New rules to protect consumers migrating to the National Broadband NetworkPart 1: Improving management and handling of consumer complaintsConsultation paperMARCH 2018

CanberraRed Building Benjamin OfficesChan Street Belconnen ACT

PO Box 78Belconnen ACT 2616

T +61 2 6219 5555F +61 2 6219 5353

MelbourneLevel 32 Melbourne Central Tower360 Elizabeth Street Melbourne VIC

PO Box 13112Law Courts Melbourne VIC 8010

T +61 3 9963 6800F +61 3 9963 6899

SydneyLevel 5 The Bay Centre65 Pirrama Road Pyrmont NSW

PO Box Q500Queen Victoria Building NSW 1230

T +61 2 9334 7700 or 1800 226 667F +61 2 9334 7799

Copyright notice

https://creativecommons.org/licenses/by/4.0//

With the exception of coats of arms, logos, emblems, images, other third-party material or devices protected by a trademark, this content is made available under the terms of the Creative Commons Attribution 4.0 International (CC BY 4.0) licence.

We request attribution as © Commonwealth of Australia (Australian Communications and Media Authority) 2018.

All other rights are reserved.

The Australian Communications and Media Authority has undertaken reasonable enquiries to identify material owned by third parties and secure permission for its reproduction. Permission may need to be obtained from third parties to re-use their material.

Written enquiries may be sent to:

Manager, Editorial and DesignPO Box 13112Law CourtsMelbourne VIC 8010Email: info@acma.gov.au

OverviewBackground 1Submissions 2Timing 3

Issues for commentComplaints-handling Standard 4Record-keeping Rules 5

Complaints-handling StandardObjective 6Rationale 6Overview of instrument 6

Record-keeping RulesObjective 8Rationale 8Overview of instrument 8

Invitation to commentMaking a submission 11

Appendix A— Changes to Chapter 8

Appendix B— RKRs: data requirements

acma | iii

Overview

The Australian Communications and Media Authority (the ACMA) is developing new rules for retail carriage service providers (CSPs) in order to improve the experience of residential and small-business consumers moving to the National Broadband Network (the new network).

A Ministerial Direction given to the ACMA dated 20 December 20171 provides the legal authority for three industry standards to be made under section 125AA of the Telecommunications Act 1997 (the Act) dealing with:> handling complaints consumers make to retail CSPs> providing information to consumers about migrating to the new network> promoting the continuity of voice and broadband services

We are also creating new rules using existing statutory powers to buttress these measures and to improve the consumer experience. These are: > record-keeping rules to be made for complaints made to CSPs (section 529 of

the Act)> a new service provider determination requiring CSPs to undertake post-connection

line-testing to proactively identify faults and ensure services are working after installation made (section 99 of the Act).

This paper specifically seeks comments on the draft Telecommunications (Consumer Complaints Handling) Industry Standard 2018 (the Standard) and Telecommunications (Consumer Complaints) Record-Keeping Rules 2018 (RKRs). We intend to consult separately on the other rules in early April 2018.

To inform this consultation process, we are also releasing a snapshot of our new research (research snapshot) into the experience of residential household consumers before, during and after their migration to the new network.

BackgroundIn mid-2017, in response to growing community concerns and a rising number of complaints to the Telecommunications Industry Ombudsman (TIO), the ACMA began an information-gathering program to identify the scale, nature and causes of consumer issues with the new network. In December 2017, we released findings from an analysis of information obtained from industry.

These findings revealed that average times for resolving consumer complaints about connections to, and faults on, the new network were, in some cases, drawn-out. Additionally, the quality, timing and efficacy of CSPs’ handling of complaints deteriorated when it was necessary to liaise with a wholesale provider to manage and resolve a complaint.

1 Telecommunications (NBN Consumer Experience Industry Standard) Direction 2017.

acma | 1

Our research snapshot found that 31 per cent of all households surveyed had complained to their current or previous retail CSP since connecting to the new network.2 Among these households, 20 per cent were resolved on the same day, 15 per cent took longer than a week and 49 per cent remained unresolved at the time of the survey.

This snapshot also shows that approximately one-quarter of those whose complaints were resolved were dissatisfied with the complaints-handling process. The top three reasons given by households for this dissatisfaction were: > too long to fix/take action (58 per cent)> poor communication or lack of communication (48 per cent)> nobody would take responsibility for fixing my problem (39 per cent).

The rules on which the ACMA is currently consulting are intended to:> impose minimum complaints-handling processes requirements on all CSPs> where appropriate, require the involvement of wholesale providers in the resolution

of consumer complaints made to CSPs> improve the ACMA’s ability to enforce compliance with these minimum

requirements> allow the ACMA to better monitor and analyse consumer complaint trends over

time.

SubmissionsWe are seeking submissions from stakeholders on the Standard and RKRs.

Issues raised in this paper provide possible points of consideration and are not intended to be restrictive. The paper also includes a number of specific questions to further help frame submissions.

2 These households were connected to the new network in the last 12 months in the areas that were surveyed.

2 | acma

TimingDate Step15 March 2018 Public consultation process begins (release of this paper)COB, 16 April 2018 Public submissions closeMay 2018 Submissions published on ACMA websiteNo later than 22 June 2018 Instruments made by the ACMA AuthorityNo later than three months after making Instruments commence

acma | 3

Issues for commentWe invite general comments on the issues set out in this discussion paper, as well as responses to the following specific matters:

Complaints-handling Standard1. Does the draft Standard properly protect telecommunications consumers who

make a complaint to their provider? 2. Are there any additional measures that should be incorporated into the Standard?

Please provide additional data and/or evidence to support your position.3. In the circumstances identified below where we have proposed a new time frame

for an obligation currently existing under the Telecommunications Consumer Protections Code (TCP Code), are those time frames appropriate? If not, why not?

Section of draft Standard

Corresponding obligation in TCP Code

Proposed obligation

Section 8(1)(c)—Minimum requirements – accessibility

Clause 8.1.1 A complaints-handling process be made available to a consumer as soon as practicable after he or she informs the CSP they wish to make a complaint and, where appropriate, to carriers or CSPs identified in Part 6.

Section 14(1)—Delays

Clause 8.2.1(a)(ix) A CSP must advise consumers of any delay to proposed time frames for managing or handling their complaint as soon as possible after becoming aware of the delay.

Section 15(1)—Complaint prioritisation, escalation and external dispute resolution

Clause 8.2.1(b) A CSP must, within five working days of receiving a communication from a consumer expressing dissatisfaction with response times or seeking to have their complaint treated as urgent, advise the consumer about internal prioritisation and escalation processes and options for external dispute resolution.

Section 16(2)—Frivolous or vexatious complaints

Clause 8.2.1(d) Within five working days of making a decision not to deal with a consumer for reason of being unable to do anything more to resolve a complaint or assist a consumer, or a consumer’s behaviour or complaint is frivolous or vexatious, a CSP must advise the consumer [in writing] the reasons for its decision and options for external dispute resolution, including the TIO.

Section 17—Attempt to make contact

Clause 8.2.1(e) If a CSP is unable to contact a consumer to discuss their complaint or to advise them of the proposed resolution of their complaint, despite attempting to do so for five working days, the CSP must write to the consumer

4. Part 6 of the Standard (reasonable assistance) sets out new obligations on carriers and wholesale CSPs to help retail CSPs resolve consumer complaints. Will the obligations in Part 6 be effective in helping retail CSPs to resolve consumer complaints that involve other entities in the supply chain?

5. Are there any elements of the draft Standard that are inconsistent with community expectations?

4 | acma

6. Are there any elements of the draft Standard that cannot be reasonably implemented or complied with for technical, operational or other reasons? For example, what are feasible time frames for the Standard to take effect, noting the three-month limit specified by the Ministerial Direction and the fact the Standard largely reflects the obligations in Chapter 8 of the TCP Code. Please provide detail.

Record-keeping Rules7. Does the proposal for the RKRs to apply to providers with 30,000 and above

consumer services in operation mean that adequate complaints information will be available to consumers and industry?

8. Are there any elements of the draft RKRs that cannot be reasonably implemented or complied with for technical, operational or other reasons? Please provide detail.

9. Are there any impediments for providers in meeting the level of detail proposed in the draft RKRs? For example, what are feasible time frames for the RKRs to take effect, noting the three-month limit specified by the Minister’s Direction?3 Please provide detail.

10. We propose that CSPs report their top three most prevalent complaint categories to the ACMA. Are the proposed complaint types appropriate to enable categorisation of consumer complaints? If not, what additional or alternative categories would you suggest?

11. Are there any additional measures that you would recommend including in the RKRs? If so, why?

3 While the three-month limit does not technically apply to the RKRs, we consider it appropriate for the RKRs to begin at the same time as the Standard.

acma | 5

Complaints-handling StandardObjectiveThe aim of the draft Standard is for complaints-handling rules, including time frames for response and resolution, to be better enforced. Additionally, retail CSPs and the TIO should be able to obtain reasonable assistance from upstream providers such as wholesalers, other intermediaries and NBN Co to resolve customer complaints.

These rules will be based on existing measures found in the TCP Code.

RationaleRules for CSPs that provide retail services are outlined in Chapter 8 of the TCP Code and were developed in line with the Australian Standard for Complaint Handling.4 However, there are gaps in the operation of these rules, including as a result of supply chain complexities. In addition, the volume of complaints and extended resolution times indicate that the current rules are not meeting community expectations, particularly during the transition to the new network.

The Ministerial Direction sets out matters that the Standard must deal with:> CSPs and carriers must deal with complaints in a professional, effective and

efficient manner> CSPs must establish a consumer complaints-handling process, including minimum

requirements for timeliness, accessibility and transparency of that process> the complaints-handling process must be free of charge> CSPs must manage, monitor, analyse and record consumer complaints> CSPs should include response times for various steps in the process> CSPs and carriers forming part of the supply chain should provide reasonable

assistance to the retail CSP who has received the complaint from the consumer.

Overview of instrumentWe have used the complaints-handling obligations in Chapter 8 of the TCP Code as a basis for the draft Standard, and included additional provisions to ensure that:> upstream providers such as wholesalers (such as NBN Co), and other

intermediaries provide reasonable assistance to retail CSPs and the TIO to resolve customer complaints

> we can take compliance action when complaints-handling rules are not being adhered to.

The instrument will apply to all CSPs and carriers as defined in the Act.

A number of proposed changes will provide additional consumer certainty, support better cooperation across the supply chain and improve the enforceability of the existing arrangements. Some obligations have been redrafted and restructured to ensure suitability for inclusion in a legislative instrument and that the Standard meets the requirements of the Ministerial Direction. Table 1 in Appendix A sets out the key points of difference between Chapter 8 of the TCP Code and the Standard.

4 Refer to the Australian Standard for Complaint Handling (AS/NZS 10002:2006 Australian Standard – Complaint Handling).

6 | acma

As required by the Ministerial Direction, we have considered whether the Standard will confer functions and powers on the TIO. Following consultation with the TIO, it is our view that the TIO currently has appropriate powers to handle consumer complaints about matters referred to in the Standard, similar to the way it handles complaints about corresponding provisions in the TCP Code.

The Standard would, necessarily, take precedence over any code-based obligations in Chapter 8. However, (harmonised) code-based complaints-handling obligations could coexist with the Standard and potentially play important roles, including:> building on matters of operational detail considered important by retail CSPs > ensuring complaints-handling compliance receives industry focus via the code-

based Communications Compliance processes> providing a regulatory mechanism that would allow the ACMA to revoke its

Standard once industry practice was sufficiently sound and mature.

acma | 7

Record-keeping RulesObjectiveThe draft RKRs are intended to make the handling of consumer complaints across the telecommunications industry more transparent. The RKRs will enable the ACMA to monitor complaint levels and assess whole-of-industry and individual providers’ level of responsiveness to, and resolution of, complaints and service issues.

It is our intention to publish the data gathered via the RKRs on a quarterly basis, enabling consumers to make informed choices about providers, encourage better complaints-handling by providers, and enable us to more effectively monitor complaint trends and levels. We have not yet reached a view about what form that publication might take and will consult with stakeholders about how that data might best be presented before we publish our first report of RKR data.

RationaleThe key findings of our information-gathering exercise released in December 2017 highlighted that complaints-handling processes across the telecommunications industry are not transparent. Specifically, there is a lack of visibility of the number of complaints CSPs receive and how well providers address them before they are escalated to the TIO.

We consider that clear, consistent and comparable information about complaint numbers and issues provided across the industry will help with early identification of emerging complaint trends or regulatory issues. It will also encourage the industry to continue to focus efforts on effectively managing complaints (and underlying causes).

Separately, the ACMA’s new research snapshot reveals the factors that are important in selecting a plan and provider for services delivered using the new network. These include cost (86 per cent), keeping an existing phone number (82 per cent for those with a home phone) and confidence in faults being fixed (80 per cent). Making information about complaints-handling more available will help consumers to make informed decisions when choosing a provider.

Overview of instrumentThe draft RKRs build on existing industry practices and will require CSPs to report complaints data to the ACMA on a quarterly basis. The proposed data will be drawn from the records that CSPs are required to keep in accordance with complaints-handling requirements contained in the Chapter 8 of the current TCP Code as well as existing industry practice, such as the Complaints in Context reporting scheme for consumer and small business services.5 Identification of data categories has also been informed by ACMA industry research and the findings of the new residential household survey. Proposed data and categories include: Service records> Total number of Services in Operation (SIOs).> Number of SIOs in the following categories:

i. mobile servicesii. fixed broadband services provided on legacy networksiii. fixed voice services provided on legacy networks

5 The Complaints in Context reports are published by Communications Alliance and the TIO.

8 | acma

iv. voice-only services provided on the new network6

v. broadband services provided on the new network by all the technology types; that is, FTTP, FTTN, FTTB, FTTC, HFC, fixed wireless and satellite.

Complaint records> Total number of complaints.> Number of complaints for each service type (as per above).> Number of complaints resolved at first contact.> Number of complaints escalated to the TIO.> For broadband services provided on the new network, the number of:

i. connection-related complaints (for example, missed appointments or delays in connecting)

ii. fault-related complaints iii. speed-related complaints.

> For voice-only services provided on the new network, the number of:

i. connection-related complaints (for example, missed appointments or delays in connecting)

ii. fault-related complaints.> The top three most prevalent complaints by complaint type as identified in the

complaint analysis conducted by the CSP for each reporting period.7 For example, a CSP’s analysis might indicate that billing complaints were the most prevalent category, followed by complaints about faults and complaints about connections.

Table 2 in Appendix B identifies the data that CSPs will be required to provide to the ACMA in each quarterly report. We anticipate these reports will be submitted via our website.

We propose that the new rules will apply to providers with 30,000 and above consumer services in operation. This includes fixed voice and broadband services (both those provided on the new network and on other networks), as well as mobile services. Our analysis indicates that this threshold encompasses approximately 97 per cent of telecommunications consumer customers (that is, residential and small-business customers). In considering the application of the RKRs to CSPs, we have been mindful to balance regulatory burden on commercial operators with improving the customer experience.

We have included audit provisions in the RKRs, which are modelled on equivalent provisions in the Telecommunications (Customer Service Guarantee) Record-Keeping Rules 2011. These provisions allow for audits only in circumstances where we form a view on reasonable grounds that an audit is necessary. In such circumstances, an external auditor will conduct an audit and provide a report to the ACMA under the RKRs. These provisions will help to ensure that CSPs put in place appropriate systems and processes to correctly keep the records required under the RKRs.

We are aware that procedures and practices for recording complaint data may vary across industry providers. It is our intention to use the existing TCP Code definition of the term ‘complaint’.8 During the implementation of the RKRs, we will provide

6 This is intended to capture standalone voice services supplied using the new network.7 Under clause 8.3 of the TCP Code, suppliers must implement processes and undertake analysis of their complaint information to identify and prevent the recurrence of complaints arising from systemic issues. The draft Standard includes similar requirements in Part 4.

acma | 9

additional guidance to help industry record and report consistent complaints data under this instrument.

8 This definition broadly aligns with the definition of ‘complaint’ in AS/NZS 10002:2014, Guidelines for complaint management in organizations.

10 | acma

Invitation to commentMaking a submissionThe ACMA invites comments on the issues set out in this discussion paper. > Online submissions —submissions can be made via the comment function or by

uploading a document. The online consultation page provides details.> Submissions by post—can be sent to:

The ManagerNetwork Migration TaskforceCommunity Safeguards and Networks BranchAustralian Communications and Media AuthorityPO Box 13112Law Courts MELBOURNE VIC 8110

The closing date for submissions is COB, Monday 16 April 2018.

Electronic submissions in Microsoft Word or Rich Text Format are preferred.

Enquiries> Consultation enquiries can be emailed to NetworkMigration@acma.gov.au.> Media enquiries can be directed to Emma Rossi on 02 9334 7719 or by email to

media@acma.gov.au.

Effective consultation The ACMA is working to enhance the effectiveness of its stakeholder consultation processes, which are an important source of evidence for its regulatory development activities. To assist stakeholders in formulating submissions to its formal, written consultation processes, it has developed Effective consultation—a guide to making a submission. This guide provides information about the ACMA’s formal written public consultation processes and practical guidance on how to make a submission.

Publication of submissionsIn general, the ACMA publishes all submissions it receives, including any personal information in the submissions (such as names and contact details of submitters). The ACMA prefers to receive submissions that are not claimed to be confidential. However, the ACMA accepts that a submitter may sometimes wish to provide information in confidence. In these circumstances, submitters are asked to identify the material (including any personal information) over which confidentiality is claimed and provide a written explanation for the claim.

The ACMA will consider each confidentiality claim on a case-by-case basis. If the ACMA accepts a claim, it will not publish the confidential information unless authorised or required by law to do so.

Release of submissions where authorised or required by lawAny submissions provided to the ACMA may be released under the Freedom of Information Act 1982 (unless an exemption applies) or shared with various other government agencies and certain other parties under Part 7A of the Australian Communications and Media Authority Act 2005. The ACMA may also be required to release submissions for other reasons including for the purpose of parliamentary processes or where otherwise required by law (for example, under a court subpoena). While the ACMA seeks to consult submitters of confidential information before that

acma | 11

information is provided to another party, the ACMA cannot guarantee that confidential information will not be released through these or other legal means.

PrivacyThe Privacy Act 1988 imposes obligations on the ACMA in relation to the collection, security, quality, access, use and disclosure of personal information. These obligations are detailed in the Australian Privacy Principles.

The ACMA may only collect personal information if it is reasonably necessary for, or directly related to, one or more of its functions or activities.

The purposes for which personal information is being collected (such as the names and contact details of submitters) are to:> contribute to the transparency of the consultation process by clarifying, where

appropriate, whose views are represented by a submission > enable the ACMA to contact submitters where follow-up is required or to notify

them of related matters (except where submitters indicate they do not wish to be notified of such matters).

The ACMA will not use the personal information collected for any other purpose, unless the submitter has provided their consent or the ACMA is otherwise permitted to do so under the Privacy Act.

Submissions in response to this paper are voluntary. As mentioned above, the ACMA generally publishes all submissions it receives, including any personal information in the submissions. If a submitter has made a confidentiality claim over personal information that the ACMA has accepted, the submission will be published without that information. The ACMA will not release the personal information unless authorised or required by law to do so.

If a submitter wishes to make a submission anonymously or use a pseudonym, they are asked to contact the ACMA to see whether it is practicable to do so in light of the subject matter of the consultation. If it is practicable, the ACMA will notify the submitter of any procedures that need to be followed and whether there are any other consequences of making a submission in that way.

Further information on the Privacy Act and the ACMA’s privacy policy is available at www.acma.gov.au/privacypolicy. The privacy policy contains details about how an individual may access personal information about them that is held by the ACMA, and seek the correction of such information. It also explains how an individual may complain about a breach of the Privacy Act and how the ACMA will deal with such a complaint.

12 | acma

Appendix A—Changes to Chapter 8Table 1: Key points of difference between Chapter 8 of the TCP Code and the

Complaints-handling Standard

Section of draft Complaints handling Standard

Corresponding obligation in TCP Code

Proposed addition

Section 5—Definitions See relevant definitions of terms in clause 2.1 of the TCP Code

The definition of ‘customer’ has been replaced by ‘consumer’.The definition of ‘authorised representative’ has been replaced with ‘representative’.

Section 8(1)(a)—Minimum requirements – accessibility

Clause 8.1.1 A complaints-handling process be set out in writing

Section 8(1)(b)—Minimum requirements – accessibility

Clause 8.1.1 A complaints-handling process be made available to the public on the CSP’s website in a concise form

Section 8(1)(c)—Minimum requirements – accessibility

Clause 8.1.1 A complaints-handling process be made available to a consumer as soon as practicable after he or she informs the CSP they wish to make a complaint and, where appropriate, to carriers or CSPs identified in Part 6.

Section 8(1)(d)—Minimum requirements – accessibility

Clause 8.1.1(a)(ii) A complaints-handling process must be free of charge for consumers to use.Note: In proposing this requirement the ACMA is acting consistently with paragraph 8(2)(b) of the Telecommunications (NBN Consumer Experience Industry Standard) Direction 2017, which requires that the standard must deal with ‘requirement that a consumer complaint handling process established under a requirement for the purposes of paragraph (2)(a) must be free of charge for consumers’. The ACMA notes that while the complaints-handling process must be free of charge for a consumer to use, the consumer may, for example, incur the ordinary cost of a call when accessing the provider’s complaints-handling process by telephone.

Section 13(a)—Resolution of complaints

Clause 8.2.1(a)(ii) Use best efforts to resolve a complaint on first contact.

Section 13(g)—Resolution of complaints

Clause 8.2.1(a)(vi) Provide written confirmation of a proposed resolution of a complaint, within 15 working days of receiving a complaint.

Section 13(h)—Resolution of complaints

Clause 8.2.1(a)(viii) Provide written confirmation of a proposed resolution of an urgent complaint, and if the consumer accepts the proposed resolution, implementing that resolution, within two working days of receiving the urgent complaint

acma | 13

Section of draft Complaints handling Standard

Corresponding obligation in TCP Code

Proposed addition

Section 14(1)—Delays Clause 8.2.1(a)(ix) A CSP must advise consumers of any delay to proposed time frames for managing or handling their complaint as soon as possible after becoming aware of the delay.

Section 15(1)—Complaint prioritisation, escalation and external dispute resolution

Clause 8.2.1(b) A CSP must, within five working days of receiving communication from a consumer expressing dissatisfaction with response times or seeking to have their complaint treated as urgent, advise the consumer about internal prioritisation and escalation processes and options for external dispute resolution.

Section 15(3)(b) and (c)—Complaint prioritisation, escalation and external dispute resolution

Clauses 8.2.1(a)(v) and 6.9.1(d)

A CSP must not commence legal proceedings against a consumer where part of the amount on a bill is the subject of an unresolved complaint or while a complaint is being investigated by the TIO.

Section 16(2)—Frivolous or vexatious complaints

Clause 8.2.1(d) Within five working days of making a decision not to deal with a consumer for reason of being unable to do anything more to resolve a complaint or assist a consumer, or a consumer’s behaviour or complaint is frivolous or vexatious, a CSP must advise the consumer [in writing] the reasons for its decision and options for external dispute resolution, including the TIO.

Section 17—Attempt to make contact

Clause 8.2.1(e) If a CSP is unable to contact a consumer to discuss their complaint or advise them of the proposed resolution of their complaint, despite attempting to do so for five working days, the CSP must write to the consumer.

Section 19(e)—Requirements for complaints monitoring and analysis

Clause 8.3 Ensure that a CSP’s processes for complaints monitoring and analysis are set out in writing, and made available to personnel responsible for monitoring and analysing complaints.

Part 6—Reasonable assistance

No equivalent Expand scope to require CSPs, carriers and wholesalers who are directly or indirectly involved in the supply of retail carriage services, to provide reasonable assistance to CSPs and the TIO in resolving complaints about retail carriage services.

14 | acma

Appendix B—RKRs: data requirementsTable 2: CSP quarterly data to be reported to the ACMA

Data point Services in operationA1 Total number of services in operationA2 Services in operation by service type: MobileA3 Services in operation by service type: Legacy (fixed-line) phoneA4 Services in operation by service type: Legacy (fixed-line) broadbandA5 Services in operation by service type: Broadband services provided on the new networkA6 Services in operation by service type: Voice-only services provided on the new networkA7 Service in operation by technology type: FTTPA8 Service in operation by technology type: FTTNA9 Service in operation by technology type: FTTCA10 Service in operation by technology type: FTTBA11 Service in operation by technology type: HFC provided on the new networkA12 Service in operation by technology type: Fixed wireless provided on the new networkA13 Service in operation by technology type: Satellite provided on the new networkData point ComplaintsB1 Total number of complaints received

B2Number resolved at first contact: (Mobile, legacy (fixed-line) phone, legacy (fixed-line) broadband, voice provided on the new network, broadband provided on the new network)

B3 Number escalated to TIOB4 Total number of complaints received by service type: MobileB5 Total number of complaints received by service type: legacy (fixed-line) phoneB6 Total number of complaints received by service type: legacy (fixed-line) broadband

B7Total number of complaints received by service type: voice-only provided on the new network

B8Total number of complaints received by service type: broadband provided on the new network

B9voice-only provided on the new network—total number of complaints by complaint type: Connections

B10voice-only provided on the new network—total number of complaints by complaint type: Faults

B11Broadband provided on the new network—total number of complaints by complaint type: Connections

B12Broadband provided on the new network—total number of complaints by complaint type: Faults

B13Broadband provided on the new network—total number of complaints by complaint type: Speed

B14Broadband provided on the new network—total number of complaints split by technology type: FTTP

B15Broadband provided on the new network—total number of complaints split by technology type: FTTN

B16Broadband provided on the new network—total number of complaints split by technology type: FTTC

B17Broadband provided on the new network—total number of complaints split by technology type: FTTB

acma | 15

B18Broadband provided on the new network—total number of complaints split by technology type: HFC

B19Broadband provided on the new network—total number of complaints split by technology type: Fixed wireless

B20Broadband provided on the new network—total number of complaints split by technology type: Satellite

B21 Top 3 from complaint analysis conducted by RSP per quarter: Highest complaintB22 Top 3 from complaint analysis conducted by RSP per quarter: Second highest complaintB23 Top 3 from complaint analysis conducted by RSP per quarter: Third highest complaint

Note: all data should be provided in absolute numbers, not percentages or ratios.

16 | acma