Issue No 4: 15 February 2022



Hot Topics
  • ACOMMS 2021:  Photos here Highlights Video here

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Record-Low Telco Complaint Numbers in Latest Complaints-in-Context Report

Telcos have achieved the lowest-ever recorded complaint rates in the latest Complaints-in-Context report, released today by Communications Alliance.

The report, covering activity during the October-December quarter, 2021, showed that across all participating service providers, there were 4.1 complaints to the industry ombudsman for every 10,000 services in operation (SIOs).

The report details the complaints received by the Telecommunications Industry Ombudsman (TIO) per 10,000 SIOs, creating an index that allows comparison of the customer service and complaint handing performance of providers, regardless of their size.

Comms Alliance CEO, John Stanton noted that because report participants change slightly each year, the results are not directly comparable.

“This is the strongest result achieved since the index was launched in 2014 and has been achieved against the backdrop of the continuing disruption caused by the COVID-19 pandemic.

“The continuing decrease in complaint rates for most participants reflects the successful efforts by all of industry to improve customer service. This aligns with the 39.7% drop in all complaints received by the TIO for this quarter (compared to the same quarter in 2020), reported last week.”

Stanton added, “The Complaints in Context results show that only one in every 2,439 of the services in operation among participating providers generated a complaint during the period.”

The industry-driven report is published by Communications Alliance, using complaints data provided by the TIO and SIO data supplied by participating providers. Per the Telecommunications Consumer Protections (TCP) Code, the participants were updated this quarter to reflect the top 10 complaint recipients in the most recent TIO Annual Report, in addition to voluntary participants.

Communications Alliance encourages any RSP interested in joining the index to contact them.

Industry Warns of Potential Problems in Electronic Surveillance Reforms

Communications Alliance has joined a broad coalition of digital rights groups and communications industry associations to alert Government to shortcomings in proposals to reform and rationalise Australia’s electronic surveillance framework

In a letter to Federal Minister for Home Affairs, the Hon. Karen Andrews, the coalition welcomed the intent of the reform initiative, but drew attention to a range of problematic elements in the Government’s proposals.

The critique was signed by Digital Rights Watch, Electronic Frontiers Australia, the Internet Association of Australia, Internet Australia, the Australian Information Industry Association and the Internet of Things Alliance Australia.

The group warned that the government’s proposals appear likely to fail in protecting individuals’ data and providing a “clear and transparent” piece of legislation that can facilitate industry compliance.

It argued that the proposed framework is weighed in favour “of extending powers for law enforcement agencies and ASIO to investigate crimes and threats to security while expanding the burden on industry by imposing or increasing the application of regulatory requirements.”

It pointed to potential difficulties if the scope of data subject to the surveillance framework was extended to include IoT data and/or metadata, along with the risk of overreach in government powers and the lack of adequate oversight of security agency surveillance activities.

Communications Alliance is preparing a formal submission in response to the Government consultation and will stay closely engaged in the reform process.

Industry Studying Regional Telecommunications Review Findings

Communications Alliance has welcomed the release of the 2021 Regional Telecommunications Review final report and congratulated the independent review committee, chaired by Luke Hartsuyker, on a substantial body of work.

The review has made 12 broad-ranging recommendations for action to address issues pertaining to regional connectivity, communications consumer and network resilience issues, among others.

Communications Alliance CEO, John Stanton, said CA and its members were digesting the details of the report and its findings and recommendations, and would offer feedback to the Committee and to Government.

He pointed out that some of the recommendations – such as a call for better coordination between communications service providers, energy providers and emergency service organisations – covered issues on which industry had taken proactive initiatives during 2021.

Communications Alliance is Seeking Comments for a Scheduled Review of the Following Code:


The Code provides standard procedures for the cooperative handling (including call tracing) by carriers, carriage service providers and the national relay service provider of communications across networks that are life threatening or connected with a pattern of unwelcome communications. The Code also outlines when carriers, carriage service providers and the national relay service provider can deal with unwelcome call complaints relating to non real-time communications such as SMS, MMS and email.

The aims of the review are to identify:

  • any existing issues with the Code;
  • whether any process improvement is required, from operational experience in dealing with the Code;
  • any gaps in the Code;
  • any clarifications that may improve requirements;
  • whether the document is meeting the needs of industry and the community satisfactorily;
  • any expected impacts of technology changes; and
  • whether a need exists to amend, reconfirm or withdraw the Code.
The Code can be downloaded from here.

Further information can be found on the Documents under review webpage. All submissions are due by 5 p.m. on Friday 11th March 2022. Submissions received will be made publicly available on the Communications Alliance website unless the submitter requests otherwise.

You can use the Submit Comments form to submit your comments via email or go to the Contact Us webpage to obtain other contact methods such as by post or fax.

CA Submission to OAIC

Communications Alliance has provided input to the Office of the Australian Information Commissioner (OAIC)’s review of the Privacy (Credit Reporting) Code 2014 (the CR Code).

In the submission we support proposals to improve the CR Code’s readability and accessibility, suggesting that many of the identified issues could be addressed through targeted stakeholder education, including through the production of guidance material. This would be particularly helpful providing clarity about the CR Code’s interaction with the Privacy Act, and helping stakeholders understand key terms and concepts, helping all parties better understand their rights and obligations.

The submission also supported moves to better product victims of fraud, offering suggestions on possible improvements to the current regime.

New Members

Communications Alliance is pleased to welcome the following new members;




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Current Consultations

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.

ConsultationOrganisationClosing Date
Update to Foreign Space Objects DeterminationACMA10/03/2022
Broadband Speeds Claim Industry Guidance (Guidance)ACCC
Implementation of Parliamentary Committee and Auditor-General Recommendations - Department of Home AffairsDoHA27/02/2022
Review of fibre-ready facilities exemptions under Part 20A of the Telecommunications Act 1997    
Proposed licensing arrangements for 2 GHz narrowband mobile-satellite services and 28 GHz fixed-satellite servicesACMA
14/02/2022 + 28/02/2022
Replanning the 2 GHz band: Review of the 2 GHz Television Outside Broadcast Frequency Band PlanACMA
14/02/2022 + 28/02/2022

We welcome your feedback on our newsletter.

Contact Tel: (61) 2 9959 9111