IAA Newsletters
Don’t be fooled by the lower than usual number of consultations going on, there’s still lots happening in the sector when it comes to policy!
Co-regulation for telecommunications continues to come under fire and is very topical as Communications Alliance released its near-complete draft of the Telecommunications Consumer Protections (TCP) Code Review 2024 to the Review Committee on 20 May. The ACCC, and TIO in particular, have critiqued the TCP Code Review iteration, claiming it does not sufficiently protect consumers. We can expect public consultation on the revised TCP Code to open shortly.
The TIO will soon be implementing changes to their reclassification processes, and publishing guidance material surrounding complaints handling processes, including what constitutes a consumer’s “reasonable attempt to contact a telecommunications service provider” before lodging a complaint with the TIO.
The IAA Public Policy Advisory Panel (PPAP) met for its quarterly meeting on 11 June where there was a spirited discussion on the future of co-regulation in the telecommunications industry, and what can be done to defend it. IAA will be calling for nominations for the PPAP later this year, so make sure to keep an eye open.
Our policy team has also been busy attending bilateral meetings with regulators and government over the period, including on matters related the ACMA’s compliance and enforcement approach, the National Office of Cybersecurity, and the federal government’s telecommunications strategy to 2035.
On the Internet Governance front, we are excited to share the news of the launch of the auIGF (previously NetThing) which will be held this year in Melbourne on 28-29 October. IAA has been a long-time supporter and participant of Australia’s Internet governance community, and encourage you to attend.
The Asia Pacific Internet Governance Academy Australia (APIGA Australia) also recently launched. A program to foster the next generation of youth leaders in Australia’s Internet and digital ecosystem, APIGA Australia are providing fellowships to attend its inaugural event held in November 2024. You can read more about APIGA Australia on their website.
Also! Don’t forget your upcoming compliance obligations:
- CommCom TCP Code attestation, due 2 September 2024; and
- Fair Work’s ‘Right to disconnect’ policy will come into place for non-small business employers on 26 August 2024, and small-business employers from 26 August 2025. Eligible employees will have the right to refuse employer or third-party contact outside of working hours. Arnotts Technology Lawyers have prepared some legal documents to assist our Members with their compliance. You can access their ‘Right to disconnect’ Policy template, along with a FAQs document, via the ‘Right to Disconnect – Template Pack’ in the Legal Templates section of the IAA Member Portal.
As always, please get in touch to share any thoughts on any of the open and/or previous submissions as we really appreciate your feedback.
Completed Submissions:
Upcoming Submissions:
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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.
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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.
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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
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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
