The Telecommunications Consumer Protections Code requires each telco to create documentation that the TCP Code calls a ‘Compliance Plan’ by 1 March 2013. Your Compliance Attestation statement (to be filed by 1 April 2013) will have to certify that the Plan is in place, and that it was prepared consistently with the Australian Standard on Compliance Programs, AS3806.
You have some decisions to make. The ‘Compliance Plan’ required by the TCP Code is not the same as a ‘Compliance Program’ under the Australian Standard. It seems closer to what the Standard calls a ‘Compliance Policy’ but even then, it doesn’t seem to be quite the same thing.
If you’re going to comply with the requirement to prepare a ‘Compliance Plan’, you first need to work out what needs to go into it.
Answer: When it doesn’t follow the rules in the TCP Code. The Code sets out detailed rules about the form and contents of a Critical Information Summary, and you can’t just type ‘Critical Information Summary’ at the top of a page to deliver a valid CIS.
Australian Communications and Media Authority
The 2012 TCP Code requires a telco to have a compliant Complaint Handling Process and a document that summarises that process. There are special requirements for the Summary, too.
If a telco has more than 99,999 ‘services in operation’, it needs to appoint an ‘External Qualified Assessor’ to provide a ‘Statement of Independent Assessment’ that must be lodged with its ‘First Compliance Attestation’ no later than 1 April 2013.
The TCP Code requires every telco to have a ‘Compliance Plan’ in place by 1 March 2013. Unfortunately, it’s not entirely clear what a ‘Compliance Plan’ requires, under the Code.
