Telco regulation 2.0 - Reconnecting the customer
Speech by Chris Chapman
Chairman, Australian Communications and Media Authority
Four Seasons Hotel, Sydney
Tuesday, 20 April 2010
In this landmark speech, Chris Chapman, announced a public inquiry into customer service in the telecommunications industry.
He spoke of how poor customer service is damaging the reputation of the industry. 'The perception of poor service and scant regard for customers may well be an indicator of underlying structural or organisational issues.'
He told the meeting of Australia's telecommunications industry leaders that the ACMA inquiry would adopt its evidence-based approach to '... get to the bottom of this issue.'
The inquiry would focus on how complaints were handled and the links to broader customer service issues.
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This is going to be a relatively long speech by my standards, but from the ACMA's perspective, it's an important one. Today, I will articulate the road map for the ACMA's role in the telecommunications sector over the next several years.
To follow this road map, you will need to accept the end of a framework built around simple voice services because the direction we are taking begins to try to shape telco regulation 2.0 through the framework of a converged and much more complex telecommunications and media landscape.
In the light of that converged landscape, simple consumer relationships are rapidly giving way to more complex interactions. This in turn necessitates a refocus on consumer and citizen vulnerabilities such as privacy, security, safe usage, accessibility, content classification and digital literacy. Telco providers will need to factor in and work with these vulnerabilities much better than in the recent past.
The concept of citizen as a useful framework through which to mediate convergence was at the heart of our structural re-organisation late last year which brought both media and telco investigations together in one division titled Content, Consumer and Citizen.
What that framework becomes is something we will all contribute to, but in the final analysis, if the consumer / citizen/ end user doesn't 'get it'-in both the literal and figurative sense of the phrase-then much of all of our efforts on matters digital will have been for nothing.
That is why our reality is that we must tackle both the problems of today while working on the solutions for tomorrow. And that is why today I will detail our «Reconnecting the Customer» strategy, which will include a formal inquiry into customer service.
As the Minister noted in his speech this morning, a big "today" problem is customer protection-as witnessed by the trend growth in complaints to the Telecommunications Industry Ombudsman (the TIO).
Simply expressed, I think we have reached a tipping point. Now tipping point is a cliché, but let me try this on you.
Is it a watershed when the world's largest retailer of DVD, Wal-Mart buys the leading HD quality web video service?
Is it some sort of paradigm shift when the biggest telco in the US, Verizon, declares that video and not telephony is now the core of its fixed-wire business?
And is it a turning point when data usage exceeds voice usage for Australian mobile carriers?
And what do I say when I open my email-delivered phone bill for my naked DSL service and it has big fat zeros against local and national calls and, most importantly, not a cent for line rental?
And is it a game changer when the popularity of a small, well-designed device-the iPhone- single-handedly takes down a carrier's network performance reputation (I'm talking about AT&T), and the same App store makes silly the walled garden content models of mobile carriers around the world?
Having conjectured about the coming converging world and all its complexity and challenges, is it time to acknowledge its arrival and begin the urgent task of making it actually work in Australia's public interest?
My own inflexion point for convergence was something more prosaic: our experience with premium SMS services. As many of you know, the myriad of consumer complaints and problems that has bedevilled these services is something none of us can be proud of.
Consumers found themselves overwhelmed, disempowered by a complex array of providers, aggregators and carriers, an immature-to put it kindly-billing and payment system and in many cases, Wild West business practices.
Soaring TIO complaints exposed the level of consumer pain and saw the ACMA, strongly supported by its regulator colleague, the Australian Competition and Consumer Commission, finally step in and, with industry, forge a comprehensive protection scheme. Without wanting to claim 'mission accomplished', this has already given consumers means to better navigate this part of the new world of media-comms services-even if they are using a basic 20-year-old technology, SMS.
Premium SMS-with its multi player, low barrier to entry, but often complex delivery chain-left consumers with no one willing to be the responsible adult to fix their problems. If there is one lesson I take away from the premium SMS issue it is this: the ad hoc incrementalism it precipitated is not a sustainable regulatory approach. To put it bluntly, the ACMA is tired of playing catch-up.
Yes, consumers need to take responsibility for their actions and commitments. But as we have seen in the US sub prime crisis-when no one is connecting the dots and declaring enough is enough-everyone gets hurt. The US sub prime market is of course in a different country, in a different industry and in a different market place-but its complexity, disintermediation and global footprint have strong analogies to the modern telecomunications market place.
So here is my thesis. While the dynamic and exciting world of converged media and communications offers great opportunity, its inherently complex, interrelated and global character means we have to ensure the end user of these services and products is not left vulnerable when things do not work the way the marketing brochure suggests.
I am not naïve about this challenge-a challenge from which the ACMA cannot, will not, now resile-nor do I want to claim we at the ACMA have all the answers to what telco regulation 2.0 looks like. My sincere hope is that this will be a collaborative exercise as we all come to terms with the all-broadband, all-IP (Internet Protocol), digital economy.
So where are we now?
Before I lay out the road map for the ACMA in the telecoms space, I think it is worthwhile to quickly describe the main drivers for our change in approach. I do this with as much candour as I can muster because it pays no one at this critical turning point to cling to 20th century myths. My list is by no means comprehensive and I am sure you will all have your own mental catalogue of what is shaping the industry and how it is affecting your particular business.
As I have already mentioned, there has been a sharp escalation in the complexity of platforms, products, services, options, device interaction and provider arrangements. We have come a long way since the single voice product, "Plain Old Telephone Service" of yesteryear.
This has created business and technical challenges for carriers, and made it significantly less clear what the telecommunications system is and where and how to best regulate it. The inexorable unification of the communications system with enterprise systems and the burgeoning ecosystem of applications in the cloud is erasing traditional notions of the network.
Similarly, the line which once divided content and carriage is also quickly disappearing as telcos and providers increasingly use content as a tool to build loyalty, engagement and margins.
Consumers are embracing niche services, new technology and devices, earlier and earlier. The extraordinary, and somewhat feverish release of the iPad saw 300,000 devices sold on launch day in the US. Today, I also note with some interest the launch of Telstra's T-Hub phone. This product will bring yet another communications option to homes already bursting at the seams with devices.
As Forester Research reported late last year, early adopters are morphing into the mainstream. I am not saying that we are all gadget geeks. Many still live happily with just a TV and landline telephone. But we have to acknowledge that the speed of new adoption is increasing, not decreasing.
Citizen expectations and permissions on key issues such as privacy are changing sharply, especially in younger demographics. Six million Australian Facebook users are participating in a massive crowd-sourcing experiment. In just a few years, the interaction of the likes of Facebook, Twitter, and now Google Wave and Buzz, has created an amazing ecology of digital life, which we are only just starting to understand.
Business models are transforming as connectivity and content increasingly become commodities. Global platforms emerge, operated by new, essentially unregulated players such as Amazon, Google and Apple, offering a suite of media, communication, gaming and other applications.
Premium SMS will look horse and buggy against the sophistication of mobile apps that offer a range of services from credit card payment to broadcast television to sophisticated location services. Indeed our market intelligence suggests rogue operators have already moved on from the premium SMS space to mobile apps.
The current regulatory regime was based on an assumption of co- and self-regulation, and sprang from that single voice service paradigm. It was driven by a need to encourage the then nascent infrastructure competition, following the end of the Telstra monopoly.
Unlike broadcasting and radiocommunications, where there is a clear and direct mandate for the ACMA to operate, the regulatory model in the telecoms space is more ambiguous, with responsibility dispersed across multiple agencies and organisations.
The perhaps harsh truth is that the broader industry suspicion of our market incumbent, Telstra, has limited sector-wide solutions from within the industry. I also suspect that, while arguably some of the telco sector's troubled reputation around customer service has been shaped by Telstra's well-documented struggle to modernise its systems, the industry can't go on blaming the incumbent for its issues forever.
In many cases, the sheer explosion in market activity has overwhelmed legacy customer care and complaint systems and to date have defeated a 'single view of the customer'. This has exacerbated the fuzziness over who is responsible for what. The result is that much has fallen between the cracks.
Relations between carriers and the first receiver of complaints (the TIO) have been focussed on the operational and, in the main, have not been a pathway to fixing systemic issues, let alone addressing institutional shortcomings.
Not to be forgotten, and balancing these observations, is the strategic importance of communications as a driver of our GDP, innovation and international competitiveness. I want to go on the record as acknowledging the role the sector has played in the successful underpinning of a remarkable generation of Australian growth. I have to say that this role is sometimes lost on commentators and interest groups.
The shift to an all-IP world, delivered across ubiquitous fixed-line and wireless broadband channels, is now becoming very tangible and will be accelerated by the roll out of the NBN.
Finally, I strongly agree with the previous speaker, Alcatel Lucent's Andrew Butterworth, that it is the services and applications which hang off the high-speed networks-and not the infrastructure per se-which are going to drive the digital economy.
So what principles will take us forward?
In the interests of transparency-or Gov 2.0 as it is increasingly being described-let me give some insight into the principles which will guide the ACMA as we go forward. This is a 'live' list and again I hope that these can be improved and added to over the coming period.
The ACMA has specific statutory functions in the telco space including resource management, (numbering and spectrum), facilitation of co-regulation, technical accreditation, licensing, content assessment, compliance and enforcement, research and providing broad-ranging advice.
This gives us a natural role in the practical design and execution of the re-thought framework, where we can be expected to have an informed view about regulation based on our experience and expertise.
We absolutely acknowledge dynamic market activity is creating strong consumer and business demand for communications products and services and is critical to ensuring continued investment and innovation. As we all know, capital has many choices as to where and what it can be applied to-but there needs to be an appropriate return on investment.
National interest considerations-government revenue stability, national security and interceptions, economic growth and rational resource allocation-are agreed assumptions for any intervention.
However, the rapid roll out of services and products is creating gaps in key areas such as connectivity speeds, network reliability, accessibility (both for the vulnerable and those with disabilities), product warranties, billing, unsolicited product, technical standards and content suitability. It is these 'gaps' for consumers which are of most interest to the ACMA.
Universal service is something which government policy makers and regulators around the world will inevitably come to re-define as we edge our way into an all-broadband world. This will include an assurance of enough bandwidth to participate in the many rich services expected to come on stream. A digital divide is not going to be acceptable for Australian citizens.
Technical assurance and network access continues to be a critical issue for vibrant competition and must also be baked into any new regulatory framework.
Many of these same issues confront all OECD countries. The global nature of the IP world demands any intervention be long term, sustainable, practical, effective and in harmony with international directions. Australia is a taker of appropriate standards.
We need to understand the supply chain to ensure intervention will be effective. We also need to appreciate that much of the sector's dynamism comes from its relatively unregulated segments, most particularly the internet.
Intervention should be aimed at fixing systemic issues where market solutions are not available or working. Strong competition gives customers real choice when they are dissatisfied. Solutions should be enduring, effective and at worst not counterproductive.
Rules and concepts will need to cater for an all IP world where vocabulary such as broadcasting, carriage, location and even numbering will have less meaning. We need to be ready and open to switch our thinking and not be constrained by tradition, sentimentality or incrementalism. But in the transition, we have to continue to support and regulate for those more comfortable in the analog world-if you like, we need to take a 'simulcast' approach.
Predicting service take-up has its risks but we should seek to be in front of the large swings in usage so I welcome the Government's leadership as it crafts its review of media rules and regulations.
Sometimes lost is the fact that the ACMA's mandate is sectoral and for some national and economy-wide issues there will be other agencies and organisations better equipped to manage oversight and behaviour.
In cases of uncertainty and rapid change, the wisest path may be simply to forbear, (ie. agree to take no action), until clarity emerges. A recent example is the ACMA's approach to geographic numbers. Here, in the face of the VoIP phenomena, we have proposed changes to numbering rules to make it easier for phone companies to issue a geographic number to a business or consumer that does not correspond to the actual location of that business or consumer.
Numbering is a classic convergence problem where we must start to exercise practical judgment about today's operating rules knowing that we are in fact transitioning to a new framework. Formed in an old era, numbering is a central pillar of the current regime but requires rethinking to provide flexibility for new services. It is a classic example of the clash between legacy services and innovation and will demand that we address these fundamental change issues.
The current numbering approach was established in 1997 and did not anticipate the scope or scale of changes convergence would bring. Today, as VoIP and other smart IP services are rolled out, a wide range of industry participants are looking to access numbers for a diverse range of products because boundaries that define these products have become more blurred. This is happening as the numbering and electronic addressing worlds become less distinct and are subject to different regulatory frameworks.
As a consequence, the Numbering Plan is straining to meet the needs of consumers and providers.
Already this year the ACMA has identified short-term changes to geographic numbering rules. These changes are designed to increase flexibility in allocating geographic numbers and allow phone numbers to be allocated to outbound-only services (including VoIP-out services). We are currently consulting on those proposed changes.
The ACMA will also embark over the year on a more systematic look at these emerging issues and how they are affecting numbering arrangements. The ACMA has started talking to industry and consumers about what transitional arrangements are needed for numbering.
Issues we need to resolve include ensuring service descriptions align with the functions, cost and technical capabilities of services in the market and how to ensure efficient taxing and charging.
Also to be determined is the management of personal attribute information and how calling line identification handles the use of this information.
The general principles which will guide us are efficiency, flexibility, simplicity, endurance and transparency. The last is critical to ensure consumers have the information about services and prices they need to make choices and get support where required. We need to ensure consumer safeguards, such as call price information, that are supported by telephone number information are not lost, that they retain their utility
Ensuring end users have a robust, easy-to-use channel for support, help and solutions for their service problems and issues, becomes hugely important in this complex service era.
Enough of the lofty principles. Let me now give you some details of what this looks like when the 'rubber hits the road'.
I am going to talk about this under the heading:
Reconnecting the customer
A key learning from the premium SMS saga I talked about earlier is the need to build a more robust consumer protection framework for the increasingly complex world of communications services.
Many here would share the ACMA's concern about whether the current self- and co-regulatory arrangements which underpin telecommunications consumer protection mechanisms are really effective in dealing with the issues that concern consumers most.
We all know what these concerns are. Whether they are evidence of a failing regulatory system or are just a perception of that failure, they need to be addressed. The perception can be as destructive as the reality.
So what are the facts? Last financial year the TIO recorded a 130 per cent increase in complaints related to complaint handling and a 118 per cent increase in complaints about customer service. These formed a large part of the 54 per cent increase in overall complaints to the TIO for the year.
What spurred this increase is a matter of conjecture-overly aggressive smart phone plans, an inevitable Wild West mentality when new opportunities spring up, outsourced off-shore help desks, and perhaps greater customer scrutiny of their bills as they became more cautious in the economic downturn.
This may have been a perfect storm and, although the number of complaint issues to the TIO marginally fell in the December quarter of 2009, the ACMA is concerned that the percentage of overall complaints to the TIO about complaint handling and customer service has NOT declined.
The trend-line growth and sheer quantum of complaints about complaint handling and customer service-upwards of 900 every working day-reflects poorly on the entire industry.
Last year, as part of the Connect.Resolve campaign, the TIO and her hard-working staff worked valiantly with the industry to attempt to reduce these complaints.
Although this campaign was a first step towards addressing the problem, early indications since the campaign stopped are such that we are not confident that this improvement is going to be sustained.
I now believe this issue has to be confronted directly and urgently, otherwise we will be talking about these same issues for years to come. So today, I will set out in detail our Consumer Protection Strategy for the coming twelve months.
Called "Reconnecting the Customer" it is a multi-layered approach which I believe is necessary to address both the immediate issues as well as the transition to the future service environment.
We don't want to act alone, unless we have to. Our preference is to work in partnership with government, other regulators, industry and consumer advocates and advisory bodies.
The broad objectives of the strategy are twofold. First, to implement specific measures to address current telecommunications consumer protection issues; and, secondly, to create a protection framework aligned to the needs and expectation of end users in the future service environment.
The first specific issue to be addressed is the poor responsiveness of industry to the concerns of its customers. The poor complaint handling of the industry is legendary.
Only last week I was told of a consumer who had last month received a promotional SMS offering him double his current data plan for half the price. He accepted only to find the link he was sent to, signed him up for double the price. Numerous attempts to get the carrier to accept it had over promised came to nought, until he finally went to the TIO who resolved his problem.
This is typical of what we hear regularly. We want to get to the heart of the cause of this 'inherent tension', as the Minister called it, between providers and customers who have problems-a breakdown which is damaging the reputation and brand equity of the whole industry.
Customer Service Inquiry
To do this, the ACMA will be undertaking a formal inquiry into the industry's practices in dealing with the problems of its customers. The inquiry, which is consistent with the ACMA's evidence-informed approach, will also identify what should be the key elements of good customer relationship management and attempt to plot the pressure points in the interaction between customers and providers. In particular, I want the inquiry to shine a strong light on complaints handling and the unresponsiveness of the industry to its customers.
We want to establish, as a reference point, an analytic framework and metrics so that this vexed issue of responsiveness and complaint management can be settled for a foreseeable future.
This framework will be a reference point which community safeguards in future code development can be linked to and measured against.
The inquiry will also consider how the current regulations can be used more effectively to address industry practices in dealing with its customers.
The inquiry may determine whether, from the ACMA's perspective, more direct regulation of complaint handling is necessary and the form that any such regulation should take, for example, through the establishment of standards. We will be actively seeking engagement with all stakeholders using the wide range of communications channels available to us.
A vital part of this inquiry will be determining how consumer expectations can be satisfied in the more ubiquitous (NBN-delivered) broadband, multiple-services world.
The inquiry will create a collective fact base and hopefully a consensus around a unified approach to best practice for managing and measuring customer concerns and complaints. This approach should itself hopefully transition that ubiquitous broadband world.
I will personally brief CEO's of the larger service providers (representing 90 per cent of the TIO complaints) and ask for their support. As the learning's emerge from the inquiry, I will seek their collective agreement on enforceable strategies for lowering the number of complaints to the TIO about complaint handing.
I want to know when, as an average punter and as a consumer of multiple communications services from the same service provider, I won't have to go through the maze of multiple authentications and business units to get my problem resolved.
Clear Focus for Code Review
The ACMA also intends taking a strong role in the review of the Communications Alliance Telecommunications Consumer Protections Code. This code review is due to commence shortly and will be one of the most important regulatory processes to be undertaken by the ACMA.
I am well aware this code is an industry code, but I will go on the record today with my clear view that there are a number of issues in the code that require change and the Authority will be forceful in its communication of these issues to industry.
The ACMA has conducted numerous compliance exercises over the past 18 months, which have not only assessed industry compliance with the TCP Code, which has been high in the main, but have also raised questions about the adequacy of the code itself- and this is something we have been working on assiduously.
The ACMA will use this material as the basis of formal guidance to the Communications Alliance on the adequacy of the current code and our clearly expressed expectations for the new code. We want results not better process in splendid isolation.
So, I am indicating we will be pro-active in providing CA and the industry with guidance about the aspects of the code that require remedy and indeed how the ACMA feels the remedy can be achieved.
Equally, if the timeframes we specify are not met, we will proceed to a mandatory industry standard in the areas where we feel the code does not provide appropriate community safeguards.
Importantly we will invite the ACCC to contribute to this guidance, especially to ensure the code successfully encapsulates the new national consumer provisions.
We also intend to communicate to CA our expectations on the code review process so that the opportunity for consumer representation and consultation on the content of the code is real and meaningful-not fractured as recent experience suggests.
The third major initiative in our 'Reconnect the Customer' approach involves the establishment of a regulatory forum. As regulators, we need to turn the mirror on our structures and roles. I do not believe the current regulatory 'alphabet soup' of ACMAs, TIOs, ACCCs, DBCDEs, CAs and TISSCs (along with the state OFTs) is leading to the best solution for some of the bigger problems.
As an immediate step, I will be seeking to work with my colleagues at the ACCC and DBCDE, consumer groups (led by ACCAN), and user groups such as ATUG, to identify emerging issues in telecommunications and develop appropriate regulatory responses. This will be done in collaboration rather than isolation.
Again, premium SMS would have been far better dealt with if early responses had been collaborative and co-ordinated through such a forum. We'll specifically turn our mind to mobile apps.
A useful starting point for the forum will be the expected outcomes from the review of the TCP Code. Thereafter, the intention will be to report regularly to the Minister on emerging issues and propose co-ordinated, considered regulatory responses to those issues.
Future regulatory arrangements
As part of the fourth major initiative, I see the ACMA, through the auspices of the Regulatory Forum, as a major contributor to a discussion on the suitability of the current consumer protection regulatory framework in a converged environment.
As part of this process, we would ask the industry to re-affirm whether it really wants self-regulatory arrangements as part of the broader regulatory framework.
If it does, it needs to consider how the TIO scheme will make these arrangements work for consumers. This includes looking at some of the ways in which issues can be more quickly and readily resolved by the industry itself. As an example, under the Insurance Broking terms of reference, the Financial Services Ombudsman has powers to order its members to publish corrective advertising, impose determinations, orders and sanctions or to cancel a member's membership. The TIO does not.
There are also issues for TIO members in the role of its Board (which has no consumer representation) and Council (which does). It is interesting that the dual structure of the TIO Board and Council would not meet the test for a unitary governance model set by the Australian Securities and Investments Commission for a financial ombudsman.
This future-focussed work should also consider whether and how to rationalise the role of each of the telecommunications regulators. Crucially, and perhaps controversially, this discussion should also examine the appropriate forms of regulation for the future. The intent here is to inform clear ACMA advice to the Minister on the key question around the ability of self- and co-regulation to deliver benefit for consumers.
As an aside to this point I'll briefly add that the ACMA has been developing a diagnostic tool- an assessment framework for testing the suitability of self and co-regulation to specific scenarios. I am hopeful that this framework will be publicly released in the next few months and will provide guidance on the ACMA's ex-ante disposition towards the various forms of regulation and how and when each should be applied.
The successful management of nuisance communications through anti-spam reporting and the Do Not Call Register are good examples where clear objectives, purposeful rules and strong compliance have delivered practical and meaningful results for consumers.
Enforcement and compliance
The Minister has introduced the Telecommunications Legislation Amendment (Competition and Consumer Safeguards) Bill to the Senate. While it is not appropriate for me to discuss the merits of the Bill in any detail, the ACMA welcomes these measures and the Minister' strong leadership, particularly the protection for those more comfortable in the simplicity of the analog world.
The Bill would also enable ACMA to designate legislative provisions which would be subject to infringement notices and provides the Minister with the ability to determine the pecuniary penalty for certain infringement notices (which could be up to $2 million). These additional enforcement options add to the suite of options available to the Authority, particularly those related to the new regulatory benchmarks which would be enabled by the Bill, but also more broadly.
The option of infringement notices has proven useful in the ownership and control aspects of the broadcasting arena to address breaches without necessarily requiring expensive and time-consuming court action.
The ACMA's strapline is 'communicate I facilitate I regulate'. Those words appear in that order for a reason. Wherever possible we will tell industry what is expected of it, and assist participants to achieve what is expected of them. But the third limb is also vital. Where communication and facilitation, through their co-regulatory framework prove to be insufficient, we will regulate, and that includes taking firm action to enforce the law.
In choosing the cases that we take on we will be particularly interested to make a 'macro' difference to the market. If we see that there is general misconduct or some broad market failure in the telecommunications sector, then we will consider choosing some egregious examples of that misconduct or failure and testing those examples in the courts.
Again I return to our actions around breaches of spam and Do Not Call Register legislation as models for successful enforcement.
Some of the penalties applied by the courts in those cases have been very significant. For example, in the Mobilegate matter involving the distribution of spam by SMS, the Federal Court has so far ordered the payment of penalties of more than $22 million against the respondents. Penalties of that order do have a salutary effect on anyone contemplating the illegal distribution of spam for a commercial gain.
We also know that compliance departments around the country have taken note of those penalties and have re-examined and, where necessary, strengthened their compliance systems and procedures. We will carefully consider other appropriate opportunities to send similar messages to other sectors of the telecommunications industry where that may be necessary.
Finally, I believe it is also incumbent on the ACMA to lift its general facilitation game. At a time of rapid change, it is important that we engage in genuine dialogue and solution building. This is an important message, not only for senior executives of our respective organisations, but also for the many technical and operational relationships we have with our stakeholders.
I'll be consulting with industry leaders on what they are looking for but, from our inquiries, we are alert to their need for the ACMA to give better feedback about our concerns. We also acknowledge that we are starting from a position where we as regulator and you as providers have very similar goals. These goals are to ensure a dynamic, innovative, technically robust service environment for the benefit of effectively informed consumers and end users.
I am hopeful that today is a good start to this engagement. Better practice will include regular statements of our approach and intent, evidence-informed concerns and priorities for remediation. Tune ups, information sessions and feedback programs could all be part of a far more robust, more two-way and more effective stakeholder framework. To this end, we have recently appointed a senior executive to drive our Gov 2.0 and stakeholder engagement program. Using the exciting toolsets available we will really lift our level of engagement and collaboration. I look forward to establishing deeper and richer relationships with all our stakeholders.
Moving then back from the soft elements of strap lines and engagement strategies to the harder edge elements that really underpin my commentary, the ACMA Authority today takes this opportunity to set out its approach:
- We remain supportive of the co-regulatory approach but, building on what we have learnt in the Telco space over the last several years as to the shortcomings of that approach-particularly with respect to consumer and user concerns-we are moving ahead with renewed vigour and a strong, pro-active bias.
- We want to forge the new paradigm, together with industry participants, with consumer perspectives effectively engaged and accommodated.
- We expect that the data, learnings and evidence from the formal inquiry to resolve to solutions for us all to deliberate on and execute as a foundational piece of telco regulation 2.0.
- We see great opportunity for leaders in the Telco space to establish customer-centric approaches that are brand equity led.
- So I am nailing the Authority's colours to the mast. We're not waiting for anyone, anymore.