::Welcome to May's edition of Communicate
:: 2008 ACOMMS: Communications Alliance and Comms Day Awards
:: New Members
:: Filling the Vision Void By Anne Hurley, CEO, Communications Alliance
:: Consumer Confidence in Networks a Must
By Josh Faulks, Manager, Policy and Government Relations, Communications Alliance
:: Online Reports
By Margaret Fleming, Program Manager, Communications Alliance
:: Review of the Accessibility Information Code
By Mike Johns, Project Manager, Communications Alliance
:: What is different about VDSL2?
By James Duck, Project Manager, Communications Alliance
:: The Draft Voluntary Information Security Breach Notification Guide
By Buchanan Law
:: Calendar
:: About Communications Alliance
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Communications Alliance is pleased to welcome the following new members:
Dialect Interactive
www.dialectinteractive.com.au
Dialect Interactive is a provider of mobile and interactive voice response (IVR) solutions in Australia.
Dialogue Communications
www.dialogue.net
Dialogue is a provider of interactive services for mobile messaging and mobile billing. Dialogue specialise in the development and operation of value added mobile solutions for an international market.
Jamba GMbH
www.jamster.com
Jamster is a provider of digital entertainment. Jamster offers mobile products and services directly via mobile phones.
Mobile Messenger
www.mobilemessenger.com
Mobile Messenger facilitates all aspects of mobile phone entertainment. From concept, creative, delivery, technology, billing, customer service and analysis.
MobileActive Limited
www.mobileactive.com
MobileActive Limited is a mobile phone content and entertainment provider. MobileActive aggregates, develops and distributes a range of mobile content and entertainment including music, games, video, information services, graphics and applications.
Siemens Home & Office Technologies
www.siemens.com
Siemens Home and Office focuses on the design, development, manufacturing and distribution of a range of products which includes classic cordless and fixed-network phones, Voice over IP devices, routers, gateways and software solutions. The portfolio also includes WIMAX devices as well as home media products such as set-top boxes.
Sybase 365
www.sybase.com/365
Sybase 365 provides mobile messaging services – including mobile messaging interoperability, mobile content delivery and mobile commerce services for operators, brands and content providers, enterprises and financial institutions.
Vocus Communications
www.vocus.com.au
Vocus was formed to address the growing requirement in the wholesale telecommunications industry for an independent service provider capable of providing complicated wholesale data and voice solutions without competing with their client base.
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Buried within a recent column in The Australian by telecoms commentator Michael Sainsbury was an assertion that our industry is “inward-looking”.
He said the industry “has never let the community, especially the business community, understand the value-add it brings, and that better broadband will bring”.
In that same column he bemoaned the lack of a “vision statement for the sector”, something which he believed was a government responsibility.
My view is that we as an industry, in cooperation with government, have a crucial role to play in addressing both of those issues.
In my experience, “vision statements” never gain traction unless they are developed in consultation with all stakeholders. Certainly government – in the broadest sense – has a major role in providing input but it would be a one dimensional exercise without involvement of the industry and its customers.
Just a few days after the column appeared there was a significant development on the government side when the Online and Communications Council – representing commonwealth, state, territory and local governments - agreed to create a national framework advancing the development and use of broadband.
“This meeting laid the foundation to a more forward-looking and progressive approach to broadband policy in Australia,” explained the Minister for Broadband, Communications and the Digital Economy, Senator Stephen Conroy. “For the first time, all three levels of government have agreed to work together to develop a unified vision of broadband in Australia.”
In order to build on that progress, the next step could be a workshop at which the other stakeholders would be given the opportunity to provide their input. This would be a sort of mini-2020 Summit or “Communications Vision Day” with representatives from all parties who have a stake in the future of Australian communications.
As well as the Ministers and bureaucrats who administer and regulate the industry at all levels, government representatives would also come from departments and agencies such as health, education, social services, defence etc which depend on communications services.
The customer input would be another vital ingredient, with consumer and business representatives drawn from the widest possible spectrum of users.
Similarly, in recognition of the convergence reality, industry representation should extend beyond the telecoms sector to embrace the media and IT players who are increasingly becoming part of the mix when broadband-enabled services are delivered to Australian customers.
By filling this vision void, we would simultaneously address the other concern raised in The Australian – the lack of community education about the true value we bring to business and consumers.
That value was highlighted in a recent report commissioned by the Australian Communications and Media Authority. The report concluded that skills and confidence in using new communications and media services are increasingly important for participation in all aspects of Australian society.
Our challenge as an industry is to educate the community about the breadth and depth of products, services and applications that are becoming available in a broadband world and how they will assist Australian business and consumers to reach their potential.
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As the telecommunications industry manoeuvres towards the tender and the roll-out of the National Broadband Network, it is important to maintain perspective and focus on what we are trying to achieve. Proponents and governments need to continue to look beyond debates about infrastructure to what business and consumers will get out of the network well into the future. To be a commercial success, consumers will need to have confidence in the integrity of the network. Fundamentally, consumers must be convinced that adequate security and privacy protections exist.
Business and governments have always grappled with how to provide security and privacy protections in a fast changing digital world. Australia still has some way to go to realising its full potential when it comes to exploitation of the digital economy. The economic benefits of pervasive digital integration can be seen around the world. Achieving a fully-fledged digital economy requires confidence in the networks.
Considerable work has already been done in consumer security areas such as e-security and cyber security. The Federal Government with the help of industry has also put in place extensive protection and planning regimes to protect critical information infrastructure. Most of these initiatives will continue to be relevant in a broadband enabled environment. However, targeted measures will still need to be developed.
The importance of consumer confidence in the protection of their personal information cannot be understated. The telecommunications industry handles large amounts of detailed personal information belonging to their customers, including financial and personal communication information. As a result, we have operated under extensive regulation relating to the privacy and security of customer information. Our members have played an important leadership role in developing some of the earliest and most comprehensive privacy compliance programs in Australia.
The ALRC delivered its final report on the Review of Australian Privacy Law to the Attorney-General last week - it will be made publicly available when it is tabled in the Australian Parliament. Any further discussion about privacy protections in the context of the roll out of the National Broadband Network should be informed by that Report. If amendments are proposed, it is essential that the telecommunications industry is included in the process through extensive consultation.
To become a fully-fledged digital economy, end users must have faith in their ICT networks. The telecommunications industry has proved its commitment to ensuring adequate security and privacy protections for consumers. With the roll out of the National Broadband Network, this work needs to continue with industry and governments working closely together.
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| :: Online Reports
By Margaret Fleming, Program Manager, Communications Alliance
Two online reports containing valuable information are available from the Communications Alliance website.
The Communications Alliance Works Program details current projects and their status, advisory groups, compliance program and document reviews due in 2008. Two newly added sections include details of current Submissions and Research Projects.
The following two submissions are currently being prepared:
- ACMA - Calling the Emergency Call Service—Review of Arrangements
- Australian Government - National Broadband Network - Request for submissions on regulatory issues
Members may provide input to submissions via the members’ only area on the Communications Alliance website - www.commsalliance.com.au/members_area. This area is only available to Communications Alliance members via login.
Three Research Projects are currently underway or being scoped, specifically:
- Climate change – development of an issues paper to inform possible industry approach to climate change
- Customer Service - The changing communications service delivery paradigm
- Disability - Accessibility requirements for customer equipment - International review
The second report, the Publication Report, contains details of all publications, including publication dates, ACMA regulatory status and review recommendations. All currently published Codes, Standards, Specifications and Guidelines and dates of previous publications are detailed.
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Equipment suppliers have an obligation to provide information to carriage service providers (CSPs) about the accessible features of their equipment that use a telephone handset, and that is either manufactured in or imported into Australia and is for use with a standard telephone service (STS). These obligations apply to fixed, cordless, mobile and satellite phones. Equipment suppliers also have obligations to respond to all reasonable requests from consumers seeking further information about features on these products.
The obligations are specified in the Information on Accessibility Features for Telephone Equipment Industry Code (ACIF C625:2005). The type of information to be provided is specified in the Operational Matrices for Reporting on Accessibility Features for Telephone Equipment Industry Guideline (ACIF G627:2005). The Code was registered by ACMA twelve months ago and now Communications Alliance is seeking comments on both of these publications as a part of a scheduled review under its normal document review processes. The outcomes of a Communications Alliance review are to revise, reconfirm or withdraw the document(s) under review.
The review will focus on the Code obligations and what the Code and Guideline deliver, rather than compliance with the Code, noting that the Code operates within the current legislative framework. Aspects being considered as a part of the review include:
- any existing issues, including gaps, with the Code or Guideline
- whether any process improvement is required, from operational experience in dealing with the Code or Guideline
- improvement of the clarity of the obligations
- whether the Code and Guideline are satisfactorily meeting the needs of industry
- impact of market, technology or legislative changes
Comments submitted for consideration in the review can be sent to Mike Johns, Project Manager, CECRP at m.johns@commsalliance.com.au by 13 June 2008. The Code and Guideline are freely available for download from www.commsalliance.com.au/documents . The Providing information on the accessibility features of telephone equipment factsheet is available and provides assistance in understanding the application of the Code and Guideline and can be downloaded from www.commsalliance.com.au/about_us/factsheets.
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Last month I reported on the publication by Communications Alliance of a new Australian Standard that includes requirements for VDSL2, the latest generation of broadband technology. VDSL2 is particularly important as a potential technology for broadband services in a network operating with a Fibre To The Node (FTTN) architecture.
VDSL2 has the capability to offer higher data rates than technology in popular use today e.g. theoretically up to 100Mbps for VDSL2, versus up to 24Mbps on ADSL2+. The catch with all of these technologies is that maximum performance falls off fairly quickly as one moves away from the exchange or node. As well, the benefits of higher data rates can become a bit marginal once one is located beyond about 1 to 1.5 km from an exchange or node. Hence the usefulness of VDSL2 is arguably greater in a FTTN network than in a traditional exchange based network because of the shorter line lengths in a FTTN network.
So how does VDSL2 achieve these higher data rates? The short answer is by using even higher frequency bands than ADSL2+. The upper limit for ADSL2+ transmissions is around 2.2MHz. VDSL2 extends the usable frequency up to 17.7MHz.
However the higher the frequency, the less distance (or ‘reach’) the signal can travel due to attenuation (or ‘loss’) along the line. For VDSL2 this requires a different approach to the allocation of upstream and downstream bands. Instead of the one upstream and one downstream band found in ADSL2+, there are three upstream and three downstream bands defined for VDSL2. This helps maintain data rates in both directions for further distances from the exchange. However the introduction of more boundaries between frequency bands (i.e. between up and down bands) means there is more complexity in managing interference.
The management of potential interference between broadband services is at the core of activity in Communications Alliance on VDSL2 technology. Work here has been focused on achieving the best overall outcome for all end users. This will place the telecommunications industry in a good position for a move of Australia’s fixed broadband services to a node based network, which will widen the appeal of VDSL2 in years to come.
For reference, the customer equipment standard that incorporates VDSL2 technology is available from www.commsalliance.com.au/documents/standards/S43.2_08.
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The Office of the Privacy Commissioner (OPC) recently released the Draft Voluntary Information Security Breach Notification Guide (the Guide).
The Guide has been produced to assist private and government organisations in preventing and responding to information security breaches (ISBs). The Guide states that an ISB occurs when personal information is exposed to unauthorised access, use, disclosure or modification as a result of a breach of an agency’s or organisation’s information security.
The OPC proposes that compliance with the Guide be voluntary, although there is speculation that the Australian Law Reform Commission, consistent with its recommendations in its Review of Australian Privacy Law (Discussion Paper 72) will request that the Attorney-General introduce mandatory compliance. The Guide, if introduced, will potentially impact upon the privacy practices of all Australian Telcos.
Responding to a breach
Compliance with the Guide does not mean that an organisation must notify individuals of all ISBs. Rather the Guide recommends that an organisation conduct a risk assessment to determine if the breach poses a real risk of serious harm to the affected individuals and, if such risks are present, the Guide recommends notifying the individual(s).
This process is divided out into four steps:
1. Contain the breach and do a preliminary assessment
2. Evaluate the risks associated with the breach
3. Consider notification
4. Prevent future breaches
The Guide recognises that in practice the line between these four steps is often blurred but offers guidance on what the OPC regards as “good privacy practice”.
The question of whether an ISB is likely to give rise to a risk of harm to the relevant individual is to be decided by the organisation who is responsible (directly or indirectly) for the ISB, not the individual to whom the information relates. This is likely to cause some controversy amongst privacy advocacy groups.
The OPC has correctly labelled this document a “guide”. From a technical perspective it does not set out any specific signposts and acknowledges that “the main challenge is to determine what circumstances justify notification”. It does however draw attention to factors to be considered by organisations in deciding whether to notify an individual of a breach, including the sensitivity of the relevant information, the nature and context of the personal information, the potential use (or misuse) of that information, the source of the breach and the steps already taken by the organisation to mitigate damage.
Although some organisations are likely to find the Guide to be inconclusive at times, there is value to this document. Any organisation that deals with personal information in any shape or form will find this Guide useful in consolidating its privacy practices and in deciphering certain obligations under the Privacy Act.
OPC Consultation
The OPC is seeking comments by 16 June 2008 on the Draft Guide. Buchanan Law would be pleased to assist with the drafting of submissions or advising you more generally in relation to privacy obligations.
You can contact Buchanan Law on (02) 6221 9555 or via our website: www.buchananlaw.com.au .
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Events 2008
• The ACOMMS 2008 : Sydney – 6 August 2008
Public Comments closing in July 2008
• Requirements for Installation of Temporary Telecommunications Customer Cabling
for Defence Purposes : DR AS/ACIF S035:2008
Codes registered in May 2008
• Telecommunications Consumer Protection Code : C628:2007
Codes withdrawn from registration in May 2008
• Customer Information on Prices, Terms and Conditions : ACIF C521:2004
• Credit Management : ACIF C541:2006
• Billing : ACIF C542:2003
• Customer Transfer : ACIF C546:2006
• Complaint Handling : ACIF C547:2004
• Consumer Contracts : ACIF C620:2005
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Communications Alliance was formed to provide a unified voice for the Australian communications industry and to lead it into the next generation of converging networks, technologies and services.
Communications Alliance offers a forum for the industry to make coherent and constructive contributions to policy development and debate.
By providing leadership on new trends and directions, Communications Alliance fulfils a vital unifying role on behalf of the industry and its members, particularly in areas of competition, innovation and industry development.
The prime mission of Communications Alliance is to promote the growth of the Australian communications industry and the protection of consumer interests by fostering the highest standards of business ethics and behaviour through industry self-governance.
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