This joint submission is made on behalf of Consumer Action Law Centre, WEstjustice, Victorian Aboriginal Legal Service and Hume Riverina Community Legal Service.
Broadly, we are pleased to see the Australian Communications and Media Authority (ACMA) taking steps to ensure the needs of people experiencing ‘vulnerability’ are reflected in the regulation, policies and practices of a sector as essential as the telecommunications sector.
This is in line with the ACMA compliance priority to ‘protect vulnerable telco consumers’, which we welcomed. It also aligns with other essential service regulators, such as the Australian Energy Regulator, and the recently launched ‘Getting to Fair’ Strategy and Decision Paper from the Essential Services Commission (ESC) in Victoria. Our organisations were involved in the consultation process for the latter strategy, and our response to this consultation is informed by that experience.
Our submission provides commentary on the appropriateness of the expressions ‘vulnerable’ and ‘vulnerability’, and offers guidance on what we consider to be more appropriate language and framing for describing the ‘vulnerable consumer’. Despite this, and with a view to providing clarity of reading, we have made references throughout our submission to clients/consumers experiencing ‘vulnerability’ in our responses to the questions for consultation.
A summary of our recommendations is available at the end of the submission.
Read our submission (PDF).210913 CALC WJ VALS HRCLS sub ACMA SOE vulnerability FINAL