IOG Meeting Overview - December 2008

    Milestone Status Update

    The IOG considered the status of Milestones due between 1 July and 30 September 2008, and Telecom's progress towards meeting the milestones due during the next quarter ending 31 December 2008.

    For milestones due between 1 July and 30 September 2008, and those due on 1 October 2008, the IOG noted that Telecom has reported that it has achieved all milestones required with the exception of previously reported trivial breaches related to the Customer Service Address classification breach (Telecom Zones) and the failure to publish Radio Communication Co-location as a relevant service. The IOG Support Office provided independent assurance over the milestone status reported by Telecom and agreed with Telecom's view.

    The IOG also considered a number of issues raised by the Support Office as a result of their independent review of milestone status and noted these issues have been notified to Telecom.

    These issues were:

    Compliance Framework Implementation
    Telecom has not fully implemented all components of its compliance framework, the key outstanding component being "measurement and monitoring". The IOG noted that the Support Office is continuing to track the implementation status.

    Honesty Box Investigation Procedures
    The IOG noted that Investigation procedures for business unit staff who perform the investigations on all Honesty Box submissions have not yet been finalised and provided to the IOG. The IOG expressed concern that this has not been finalised and asked the Support Office to follow up with Telecom.

    BUBA
    BUBA service was launched on 8 July 2008. However, the Support Office is not yet satisfied sufficient evidence has been produced to demonstrate that all launch requirements have been met. The IOG noted that the Support Office is continuing to work with Telecom Wholesale to confirm the delivery of the outstanding requirements.

    Separation of Systems - Issue of concern
    Telecom has developed a plan for upgrading or migrating its shared information systems to meet information separation requirements to be delivered by 31 December 2009. The plan currently does not have sufficient information to give comfort that the final 31 December 2009 completion date can be achieved. The IOG resolved to report to the Telecom Board under clause 79.1 (j) that the lack of detail contained in the plan combined with other factors was an issue of concern (The IOG wrote to Telecom outlining their concerns on 4 December 2008 and received a response pre-Christmas).

    Workforce Management Interim Milestone
    The IOG noted that the Workforce Management interim milestone plan has not been finalised. Chorus has proposed updating the IOG no later than 31 January 2009 with a set of proposed milestones showing progress towards EOI compliance. The IOG has no objection to Chorus's proposal to submit a set of revised interim Workforce Management milestones showing progress towards EOI compliance, against which Telecom would regularly report.

    At Risk - DSTN Migration
    Telecom confirmed to the IOG that they were unable to migrate one customer off the DSTN service which is due for withdrawal effective 31 December 2008. The IOG directed the Support Office to further investigate in order to determine the severity of the breach. (Post meeting the IOG resolved that failure to migrate the customer by 31 December would be a trivial breach subject to the IOG reviewing Telecom's formal reporting on the status of all other migrations. This view was communicated to the Commerce Commission and Telecom pre Christmas)

    At Risk - Other 31 December 2008 Milestones
    The IOG also considered the status of Milestones due in the December quarter as reported to the IOG by Telecom. It was noted that two milestones are currently reported as at risk of achievement. These were UCLL Migration Detailed Design for Inventory Management and BUBA/EUBA Migration Detailed Design for Inventory Management. Telecom presented on these matters at the meeting.

    Telecom also reported five other 31 December 2008 quarter milestones at risk but with plans in place to resolve. Telecom agreed to provide weekly reports to the IOG Support Office on the at risk milestones.

    The IOG Support Office will continue to monitor progress towards these milestones and the results will be considered by the IOG at their next meeting on 12 March 2009.

    Audit and Assurance Reviews

    The IOG reviewed and approved the Support Office Risk Methodology and Assurance Plan to June 2009.

    The IOG reviewed two Assurance reports completed by the Support Office. The key conclusions noted by the IOG were:

    Chorus Service Order Provisioning - Service Order Management
    The IOG noted a trivial breach of clause 41(a) as a result of a failure by Chorus to ensure all persons who have or seek to have access to relevant Network Access Services use the same request form for requesting UCLL Co-location third party fibre lead-ins. The Support Office noted that some Service Providers were using different types of order forms to request the service. Chorus advised they have addressed this and now have one standard form. There was no impact on Service Providers.

    Trading Arrangements Review
    The IOG noted the contents of the Trading Arrangements review report and noted that there were no issues identified.

    Complaints and Honesty Box Summary

    Service provider complaints
    No complaints have been received by the IOG from Service Providers during the reporting period and there are no outstanding complaints from Service Providers to the IOG.

    Non-trivial breaches
    The IOG Support Office did not identify any non-trivial breaches during the reporting period.

    Investigations - overview
    The number of Honesty Box submissions is continuing to level off, with 250 submissions in September and 242 submissions in October (compared to 707 submissions in July and 316 submissions in August). The proportion of items reported directly to the IOG is also decreasing. The distribution of submissions across business units is fairly constant. The submissions primarily involve the unintentional viewing of Wholesale Customer Confidential Information by Retail staff.

    The rate at which both Telecom and IOG Support Office are closing out submissions is increasing, and the number of open submissions is reducing.

    Access to Wholesale Customer Confidential Information
    The Undertakings allow for Retail employees to continue to use Wholesale Customer Confidential Information (CCI) contained in ICMS in the ordinary course of business, provided it is not used or disclosed in a manner inconsistent with the Undertakings. This transitional clause ceases in December 2009 when Telecom is required to prevent access to ICMS except as allowed by the Undertakings.

    Retail has identified five scenarios where Retail employees are required to access ICMS Wholesale information for the purposes of their work. In each scenario, Service Providers are not disadvantaged through Retail's use of the information, and in some cases it benefits Service Providers. The IOG resolved that the five scenarios are in the ordinary course of business and do not involve use or disclosure of the information in a manner inconsistent with the Undertakings.

    Investigation and reporting process
    Due to the high volume of Honesty Box submissions, the Support Office has revised its investigation and reporting process to place greater emphasis on Honesty Box submissions which have Service Provider impact, and streamlined the review and reporting process for other submissions. Telecom is continuing to finalise its investigation processes, including investigation timeframes. Once Telecom has finalised its process, the Support Office will further review its own investigation and review processes to determine what further efficiencies can be gained and the extent to which information provided by Telecom can be relied on.

    Definition of trivial/de minimis and non-trivial breach
    The IOG noted that the Support Office and Telecom will meet to align their approaches for the categorisation of trivial/de minimis and non-trivial breaches.

    Industry Perspective

    Alan Freeth and Chris Abbott from Telstra-Clear, and George Reedy from Actrix, attended the meeting to provide the IOG with their views and expectations of the Undertakings and how they perceive Telecom are implementing them.

    Other Matters Considered

    Inventory and Service Order Management

    1. Telecom presented an amended plan for Inventory and Service Order Management. The IOG noted the plan is intended to:
      1. deliver the required outcomes in a more logical manner and better achieve Service Providers' outcomes rather than just achieving the Undertakings with no processing improvement
      2. meet the required enforceable milestones with a better quality result and reduced risk, but with resulting changes to some tracking milestones
      3. recognise that many of the Undertakings milestones are inter-dependent and offer a solution which enables delivery of a number of Undertakings milestones to be achieved in a more logical and co-ordinated way
    2. noted that failure to achieve a tracking milestone is expressly deemed not to constitute a breach of the Undertakings.
    3. agreed to monitor Telecom's compliance against the dates set out in the amended plan.
    4. directed the Support Office to advise the Commerce Commission that it has no objection to the amended plan and does not believe it will affect compliance of the ultimate enforceable milestones.

    Operational Separation Update
    Telecom presented an Operational Separation Update paper. The IOG noted that the overall compliance status is currently amber, which Telecom believes reflects the aggressive timetable signed-up to with the Government.

    Key Performance Indicators (KPIs)
    Telecom presented a revised KPI framework. The IOG agreed to recommend the framework to the Telecom Board, noting that the KPIs are likely to be further developed in future months as both Telecom and the IOG react to issues that will inevitably arise from implementing the framework. (On 11 December 2008 the Telecom Board approved the KPI framework and the first KPI report was subsequently published on the Telecom website).

    Commerce Commission Protocol
    The IOG have received a draft protocol from the Commerce Commission outlining an approach for how the IOG and Commission could work together. The IOG provided feedback to the Support Office and asked that they revisit the protocol at the 12 March 2009 meeting.

    Post Meeting Communication
    After the meeting the IOG instituted a policy to write to Telecom and the Commerce Commission outlining key decisions made at each meeting. A letter outlining the relevant matters from this meeting was provided to both parties prior to Christmas.

    Briefings from Telecom
    The IOG received briefings from Telecom on Inventory and Service Management, Primary Line Migration, Chorus EOI Update and Wholesale December 2009 requirements.

     

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