutes ‘reasonable attempt to make contact’ may be too vague and sets the bar for a consumer to ‘attempt to make contact’ with a provider too low, potentially resulting in vexatious complaints being lodged with the TIO and imposes a higher standard for complaints handling than required by regulation. The TIO has assured IAA that while it will consider a consumer’s complaint in good faith, the Guidelines are intended to ensure a genuine attempt of contacting the provider has been made, and complaints will be considered on a case-by-case basis.
If you have any questions or would like to discuss the TIO reforms further, please contact us at policy@internet.asn.au.
Welcome to our newest Professional Members:
Nick Grundy
Matthew Keen
Mariana Hernandez
Mark Newton
Adam Holczer
Dave Browning
Hayden Flack
Karen Ganschow
Welcome to this year’s IAA Systers!
Lili Wan
Nasla Joshi
Cara Stylianou
Jossaline Tanasaldy
Nicola Cavaleri
Natalia Khobotova
Nancy Nguyen
Chaitrali Nandedkar
Chinmayi Sajjala
Thamali Hasitha Ratnayake
Jewel Gonzales
Fiona Atkinson
Lu Zhang
Gabriela Facci
Taylor Newnham
Thy Boskovic
Kayla Lizardo
Florence Kanapitu
Lynnette Mekau
Maybelle Galicia
Avanti Gauba
Kiki Fong Lim (current Member, congratulations)
Welcome to our Corporate Members:
RINGCENTRAL
With a focus on improving service quality and reliability for their Australian customers, we would like to welcome RingCentral. With offices in 14 countries, RingCentral provides simplified business communications that help people connect worldwide. Founded in 1999, they’re using the power of cloud technologies to reimagine business communications.
SG.GS PTE LTD
We are pleased to welcome SG.GS to our exchange. Established in Asia Pacific, but expanding globally, they are building a global network across major and emerging markets, interconnected with multiple subsea routes worldwide. They offer a suite of services including cloud connect, and of course, peering.
ZONE TECHNOLOGY
Offering managed IT services for business, Zone Technology deliver high quality IT services to businesses in Perth and Australia. Their team are veterans of the IT industry, with decades of experience providing enterprise grade IT services to businesses of all sizes. We’re delighted to have them join us!
INFINITE NETWORKS
A warm welcome to Infinite Networks! Joining the ACT-IX, Infinite Networks is an Australian owned and operated Managed Network Provider that also offers Cloud Hosting and Development Services working with enterprises and ASX listed businesses since 2003.
If you’ve noticed something missing from your inbox, it won’t surprise you that we have shifted our newsletter to quarterly rather than monthly in the interest of providing more focused and timely content when it arises, and a better update on all things IAA. It’s been a full and fun quarter, too! I’m quite chuffed that we certified as a ‘Great Place to Work’, a strong endorsement of the workplace culture we’ve managed to create.
We’ve had events in Adelaide and Melbourne, with both nicely attended and covering great topics. The Melbourne session on NTP is being repeated online due to popular demand! It was truly fascinating to look into the issues with NTP and see measurements taken over a twenty-year period. We’re planning some more events in conjunction with APNIC, so stay tuned.
The tech team have also been ripping things apart and rebuilding a few things, with new switches installed (Brisbane and Melbourne) and some rearrangement work in VIC-IX after the data centre space was reassigned. We’ve also taken a broom to all the bodgy paths in our OSPF configuration so now we have a nice clean area zero in all the right places. Thank you to Aaron and Matt who had a few sleep deprived nights on all that effort!
In general on the IX front, we’ve been cracking the terabit mark on a fairly regular basis now. This means our traffic values are trending up nicely and we’re serving over a solid petabyte worth of content every day too! We also welcomed Hurricane Electric onto QLD-IX which caused an influx of new routes into Queensland.
There’s been a lot happening over in SA-IX too! We’ve completed some upgrades, creating more capacity between the sites and a new content switch on the way. In line with these upgrades, we’ve made the tough decision to commence charging from Q2 FY23-24 at 50% off and at full price in the following year (from Q2 FY24-25). After 10 years operation without charge, this brings the exchange into line with the other well-established exchanges and means we can continue to invest in it into the future.
We received over 50 applications for the IAA Systers program this round, and I must say I was really impressed with the calibre of the candidates. Hopefully the ones we take to the Systers’ workshop will all submit talks for AUSNOG as their work sounds really interesting and worth hearing about! A big thank you to all of you who applied or supported candidates to apply. Together, we’re making a genuine difference!
On the regulatory front, we’ve been asked to participate in a regulation ‘sprint’ between government and industry reviewing all the overlaps due to changes in security legislation imposed on the telco sector. Some of this may even affect your licencing conditions and there has even been talk of licencing internet providers generally. Rest assured we will oppose the latter right into the ditches. While we do expect further consultation on this, the sudden call to review complex matters in a ridiculously short time frame has most of us rather annoyed, to say the least… As ever – let us know your views.
Happy peering!
Narelle
Since our last newsletter we’ve had a few more Members come on board. We’d like to say a special hello to you all!
We welcome Corporate Members:
Space Exploration Technologies Corp
Starlink is a satellite internet constellation, operated by SpaceX, providing satellite internet access coverage to over 50 countries to provide a commercial internet service. In January 2020, the Starlink constellation became the largest satellite constellation ever launched, and as of December 2022 comprises over 3,300 small satellites in orbit. SpaceX Starlink is opening a new POP in Perth connected to WA-IX.
IPSTAR has been providing rural and regional Australians with connectivity at home and on the farm for nearly 20 years. They are an ISP with partnership with large semi-government entities, currently expanding their network. They recently joined IAA as part of their expansion.
INMARSAT AUSTRALIA PTY LIMITED
Inmarsat is a mobile satellite operating company whose customers need access to the Internet through their ground station network. They see IAA’s NSW-IX as an important way of improving their internet connectivity in Australia and elsewhere and believe this will greatly enhance the scope and number of internet providers they have access to.
We also welcome Professional Members:
Michelle Williams
Michael Maenuú
Josh Finlay
Gordon Morton
The past couple months has been very busy for the policy team, and we continue to see various legislative and regulatory reforms in the telco sector.
Please get in touch to share any thoughts on any open and previous submissions; we always appreciate your feedback.
CDR Paused For Telcos
Treasury has confirmed that the expansion of the Consumer Data Right (CDR) Scheme has been paused for the telecommunications sector. Following the release of the 2023-24 Budget, it was revealed that $88.8 million will be invested over 2 years to support the CDR in banking, energy and non-band lending sectors and deliver a cyber security uplift. As had been speculated, it was further announced in the CDR Framework Design and Strategy, that a strategic assessment is planned for the end of 2024. This is to inform future expansions of implementation of action initiatives, including in the other sectors. This strategic assessment will require the consideration of new criteria, and consultation process.
The telco industry has long been pushing back on the expansion of the CDR into the sector. With plenty of information already provided to customers in an accessible format, in accordance with the Telecommunications Consumer Protections Code, as well as switching between telco providers being a feature within the industry, representatives have disputed the need for the CDR Scheme.
This pause is welcome news. We look forward to continuing consultations with government, should discussions surrounding the implementation of the CDR for the telco sector arise again. You can read our previous responses to consultations related to the CDR for further details.
Completed Submissions
Copyright Enforcement Review | Attorney General Department
The Attorney General Department consulted on its Issue Paper regarding the review of Australia’s copyright enforcement regime. In our response, we pointed out the dangers of relying on website blocking schemes due to their inherent impact on the openness of the Internet, and the likelihood of motivated actors to go around these blocks. We also recommended finding other mechanisms outside of the court system to enforce copyright protection, and to focus on reducing infringement of copyright laws as opposed to enforcement after the fact.
Internet Carriage Services Online Safety Code | Industry Associations
Following the eSafety Commissioner’s response to the first round of the industry Online Safety Codes, the industry associations released round two of the Codes. We submitted specifically to Code 7 for Internet Carriage Services. Our response focused on the need to ensure compliance measures balance the protection of individuals with the need to minimise unnecessary burdens on ISPs.
ACMA Compliance Priorities 2023-24 | ACMA
We responded to the ACMA Compliance Priorities for 2023-24 and emphasised that rather than focusing on enforcement measures, the ACMA should prioritise encouraging compliance. We suggested this could be achieved via industry and community engagement, education and awareness and lowering the burden of regulatory compliance for industry.
Privacy Act Review Report | Attorney General Department
The Attorney General Department released its Privacy Act Review Report, which proposed various significant reforms to the Privacy Act. Should the Privacy Act be amended as per the proposals contained in the Report, these changes could prove to have substantial impacts, such as the removal of the small business exemption that currently exists. Our response reiterated positions we have expressed in previous submission regarding privacy legislation. In particular, we emphasised the need to focus on ensuring best practice data and personal information handling practices through collaborative means, as opposed to the expansion of the APPs that does not necessarily ensure compliance with the complex regulation.
2023-2030 Australian Cyber Security Strategy | Department of Home Affairs
The Department of Home Affairs and the Strategy Expert Advisory Board sought feedback on the 2023-30 Australian Cyber Security Strategy Discussion Paper. Our response primarily focused on the need for greater genuine engagement and collaboration, to ensure a truly effective approach to cyber security. In the context of increasing regulatory requirements for the telco sector in relation to data security, critical infrastructure and privacy, we emphasised the need to harmonise and simplify the current policy landscape for an effective and efficient strategy that combats the threats and risks to Australia’s cyber security.
Final Access Determination (SBAS) | ACCC
The ACCC released its Exposure Draft to the Superfast Broadband Access Service Final Access Determination. This draft instrument was based on the ACCC’s decision released in October 2022, with limited incorporation of stakeholder feedback to the consultation held during December 2022. Our response reiterated our positions stated in our response during the December consultation, including the extension of the Determination to cover all residential TC-4 speed tiers at NBN Co pricing, and regarding NNI and state based aggregation charges. We also recommended the Determination to expressly set out prohibition to on-charge RBS.
Open Submissions
Draft Decision: Variation to the NBN Co Special Access Undertaking (Nov 2022) | ACCC | 30 May 2023
The ACCC has released its draft decision to reject the proposed NBN Co SAU Variation. It is seeking views on its draft decision, and whether providers would accept a NBN Co SAU variation proposal based on NBN Co’s letter in response to the issues raised by the ACCC.
Although rejecting the SAU overall, amongst other things, the ACCC has indicated it is willing to accept the price increase for the 50/20 Mbps speed tier. Review the ACC’s draft decision.
Telecommunications Consumer Protections Code| Communications Alliance | 6 June 2023
Communications Alliance has commenced its review of the TCP Code, with the review to take place over 3 stages. The first stage, with the deadline for responses to its Discussion Paper closing in early June, is intended to be a pre-code drafting stage to gather information in order to set the foundations for the rest of the review.
Planning for IAASysters 2023 is well underway! We’re excited by the program we have in store. This year’s theme ‘Future Heroes of the Internet’ has been chosen to celebrate all the super women we have in our industry. We’re also proud to announce that this year’s conference will be held at Sea World Resort on the Gold Coast. If you’ve not heard of our Systers program before or just want to know more be sure to check our short video.
The successful participants were selected from a record number of strong applications. The sponsored attendees will enjoy:
- Ticket to attend the IAASysters Workshop (6 September 2023)
- Ticket to the AusNOG Conference (7-8 September 2023)
- Economy airfares to Gold Coast and accommodation
- One-year complimentary Professional Membership to IAA (subject to board approval)
We could not host such an amazing three-day program without the generous support of our sponsors. We like to thank this year’s Sponsors including:
If you would like to support the next generation of women in the Internet industry, it’s not too late to be a part of the Systers program. Head over to the Systers page on our website to find out how to sponsor!
