IAA Newsletters
National Data Security Action Plan | Department of Home Affairs | 10 June 2022
The Department of Home Affairs is calling for submissions for the development of the National Data Security Action Plan. They seek to explore with industry and state and territory governments how Government and industry can meet data security expectations, how responsibilities can be best assigned to keep Australians’ data safe, and how Government, businesses and individuals can share responsibility for data security in the future to get the best outcome for everyone.
NBN Co. SAU Variation | ACCC | 8 July 2022
The ACCC is seeking submissions to its report on NBN Co.’s SAU Variation. The proposed variation from NBN Co includes product and pricing commitments, changing the framework for NBN Co’s cost recovery, and incorporating fibre-to-the-node and other copper-based technologies to create a single regulatory framework for all technologies.
Read More
Given the recent federal election, IAA’s policy team has largely worked on publications related to the election in May. We published our 2022 IAA Election Wish List, outlining the policies we would like to see adopted by the political parties. We also released our 2022 Election – Policy Assessment evaluating the policy platform of the major political parties in comparison to our Election Wish List.
Unrelated to the election, we also released a Customer Identity Authentication whitepaper to provide information and guidance on the new ACMA rules and steps that members will need to implement in order to ensure compliance with the new rules by 30 June 2022. We hope you find this guide useful.
5 Year Independent Review | Telecommunications Industry Ombudsman
In our submission to the Independent Review, we raised the concerns of industry, particularly relating to the inherent issues in the TIO’s complaints handling structure and costs model. We noted that this inherently affects the ability of the TIO to meet industry benchmarks.
Statutory Review | Department of Treasury
We primarily focused on the need to ensure that the costs to industry are being properly considered and that there is a commitment to ensuring rules will realise actual benefits for consumers.
Industry Guidance on the Carrier Separation Rules | ACCC
In our response, we raised attention to obligations not specified directly in the rules but contained in the written notice to avoid any confusion.
Read More
Well, wasn’t that a fun-filled month! The longest election campaign in recent history is over at last, and we have a new government. We can say goodbye to unwanted vile political text messages, nasty social media memes and pork barrelling, and we’ll move to a new regimen of well-articulated policy discourse by a polite and caring political class motivated by the nation’s best interest, not simply the retention of power. [Yes, I know it’s a dream, but I live in hope.] Seriously, we congratulate the new Prime Minister, Anthony Albanese and look forward to deepening our relationship with Michelle Rowland as the expected Communications Minister. We also wish Paul Fletcher and his team well and thank them for their service.
You may have noticed we issued an election wish list and rated the political parties’ policy platforms in the lead up to the election. One thing we asked for was that the new government restore trust in our political processes. While an integrity commission is a key component of a trustworthy system, our issue is with the government’s approach to engagement with industry: we’ve had too many tokenistic consultations and rushed legislation rather than constructive engagement towards effective, efficient regulation. We’ll keep on asking.
Last month I also managed to attend NZNOG in Wellington and caught up with our NZIX colleagues and many of the NZ based ISPs. If you get a chance, have a look over the many useful presentations, such as the OpenLI, security and 800G sessions. They also had a number of sessions given by government which had me feel I was in some parallel universe with genuine, constructive government-industry relations. Sweet as!
Looking forward, we’re doing some heavy analysis to properly scope out our program of upgrades and expansion. In the wake of our cracking the 900Gbps level, our member survey on sites, and looming equipment shortages, we will need to do some rearrangement, and it may well mean the closure of one or two POPs where there are no members present anymore. In this way, we can ensure we have the capacity you want in the places you want, as well as ensure efficient cache fill and plenty of head room for intra-IX traffic. So here’s the challenge: how about for the 25th anniversary of WA-IX next month we break the TERRABIT barrier? Come on, you know you can do it!
Read More
Privacy Awareness Week (PAW) is an annual event to promote and raise awareness of the importance of protecting personal information led by the Office of the Australian Information Commissioner (OAIC) in partnership with state and territory privacy regulators and Asia Pacific Privacy Authorities. This year, the event is highlighting privacy as the foundation of trust and will focus on simple foundations we can put in place to protect our personal information.
We will be promoting the material through our social media accounts and will provide tips for individuals to build a solid foundation of privacy and set a challenge for you to see how well your privacy practices stack up. For more information on PAW2022, please visit their website for more detail https://education.oaic.gov.au/paw2022/
Read More
Completed Submissions
Telecommunications Sector Security Instruments | Department of Infrastructure, Transport, Regional Development and Communications | 29 March 2022
The DITRIC has drafted new conditions and rules for carriers and CSPs to apply equivalent security measures for the telecommunications sector to those under the Security Legislation Amendment (Critical Infrastructure) Act 2021 which is currently in place for other sectors. Our response predominantly commented on the breadth of scope which would impose unnecessary burdens and substantial costs on industry, and the lack of clarity provided in the instruments regarding the definition of key terms.
Digital Platform Services Inquiry – September 2022 Report | ACCC | 1 April 2022
This inquiry is part of the ACCC’s five-year Digital Platform Inquiry for its September 2022 Report and follows the release of its fifth interim report. In our response, we focused on the need to ensure appropriate regulation over the digital landscape which fosters competition in the industry as well as improve the protection of consumers.
Consumer Data Right Rules and Standards Paper for the Telecommunications Sector | Department of the Treasury | 5 April 2022
Following the formal designation of the telco sector earlier this year, the federal Treasury has sought input for the development of rules which would apply to the sector. In general, we raised concerns about the disproportionate costs for industry and supported the introduction of a limitation threshold to provide exemptions for smaller organisations.
Open Submissions
NBN Co Special Access Undertaking – Long Term Revenue Constraint Methodology draft determination 2020-21 | 13 May 2022
The ACCC is seeking input to assist their assessment of whether NBN Co has complied with the criteria for their annual LTRCM determination.
Independent Review | Telecommunications Industry Ombudsman | 15 May 2022
Public consultation for the Telecommunications Industry Ombudsman (TIO) is currently underway as part of its independent five-year review. The consultation is seeking feedback from industry in regard to the TIO’s accessibility, fairness, accountability, efficiency, effectiveness and land access (amongst other concerns).
National Data Security Action Plan Discussion Paper | Department of Home Affairs | 10 June 2022
The Department of Home Affairs has released a discussion paper for consultation on the development of the National Data Security Action Plan.
Please get in touch at policy@internet.asn.au to share any concerns or feedback we can incorporate into our submission for these open consultations.
Read More
After much speculation about the date, the election has finally been called and we are now in the longest election campaign for decades. While the media sit watching for gaffes and hunting for the most embarrassing candidate, the rest of us are left wondering whether we will see any real policy scrutiny. If a change in government comes, or if the pressure to appear tough on security lifts after the election, will we see any real change to the heavy hand of ineffective regulation largely enacted for appearance’s sake? Those of you who attended my AusNOG presentation will recall that I am not impressed with the state of our regulatory processes: we need to restore trust in government, and government needs to be worthy of that trust. Rest assured, I am banging on their doors to tell them ways to improve, and will be doing so again next week at the CommsDay Summit. Look out for our Election Wish List, which we will release soon.
Speaking of AusNOG, it was great to catch up with so many of you and to hear of all the great projects conducted by our members and others across the industry. Everyone looked great in the IAA hoodies as well! Our IAA Systers@AusNOG program went down really well, so look out for any future versions and possible sponsorship opportunities.
Sadly, also an AusNOG after event was marred by alleged bad behaviour and we thank the broader industry for your support in calling for change. The Australian Human Rights Commission study from 2018 reported that some 81% of employees in the information, media and telecommunications industry in the preceding five years had experienced sexual harassment at work. Compared with 42% in retail and 40% in mining. We clearly have an entrenched problem worse than other industries, and it’s utterly overdue this changed. We are working through what initiatives IAA can lead and what we want others to do. Either way, if you see harassment of any kind act to stop it, call it out as I did at AusNOG and protect your colleagues. We want this industry to be better so that all participants can enjoy and be productive in their working lives. Adherence to and promotion of codes of conduct are a good start, and stamping out this type of behaviour will go a long way to retaining great people within it.
On the technology front, seeing us crack 800Gbps last month means we really need to get moving on our upgrades! The team are putting some more kit through our rigorous test plan in the hope of identifying the right upgrade path to a 400Gbps core, and even 400Gbps services. If only the supply chains could fulfil orders… we’re still awaiting gear we ordered last year! Rest assured, however, we won’t be out of ports or hit congestion for some time, as we still have good headroom everywhere.
We’re also still working through our expansion options and trying to get a better understanding of what data centres are worth being in into the future. The newer ones are looking very attractive and are great pieces of construction and design. We partner with a number of them to provide services, so as you grow, we can grow into more locations. Don’t be afraid to let me know about your expansion plans or even just to bend my ear about how you’re weathering the industry storms!
Til next month
Narelle
Read More
Dr Karen Lee, Senior Lecturer in the UTS Faculty of Law, is undertaking research into the ways in which service providers engage when codes of practice are drafted; and why industry participants choose to engage or disengage in code development.
Using the development of the Telecommunications Consumer Protections Code (C628: 2019) as a case study, the research seeks to identify the consultation mechanisms used; the difficulties encountered; the barriers to participation that industry participants of all sizes and business types might experience; the effect these mechanisms and barriers have on the code development process, and measures that might be taken to improve industry rule-making activities.
To schedule an interview with Dr Lee or for further information about the project (UTS ETH21-6356), please contact her at karen.lee@uts.edu.au.
Read More
Last month, one of our staff members caught up with Diego Campagna – a founding member of WAIA who owned and operated Global Data Access Pty Ltd from 1994-1997 – one of Perth’s early Internet Service Providers (ISP). The company quickly expanded to Kalgoorlie, Karratha and Port Hedland and eventually merged with Starwon Internet. As an owner of a local ISP, Diego joined WAIA due to the heavy-handed regulation being proposed and subsequently exited the association as he moved away from the Internet industry.
When talking about WA-IX and its contribution to Australia’s Internet, Diego spoke about how the Internet industry has become a lot harder to survive in due to more prominent players and how having an established IXP like WA-IX would have made a difference to his business. He reminisced about his ISP, which suffered significant income losses due to black hole routing by a larger ISP over a bandwidth dispute. Unfortunately, in the mid ’90s, legislation wasn’t reasonably equipped to keep up with some of the technology around, and his business suffered severely.
These days, Diego is the Managing Director of Suburban Integration, a technology company specialising in audiovisual and security integration solutions travelling around WA doing what he is truly passionate about.