ACCAN Customer Service Project (25 August 2009)

5.2. Governance

If customer service charters are to play an enhanced role in the communications sector in Australia, some governance and oversight may be required. There may be specific roles to be played by Government, the regulator (e.g. ACMA) and by industry associations (e.g. Communications Alliance). The exact governance model may depend on the selected implementation model (discussed above). It is important to note that the establishment of a governance and oversight mechanism may have a substantial impact on resources, and this may have a knock-on effect on other regulatory tools.

There is some limited guidance available on service charter governance issues from other sectors:

  • Oversight
    In 2000 Victorian public transport operators released customer service charters, overseen for a short period by a Customer Service Charter Committee that included community representatives.[24] Charters were the subject of regular reviews.
  • Charter guidelines
    The Victorian Essential Services Commission Customer Services Code contains requirements for mandatory customer service charters for water utilities.[25] The WA Economic Regulation Authority has also published Customer Service Charter Guidelines.[26] Both documents set out basic content requirements and guidance on the development and review of charters.
  • Charter reviews
    There has been a history of charters being subject to independent reviews, and methodologies are available for this task.

There is enough information and guidance available to develop a basic governance and oversight structure for customer service charters in the communications industry. Again, there will be considerable overlap / confusion with the governance and oversight structure for codes of conduct in the communications sector, as many of the issues (and players) are identical.

One key issue that may be difficult to resolve is that there is a considerable disconnect between consumer expectations of the content of service charters (as evidenced by the content of consumer-driven charters[27]) and business expectations of the content of service charters (as evidenced by examples of private sector charters in Australia). Key consumer issues such as affordability are not even mentioned in service charters. On this evidence the starting positions of the parties are a long way apart.

[24] P Batchelor (Minister for Transport), op. cit.

[25] Essential Services Commission, op. cit.

[26] Economic Regulation Authority, op. cit.

[27] See especially the CTN Draft Australian Charter of Communication Rights, Consumers’ Telecommunication Network, Consumers’ telecommunication network position paper: digital economy future directions consultation, Sydney, March 2009, <>.