Telcos that have registered with TCP Code monitor Communications Compliance via its website can now download a template for the Customer Information Compliance Statement (CICS) that the TCP Code requires to be lodged by 1 April 2013, and annually thereafter.
The template isn’t a substitute for a full compliance checklist, because it doesn’t explicitly cover all the TCP Code’s requirements for publicly available information (eg how it is to be presented). But we now know in detail what the monitor requires to be covered in your lodged CICS document.
Why satisfying the CICS doesn’t satisfy the TCP Code
The TCP Code requires that various points of information must be ‘publicly available’. In most cases (but not all) that means ‘must be published on your website’.
The Code goes on to set out requirements for ‘discoverability’ of the information eg prominence and easy location, and sometimes other requirements.
The new CICS template is only a list of the web pages that contain the required information. It doesn’t fully address information that must be available, but not necessarily on your website. And it doesn’t audit compliance with related requirements, such as ‘discoverability’.
Of course, Comms Compliance or ACMA might use the CICS to review your website and audit ‘discoverability’ and other related requirements. But the point is that a telco cannot tick off each item in the CICS and rest assured it has complied with all the TCP Code’s ‘publicly available information’ requirements. In a nutshell:
The CICS is required by the TCP Code, but it doesn’t include all that the TCP Code requires.
Cooper Mills has updated our detailed TCP Code Publicly Available Information Checklist to highlight what items appear in the Communications Compliance CICS template, so you can be certain you have those covered. But of course, our Checklist goes further and audits all the dimensions of compliance with the TCP Code in relation to publicly available information.