Day 2: What should telco management be doing?

OK, we’re at Day 2 after ACMA announced it would register the 2012 Telecommunications Consumer Protections Code.  What should management be doing right now?

We’re assuming that (a) you aren’t Telstra, Optus, Voda, TPG, Dodo or iiNet and (b) you haven’t given the TCP Code (past or future) a whole lot of thought.  Well, hello … you’re a typical Aussie telco.

Here’s where we think your management’s head should be at this point.

We know how you (should) feel

Any number of times during a year, clients send us an email with three or four attachments and an instruction:  Can you look through these and tell us what you think we need to do?

We often have no idea what it’s about, or how complicated, or whether the four attachments add up to four pages or four hundred.  And when it arrives, we’re deep in something else urgent, so we can’t take time right then to work out whether the email will call for 20 minutes of work, or 20 hours.

We don’t sleep well that night.

If you have no real sense of what the TCP Code is about, and what ‘compliant’ means, you should be nervous.  Depending on your business circumstances, it could be relatively easy to comply, or a nightmare.  Until you have a good idea of where on the spectrum you fit, you have a particular – and unnecessary – problem.  Open it up, scope it early, and either relax (because you know you can) or relax (because you know you have made a great start to compliance).

But if you’re responsible for running  a telco, and you go home a couple of weeks from now saying, ‘I must find out what that code thing involves’ then we think you’re starting to ask for trouble.

So what to do?

We’re advising our clients to hold a (roughly) two hour orientation session, as soon as possible.

That session should be facilitated by someone who’s across the code.  (For our clients, that’s us.)  It should be attended by:

  • the most senior director / shareholder / stakeholder / owner
  • someone senior in sales
  • someone senior in marketing
  • someone senior in finance
  • someone senior in carrier relations and provisioning
  • someone senior in customer care and complaints
  • the compliance manager.

The idea is for the group to get its bearings with the TCP Code, and to work out a good high level sense of what compliance will involve.

What then?

You might decide that this can wait a little while.  More likely, you’ll decide your telco needs to get cracking.  The point is that you’ll be better placed to make an informed decision.

How can Cooper Mills help?

We know a bit about this, and we’re good at passing that knowledge on to non-lawyers.  We’re available to lead TCP Code orientation sessions for management in Melbourne and, by Skype or FaceTime, around the country. Let’s get to know each other at an orientation session, and see if we want to take it further.

BYO lawyer

Already have a lawyer you love?  Great.  We have no problem if you bring them along to a management orientation session, and we talk about a model where we up-skill them in the expert area of TCP Code compliance, and they look after you.

What else?

As we posted yesterday, it’s important that your whole organisation quickly understands that something big is happening, and 1 September is a key date.

If you do nothing else this week, use posters or emails or a staff meeting or something to make sure that nobody can say on Monday morning, ‘Code?  What code?’

About Peter Moon

A telco lawyer with a truckload of experience
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