[LINK] Submissions Called re Do Not Call Register

Roger Clarke Roger.Clarke at xamax.com.au
Sat Oct 10 08:40:55 AEDT 2009

Start here:

This is separate from the previous round last year, which led to the 
impending widening of the scope of the Register, to allow the 
registration of all telephone and fax numbers, including the numbers 
used by businesses and emergency service operators.

Go here for the Discussion Paper:

It appears to be a vanilla-flavoured statutory review.

But some positive statements from consumers and consumer 
representative organisations are likely to be necessary, to counter 
the inevitable pleading from consumer marketing organisations.

And consumers could repeat the request to include researchers and 
charities in the scheme;  or to add separate choices for those 
consumers who wish to deny one or two of marketing, research and 
charity uses and permit the other two or one uses.

Attachment A: Discussion questions
Key elements of the legislation
3.1.1 Are there ways that the opt-out structure of the scheme could 
be improved? 
3.2.1 Are there ways that express consent could be improved? 
3.2.2 Are there ways that inferred consent could be improved?
3.3.1 Are there ways that the registration period could be improved?
3.4.1 Are the current exemptions appropriate and relevant?
3.5.1 Should 'research calls' be defined in the Act to clearly 
distinguish between calls
with a commercial purpose and calls with a research purpose?
Operation of the Register
4.2.1 Is the registration process effective and easy to use?
4.2.2 Is the washing process effective and easy to use?
4.2.3 Are there ways to improve either of these processes?
4.3.1 Are there ways that the complaints handling process could be improved?
4.3.2 Are the penalties in the Act appropriate and a sufficient deterrent?
4.4.1 Do you have any comments on the education and awareness 
activities undertaken
by ACMA?
4.4.2 Is information on the Register easy to find and understand?
4.5.1 Should industry codes and standards apply to organisations outside of the
telemarketing industry that are causing telemarketing calls to be made?
4.5.2 Should the process for making industry codes and standards be 
faster, more flexible
and more responsive to community needs?
4.5.3 Should the Register scheme include additional rules requiring 
telemarketers to:
* keep records of their calls?
* keep internal do not call lists? 
* limit the number and frequency of silent calls?
5.1.1 Do you have any other comments or concerns about the Register?

Roger Clarke                                 http://www.rogerclarke.com/
Xamax Consultancy Pty Ltd      78 Sidaway St, Chapman ACT 2611 AUSTRALIA
                    Tel: +61 2 6288 1472, and 6288 6916
mailto:Roger.Clarke at xamax.com.au                http://www.xamax.com.au/

Visiting Professor in the Cyberspace Law & Policy Centre      Uni of NSW
Visiting Professor in Computer Science    Australian National University

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