Dated 14 May 2002
This document is at http://www.privacy.org.au/Papers/SubmnACA0205.html
I hope it is not too late to make this submission on behalf of the Australian Privacy Charter Council (see www.apcc.org.au) to the ACA consultation on a draft Guideline on Consumer Information by Internet Service Providers (ISPs).
We note that the draft Guideline includes information about security and SPAM control in the list of things consumers should be told (in Section 5).
Both of these are closely related to and affected by privacy principles which ISPs should already be following both under the Telecommunications Act and ACA registered ACIF Code on Customer Personal Information, and under the Privacy Act 1988.
In light of the Principles requiring notification of purpose, intended use and disclosure, access & correction rights etc (NPP 1 and equivalent in the CPI Code), it would make sense for this new Guideline to expressly acknowledge and re-inforce these privacy aspects.
We accept that there is an argument for dealing with security separately although there should be a cross reference to the Privacy Principle NPP 4, equivalent CPI Code Provision, and Part 13 of the TA.
Information about an ISP's policy on SPAM should be more closely integrated into its overall privacy policy.
We note that NOIE is currently considering regulation of SPAM and their findings might usefully be taken into account in this Guideline.
We suggest that the Guideline should expressly acknowledge ISP's privacy obligations in a new section.
Thank you for your consideration.
We would be pleased to expand on this brief submission if the opportunity is available.
Nigel Waters
Convenor
Australian Privacy Charter Council
Go to the APF Home Page.
Created: 7 February 2003
Last Amended: 7 February 2003
APF thanks its site-sponsor: