We would also advocate for general product data for all telecommunications to be included in the
designation for telecommunications. This will allow consumers to compare what is included in certain
plans aer they have checked what is available based on the geographical location. We think these
data sets would be similar for both broadband and mobile plans and should include:
● Full pricing details of all plans, including connection costs, hardware costs, any bundling
discounts and any contract discounts.
● Standardised information for comparison (included domestic calls, included domestic texts,
included international allowances, included data, data excess charges)
● Information relating to customer service including average wait times and location of support
staff.
Finally, on consumer data, we think the priority should be on usage information for the consumer’s
current plans for both mobile and broadband. This will help consumers to more quickly find plans that
suit their needs. Also, and if this usage data was made available on a regular basis (hourly or daily),
then usage data could also help to solve the problem identified in our research for mobile phone users
getting unexpectedly high bills with data recipients able to provide warnings when limits have been
reached. We think usage data for both mobile and broadband plans should include:
● Near-live usage updates (e.g. data used, texts sent, minutes on calls)
● Monthly averages for comparison purposes (e.g. average monthly data usage, call duration,
texts sent)
Question 7:
● How is applying the CDR to telecommunications likely to encourage competition in the sector?
Making the product data and usage information discussed above available through the CDR will allow
consumers to compare plans more easily. We believe this will increase competition in the sector and
ensure more consumers are using plans that are suited to their needs. In particular, we believe that
this will help smaller retailers acquire more customers and grow their businesses.
Question 11:
● What privacy issues should be taken into account when considering the designation of the
telecommunications sector to the CDR regime? For example, are there particular classes of
data that present privacy or confidentiality risks that cannot be mitigated, such that they
should not be designated as CDR data?
There are a number of privacy issues when considering the designation of datasets in the
telecommunications sector. Datasets of particular concern include location data from mobile phone
usage as well as specific information included in communications sent from a given device. On the
latter, any information on usage of telecommunications services shared through the CDR should be in
summary form (e.g. the number of text messages sent), and not include specific details about what is
being communicated (e.g. the contents of individual text messages).
Finder
99 York Street
Sydney NSW
11