Submission to the TIO Independent Five-Year Review
Communications Alliance has made a submission to the independent five-year review of the Telecommunication Industry Ombudsman (TIO).
The submission provided feedback on all six key benchmarks of ombudsman performance, with particularly detailed observations and suggested improvements in two areas: complaint classification and process handling errors, and approach to systemic investigations.
To address the high number of complaints accepted without proper regard to due process, Communications Alliance suggested that the TIO introduce a requirement for complainants to provide a complaint reference to the TIO on first contact – to demonstrate that the consumer had attempted to resolve the issue directly with the provider before contacting the TIO. We acknowledged the importance of ensuring that such a requirement would not serve as a barrier to consumers contacting the TIO, suggested this could be easily avoided through simple options to indicated attempted contact, and noted that the Australian Government’s own Ombudsman, the Commonwealth Ombudsman, requires complaint reference numbers.
On the issue of systemic investigations, Communications Alliance acknowledged that systemic investigations can lead to improved industry practice and lasting, beneficial change. However, we raised concerns that the burden of information requests over the last few years has increased substantially, with more requests, for ever-more complicated and detailed information, including on issues which had already been resolved, or which covered areas already the subject of information requests from the ACMA. The result, in our view, is that the regulatory burden of responding to systemic requests now outweighs the benefits gained. We put forward proposals for how this might be addressed, including suggesting that the TIO limit the number of systemics in a given year.
Submission to the Statutory Review of the Consumer Data Right
Communications Alliance has made a submission in response to the Statutory Review of the Consumer Data Right undertaken by Ms Elizabeth Kelly PSM.
The submission reiterates our support for the objectives of the CDR, outlines our previous engagement with the process and responds to the specific questions raised in the Issues Paper that accompanies the Statutory Review.
We also put forward our view that the case for CDR in telecommunications has not yet been adequately made and that the Review should recommend to Government that the designation/rule-making process for the telecommunications sector be paused, to enable:
- further examination and stringent modelling of whether it would deliver a net-benefit;
- a better understanding of what CDR is – or is not – delivering in the first two designated sectors; and
- the exploration of alternative, lower-impact initiatives that might deliver projected benefits more effectively and efficiently.
Below is a list of currently open telecommunications-related consultations being conducted by Government and other organisations that provide an opportunity for you to have your say.
Communications Alliance members interested in contributing to an industry submission (if one is being developed in response to a specific consultation) should contact us.