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Systemic Issues



1.0 Identifying a systemic issue

2.0 Notification of a systemic issue

3.0 Commencing an investigation

4.0 Working towards resolution

5.0 When a resolution cannot be agreed or is not implemented

6.0 Reporting on systemic issues


The purpose of this Procedure is to provide a framework for our monitoring, investigation and resolution of systemic issues.


In addition to resolving individual Complaints, we also look at issues that may affect a number of a provider's customers. 

We handle systemic issues under the Terms of Reference

The Terms of Reference define a systemic issue as a concern about a system, process or practice of a provider or providers that may or does affect a significant number or particular type of consumers. We can handle a systemic issue with or without a Complaint.

The systemic issues procedure has four stages:

  • Identification - identifying and assessing a systemic issue
  • Notification - notifying a provider about a systemic issue and when appropriate, seeking a response
  • Investigation - investigating a systemic issue and working with the provider to resolve it
  • Report - reporting on systemic issues.                                  

1.0 Identifying a systemic issue


We identify systemic issues through a range of methods, including through:

  • handling a Complaint or Complaints 
  • analysing complaint trends, or 
  • receiving other information that may suggest a systemic issue. This could include information from consumers, the media or regulators.  

2.0 Notification of a systemic issue


When we identify a systemic issue we will:

  • quickly and informally highlight the issue directly with the provider 
  • start discussions with the provider about the impact of the issue on Complaints or Enquiries, and  
  • ask the provider for a response.


When the provider’s response is received we will decide if any further action on the issue is required. This may include investigating, monitoring, or taking no further action on the issue.

3.0 Commencing an investigation


When we decide that a systemic issue warrants investigation, we will notify the provider in writing and ask for a response in writing. The purpose of the investigation is to assist us to fully understand the systemic issue and any options to resolve it.


The written notification to the provider will outline the nature of the systemic issue, and may include the following:

  • questions to help us assess the nature of the issue, its causes and the level of consumer detriment
  • requests for information and evidence including data, contracts, voice recordings, and policy and procedural information
  • suggestions about how the systemic issue could be resolved 
  • an offer for us to speak and meet with the provider to discuss the systemic issue and help with a possible resolution
  • a timeframe to provide a written response.


At any time during our investigation we may request further information about the systemic issue. 

4.0 Working towards resolution


During an investigation, we will work with the provider, including through consultation and negotiation, to reach an agreed resolution. 


When the provider agrees on a resolution, it must implement the resolution within an agreed timeframe.


We will monitor Complaints relating to the systemic issue for an appropriate time after the investigation to assess the effectiveness of the agreed resolution and its implementation.  

5.0 When a resolution cannot be agreed or is not implemented


If, after an investigation, an agreed resolution of a systemic issue cannot be reached or if an agreed resolution is not implemented, we will determine what further action is necessary. This may include: 

  • making recommendations to the provider for resolving the issue. Under the TIO Terms of Reference, the provider must consider our recommendations and take steps to resolve the issue
  • reporting the systemic issue to the Chief Executive Officer of a provider, with the expectation that the issue and any recommended resolution be further considered, or
  • referring the systemic issue to an appropriate regulator, for example, the ACMA, the ACCC, the OAIC or another appropriate body. 


We will notify the provider when we formally refer the systemic issue to a regulator.

6.0 Reporting on systemic issues     


We will regularly report on our work in handling systemic issues. This includes:

  • providing information as requested by the ACMA, the ACCC, or other relevant regulators about systemic issues
  • providing information to providers or their representative organisations, and
  • reporting to the community including in the Annual Report, on the TIO website and through regular publications.


Effective date: 5 July 2010

Updated on: 30 November 2014

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