Consumer Protection in the Communications Industry: Moving to best practice - Issues Paper (July 2008)

6. Appendix 2 – Case Study on the Code on Information on Accessibility Features for Telephone Equipment

This case study (prepared by Telecommunications and Disability Consumer Representation – TEDICORE[47]) provides an overview of some of the significant consumer concerns that have arisen during the development process for a specific code.

The ACIF Code on Information on Accessibility Features for Telephone Equipment[48] has been in operation since April 2007. The Communications Alliance website states:

The Code requires customer equipment importers and manufacturers to provide information to CSPs on features of their equipment that will meet people’s communications needs. The information provided must be consistent with the features matrices provided in ACIF G627:2005. Equipment suppliers must also have a contact point for consumers to seek further information about the equipment supplier’s equipment features. The Information Accessibility Code summary sheet[49] has been produced to provide an overview of the Code Provisions, the Guideline and the regulatory framework under which the Code was registered.

The Working Committee to develop the Code was set up in April 2004. Public comments were requested on the draft Code in November 2004. The Working Committee struck a number of problems in progressing the work in 2005 due to differences in what consumers and equipment supplier representatives wanted as outcomes for the Code. A meeting between ACIF, ACA and industry stakeholders where a number of issues were discussed helped to lead into a new working form where a sub-committee comprising the three key stakeholder groups developed methodology that was reported to the Working Committee on 28th November 2005.

After considerable negotiation, agreement was reached on the Code – the ACIF Board approved its publication in December 2006 and sent it to ACMA for registration. Unfortunately, industry continued to express its concerns to ACMA about the Code and there were further delays. After discussions with ACMA, ACIF and other key stakeholders, TEDICORE could still not see any result. Finally, TEDICORE resorted to writing to the Minister about its concerns. The ACIF Code (C625:2005) Information on Accessibility Features for Telephone Equipment[50] with the accompanying ACIF G627:2005 Operational Matrices for Reporting on Accessibility Features for Telephone Equipment was registered in October 2006.

The end result was a Code that left out key consumer information such as hearing aid compatibility.

Communications Alliance established an Information Implementation Group comprising industry stakeholders (and no consumer representatives) to decide on mechanisms for the implementation of the Code. Consumers were denied involvement in this group, despite Communications Alliance stating that this group may influence revisions of the Code. Currently, information from each manufacturer is meant to be sent in spreadsheet format (based on the matrices in the Guidelines) to each carriage service provider and in turn each carriage service provider is meant to make the information available to its customers. Even when companies like Nokia have followed the Code requirements by placing information prominently about each phone model on its website, it is time-consuming both for CSP staff and customers to open the link to each of the 39 models listed and go down the list manually to find which of the models have a particular feature.

Even with the current system there has been a lack of compliance by some of the key suppliers and manufacturers of phone equipment. As a result, Communications Alliance wrote a letter in December 2007 reminding them of the requirements under the Code. There still continues to be a significant lack of compliance by these suppliers. This is very frustrating for people with disabilities who need to find phone handsets to meet their needs. In addition, the Code has been registered with ACMA, making the Code a legal requirement, yet there has been no enforcement of the Code to date. After TEDICORE raised its concerns, ACMA has undertaken to contact non-compliant suppliers in the near future.

Sen. Stephen Conroy, Minister of Broadband, Communications and the Digital Economy stated in his speech to the 2008 ATUG Conference that ‘Industry members need to be much more responsive to the interests of consumers, and respectful of the needs and experiences of individual consumers. To ensure that self-regulatory mechanisms continue to adapt to emerging technologies and services, consumers need to be given a strong voice in the development of codes and other protections.’

Therefore, a much more effective way would be for the establishment of an online database where manufacturers can input data on each phone model in a secure manner. This could then be searched based on criteria such as feature or disability to produce a list of handsets meeting the search criteria.

In addition, the Code needs to be considerably expanded in its reporting of features, by informing consumers about features that they really need rather than those that are easy to report.

[47] <http://www.tedicore.org.au/>

[48] Communications Alliance, ACIF G627:2005 Operational Matrices for Reporting on Accessibility Features for Telephone Equipment, 2005, <http://www.commsalliance.com.au/documents/guidelines/g627>.

[49] Communications Alliance, Providing information on the accessibility features of telephone equipment, fact sheet, December 2007, <http://www.commsalliance.com.au/__data/page/13230/ACIF_C625_2005_and_ACIF_G627_2005.pdf>.

[50] Communications Alliance, ACIF C625:2005 Information on Accessibility Features for Telephone Equipment, 2005, <http://www.commsalliance.com.au/__data/page/15367/C625.pdf>.





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