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Disability Action Plan 2013 - 2016 (HTML)


About the TIO

The current environment

Key findings and lessons

Action plan

Action plan tables

Appendix 1


I would like to dedicate this, our third Disability Action Plan, to the memory of the Reverend Dr Christopher Newell AM, who served on the TIO’s Council as a representative of the Australian Federation of Disability Organisations.

Christopher, who lived with an illness that caused him to be wheelchair bound, was the driving force behind the TIO’s first and second disability action plans. Our second disability action plan formally concluded in 2010. But many of the lessons that we learned are being continually applied in our work today.

Some of the major deliverables of our second plan were:

  • our website, which meets WCAG 2.0 A standard, was delivered in September 2011.
  • a significant training program, which included disability awareness, deaf awareness and National Relay Service training
  • an outreach program through which the TIO attended conferences and visited organisations that represented people with disabilities.

Since the advent of our last plan in 2007, the telecommunications industry has changed substantially, offering challenges and benefits for people with disabilities. The underlying principle of this plan is inclusion. Through it we aim to capitalise on the diversity and dedication of our staff, the creativity of our member companies and the cooperation of our external stakeholders to provide a first-class complaint resolution service for all Australians.

Simon Cohen


October 2013

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About the TIO

The TIO operates with a vision to deliver an exceptional telecommunications dispute resolution service for consumers, service providers and the Australian community. It also aims to contribute to better customer service and complaint handling within the telecommunications industry.

The TIO plays four main roles in the telecommunications industry:

  • Resolving disputes: the TIO’s first and primary role is to provide a dispute resolution service that is accessible, independent, fair, efficient, responsive and effective.
  • Improving telecommunications services: the TIO assists telecommunications service providers and their industry to improve their services to consumers, through identifying systemic issues and engaging with industry representatives.
  • Being an independent voice: the TIO is an independent and expert voice about matters affecting telecommunications consumers. We provide information and analysis to government and industry, and reach out to the community.
  • Leading by example: the TIO is innovative, adaptable, collaborative, responsive, resilient and forward thinking. We value very highly the work of our people and support their ongoing development of knowledge and skill.

These roles are articulated in our strategic plan and are the building blocks for our action plan. LINK

The TIO is the elevated complaint handling body for the National Relay Service

This is the third disability action plan for the TIO and seeks to deliver maximum service benefit for people with disabilities and cultural growth and development for the TIO.

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The current environment

The Australian Bureau of Statistics (ABS) records that one in five Australians have a disability – that’s close to four million Australians. Further, over six per cent or 1.2 million Australians have a profound or severe level of core activity limitation, and the rate of disability increases with age.

65% of people with a disability would consider moving to a service provider that shows leadership in providing disability confident customer service (Australian Network on Disability, 2012).

5.5 million Australians are carers of children, ageing parents and family members with disabilities or health issues (Australian Human Rights Commission, 2013 as sourced from the Australian Bureau of Statistics).

Disability by age
Age groupLikely to have a disability
Aged 151 in 15
Aged 251 in 10
Aged 451 in 5
Aged 601 in 3
Aged 751 in 2

92% – of primary carers for children with disability are women (Australian Human Rights Commission, 2013 as sourced from the Australian Bureau of Statistics).

Telecommunication services play a vital role in the lives of all Australians. They facilitate business, employment, community participation and social interaction. However, some people with disability find it difficult to make effective use of telecommunications services.

Legislative context

There are four important Acts and policies that inform the development of disability action plans within the telecommunications industry. They are:

  • TheDisability Discrimination Act 1992 provides protection for everyone in Australia against discrimination based on disability.
  • TheTelecommunications (Consumer Protection and Services Standards) Act 1999 mandates a Universal Service Obligation to ensure that standard telephone services are reasonably accessible to all people in Australia on an equitable basis and internationally.
  • The United Nations Convention on the Rights of Persons with Disabilities.
  • The Federal Government'sNational Disability Strategy, launched on 18 March 2011, which sets as a policy direction the need for communication and information systems to be accessible, reliable and responsive to the needs of people with disability, their families and carers.

Dispute resolution schemes

As part of the preparations for this plan, the TIO reviewed practice in other Ombudsman schemes. No industry dispute resolution schemes have disability action plans.

In 1997 the Commonwealth government facilitated the development of a set of benchmarks to guide industries to develop and improve complaint resolution schemes. There are complaint resolution schemes for banking, telecommunications, insurance, and energy and water.

The benchmarks were developed to apply primarily to nationally-based customer dispute schemes set up under the auspices of an industry and drafted primarily with a focus on individual consumers as users of the schemes.

The benchmarks have a three-fold purpose.

  • They act as a guide to good practice for those industry sectors with a scheme to resolve disputes between their industry members and individual consumers of their goods or services.
  • They provide objective guidance on the practices to aim for in the operation of complaint resolution schemes.
  • They serve as a guide for consumers in giving them some idea of what they should expect from such schemes.

The principles


The scheme makes itself readily available to customers by promoting knowledge of its existence, being easy to use and having no cost barriers.


The decision-making process and administration of the scheme are independent from scheme members.


The scheme produces decisions which are fair and seen to be fair by observing the principles of procedural fairness, by making decisions on the information before it and by having specific criteria upon which its decisions are based.


The scheme publicly accounts for its operations by publishing its determinations and information about complaints and highlighting any systemic industry problems.


The scheme operates efficiently by keeping track of complaints, ensuring complaints are dealt with by the appropriate process or forum and regularly reviewing its performance.


The scheme is effective by having appropriate and comprehensive terms of reference and periodic independent reviews of its performance.

The principles underpin the service delivery of the TIO and are inherent in the actions of the DAP.


Successful DAPS are the result of considered and extensive planning and preparation.

The development of this DAP has included:

  • a review of best practice around the world and the identification of key learnings and strategies
  • consultation with all key internal (Council members, Executive and staff) and external stakeholders from the telecommunications and disability sectors
  • a survey of staff and stakeholders
  • feedback on the draft plan with the TIO Disability Action Committee and key stakeholders

Monitoring and evaluation

This DAP will be delivered by the Disability Action Committee at the TIO.

The review of the DAP will become a standing agenda item at each quarterly meeting of the Disability Action Committee and an annual report will be produced independently and provided to the TIO Council (or in the event the Council ceases to exist, the Board) as part of their ongoing governance role.

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Key findings and lessons

This information was gleaned during the development of the TIO’s Third Disability Action Plan. Telecommunications accessibility varies around the world. Australia is well advanced in research and philosophy. However, it is behind in action.

People with disabilities rely on industry to introduce technological advances into accessible practice. Delay in doing so impedes the human rights of people with disabilities. There is an overwhelming amount of research into best practice for people with disabilities.

The next iteration of DAPs (evidenced by what is occurring in the United States) is focused on how to create diversity and maximise inclusion in the workplace rather than how to "deal" with a diverse workplace. Progressive organisations seek to influence others through vehicles such as procurement policies and enable through proactive recruiting policies.

Lots of plans are still "going through the motions" – at a very low evolutionary stage. Leadership is key. The most evolved plans focus on leadership to enable cultural change.

Best-practice plans ensure ownership is included and assured through performance plans. Proactivity is in best practice plans – creation of networks, active recruiting, links to values and behaviours

Best practice organisations have quotas for people with disabilities and other minority groups. If your market is diverse, then to lead and understand that market you must be diverse from within.

There is great variety around the world in approaches – legislation is in place, it’s the implementation that varies. The United States based global corporates are leading the world – focusing on inclusion and proactively seeking diversity.

TIO staff survey outcomes

More than half the current staff of the TIO were unaware of the existence of the previous DAP and staff were not aware of reporting.

Action: More staff awareness through reporting and socialization of the plan is required.

The most successful activities of the previous DAP (as viewed by employees) were the establishment of the new website and disability awareness training.

Responsibility for actions in the previous DAP were viewed as belonging to a very small number of people across the business and were not included in performance plans.

Action: Broaden ownership of DAP goals to all employees through links to the TIO strategic plan, ownership by Disability Advisory Committee and actions included in performance plans

Two of the major challenges for staff in assisting people with disabilities are equipment or tools that do not support the complainant or the staff member or a lack of understanding of the process by the complainant.

Action: Staff training and improved clarity of complaints process for TIO members, consumers and TIO employees

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Action plan

Objectives and strategies

An over-arching theme resulting from consultation was the interaction and engagement of the TIO with its key stakeholder groups including people with disabilities. The establishment of a critical friends group with a benchmark accountability to represent key customer groups of the telecommunications sector will provide a voice directly to the TIO.

The TIO is committed to promoting inclusion for people with disability and ensuring that they have equal awareness of, and access to, our service. The TIO Disability Action Plan identifies actions which, as well as being aligned with our broader business strategy, will mean the TIO fulfils its obligations under State and Commonwealth laws to eliminate discrimination based on disability.


  1. People with disabilities are aware of, and have equitable access to, the TIO
  2. People with disabilities have a voice, influencing how the TIO delivers its own services, and how it provides key consumer information to industry about the disability issues sector.
  3. The TIO promotes an organisational culture that is responsive to the needs of people with disabilities.

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Action plan tables

Leading by example

Where we want to be

An organisation that scans our environment and responds to our stakeholders' needs through innovative strategies and work practices.

Engaged people who are highly motivated in their roles, and continuously learning.

Action Plan - Leading by example
ActionPerformance indicatorResponsibilityTimeframe
Establish a Critical Friends Group composed of people with disabilities to ensure that the TIO is actively engaged with the disability sector.Critical Friends Group meets annually and works effectively to identify and discuss emerging disability issuesDisability Action Committee led by the Community Liaison ManagerAnnually with first meeting to be held by June 2014
Develop a recruiting strategy to identify positions which are suitable for employment of persons with a disability.Employ a person(s) with a disability during the life of the planManager People and Development

Strategy by June 2014

Recruitment by June 2015

Consult with staff members who advise the TIO of disability issues, about how those issues affect their employment or the employment of their colleagues.Report completed each year to satisfaction of Council and Executive. Executive to consider and decide on any recommendations from the report within three months. Manager People and Development

June 2014

June 2015

June 2016

Review TIO practices to identify potentiallydiscriminatory practices and opportunities to promote inclusionReview to be completed to satisfaction of Council and Executive. Executive to consider and decide on any recommendations from the Review within six months.Manager People and DevelopmentSeptember 2014
Establish terms of reference for the Disability Action Committee (DAC). Review membership of the committee periodically to ensure that appropriate business units and expertise are represented. A committed and engaged DAC that will be responsible for the deployment and monitoring of the disability action plan. DAC responsibilities to be incorporated into individual performance plans. Disability action committee to meet monthly.Executive Director -Industry Community and GovernmentCommittee members to be in place by October 2013
Develop a community awareness strategy that delivers a consistent schedule of engagement with key stakeholder groups.A communications plan is developed which incorporates feedback from the Critical Friends Group. Opportunities to increase access to, and for, people with disabilities are explored through liaising with other Ombudsman schemes and through potential partnering.

Community Liaison Manager to coordinate.

All divisions within TIO to participate.

Annual calendar to be completed by December each year.
Review the TIO brochures to ensure that they are accessible by people with vision disabilities. Develop revised audio versions of the TIO's promotional materials. Develop accessible versions of this plan.Revised audio files to be uploaded on the website by June 2014

Community Liaison Manager 

Communications Officer

June 2014
Annually review for potential improvements to office accessibility for people with disabilities. TIO arranges for    annual, independent review of our offices and develops appropriate action plans for substantive recommendationsAdministration and Facilities manager

Jan 2014

Jan 2015

Jan 2016

DAC reports annually to the Council (in the event the Council ceases to exist, the Board) and TIO Executive about progress against the DAP and to identify emerging consumer issuesReport completed to satisfaction of Council and Executive

Executive Director -Industry Community and Government

Community Liaison Manager

June 2014

June 2015

June 2016

Review plan annually and at completion, report to the TIO Executive and the Critical Friends Group. Satisfactory report from reviewer Independent review to occur at end of plan


Executive Director - Industry, Consumer and Government

June 2014

June 2015

June 2016

Resolving disputes

Where we want to be

Increase TIO accessibility through:

  • increased hours of operation
  • appropriate use of new technologies
  • appropriate guidelines to determine if matters referred or conciliated at first instance
Resolving disputes
Action Performance indicatorResponsibilityTimeframe
Ensure that all complaint channels are accessible by people with disabilities. TIO will monitor and refine complaint channels to ensure they are accessible for people with disabilities. Annual review of complaint channels with Critical Friends Group

Deputy Ombudsman

Manager – Dispute Resolution Operations

June 2014

June 2015

June 2016

Online channel to meet best practice accessibility guidelines.TIO website to be WCAG 2.0 AA compliant. Social Media platforms to meet equivalent of WCAG 2.0 AA standard. All documents posted to TIO website to be available as html, MS Word, PDF and rich text formats.

Communications Manager

Online Communications Officer

December 2014
Establish a proactive training program to ensure staff understand the diversity of disabilities and the specific communications issues for people with different disabilities.Establishment of an efficient and effective training program that runs through the life of the disability action plan.

Manager – Dispute Resolution Quality

Learning and Development Officer

Training program to commence by July 2014

An independent voice

Where we want to be

We want to continue to be smart users of new media to increase the accessibility of our information and awareness of our services.

An independent voice


Performance indicator



TIO publicises information about disability issues and about industry improvement activities it has undertaken

Consumers are informed through bi-annual articles in TIO publications about emerging issues and how TIO has sought to address them

Community Liaison Manager

Communications Officer

Two articles per annum in 2014/15/16

Establish an up-to-date Communications - Community Relations database.

Existing TIO Talks database to be reviewed and segmented into target audiences, ie:

  • financial counsellors
  • disability advocacy organisations
  • CALDgroups
  • serviceproviders
  • regulators
  • Indigenousservice providers

Community Liaison Manager

Review to be completed by December 2013
Segmentation to be completed by March 2014

Establish a mailing list of disability related organisations in Australia

Ensure that 20% of all disability-related organisations subscribe to TIO Talks database during the life of the plan.
Attain a click through rate of 15% on all TIO Talks articles from disability related groups.


Community Liaison Manager.

Mailing list to be established by February 2014

20% target to be achieved by June 2014

Click through rate to be established by December 2014

Improving telecommunications services

Where we want to be

More effective and responsive use of TIO information – including complaints, statistics and other intelligence – to identify and act or root causes of detriment to consumers (as evidenced by complaints to the TIO.)

An identified role for the TIO to build the capacity of TIO members and the telecommunications industry, to more effectively respond to consumer complaints.

Improving telecommunications services
ActionPerformance indicatorResponsibilityTimeframe
TIO analyses complaints data and information provided by disability consumer advocates to identify accessibility and other issues affecting consumers with disabilities, and to raise these issues  with Industry.TIO Industry Improvement Team analyses complaints data and reports to Disability Action Committee quarterly on disability issues.Industry Improvement TeamQuarterly during life of plan

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Appendix 1

Review of the TIO Second Disability Action Plan

The second plan focused on five key areas and identified actions required in each of these areas. The areas were:

  • organisational culture: to develop and maintain a responsive and non-discriminatory organisational culture
  • accessible information: to improve accessibility to information about the TIO’s services
  • accessible complaint resolution services: to provide equitable access to the TIO’s complaint resolution services
  • physical environment: to ensure that the TIO’s physical environment is accessible to all
  • monitoring and evaluation: to ensure that the DAP is regularly reviewed and evaluated.

The second plan achieved a number of significant goals, some of which are outlined below. Several other initiatives, which were not part of the second plan, were achieved subsequent to its completion in 2010.

Objective 1 – organisational culture

Staff training

Extensive training was conducted during the life of the plan and shortly after its completion. At the commencement of the plan, all TIO staff received disability awareness training. In 2011, VicDeaf conducted training in deaf awareness and the operation of the National Relay Service.

EEO employment

The TIO’s recruitment policy was updated in November 2011. All TIO employment advertisements encourage people with disability to apply. We have worked with specialist employment agencies that provide employment for people with disabilities. To date no suitable candidates have been identified.

Updated versions of the Equal Employment Opportunity (EEO) and Occupational Health and Safety policies (OH&S) have been approved.

Objective 2 – accessible information

Since the inception of the second plan, all promotional information, with the exception of our brochure in languages other than English, has been produced in consultation with Vision Australia. All promotional material is also available on our website in audio formats.

Although not specifically related to people with disabilities, the plan required the TIO to review, update and make available fact sheets in languages other than English. During the course of the plan, 31 fact sheets have been produced. The same information has produced in a brochure. A total of 50,000 of these brochures have been distributed nationally.

During the life of the plan, the Community Liaison Manager produced a fact sheet, Consumers with Disabilities and the TIO, which was distributed nationally. The Community Liaison Manager also met with key government officials in all the eastern states. We communicated similar information to their counterparts in other states by email.

Since the inception of the plan and beyond, the TIO has also regularly attended at least three conferences each year involving people with disabilities


The website, which was unveiled in September 2011, was developed to meet Web Content Accessibility Guidelines 2.0 (WCAG) standard Level A with Level AA where possible. Since its inception, a number of features have been added to the site to make it more accessible for people with disabilities. This includes an Auslan video, produced in cooperation with VicDeaf.

Objective 3 – accessible complaint resolution services

More than a third of new complaints to the TIO are lodged via the online form on our website. In 2012, the TIO worked with Vision Australia during the development of the online form by Resolve, the software vendor for our Radar complaints management system. Resolve has assured us that the form meets WCAG 2.0 Level A and will meet Level AA in 2014.

During the life of the plan, the TIO met formally with several advocacy groups for people with disabilities. Of note were several conversations with the Australian Communications Consumer Action Network. These organisations provided information to allow us to identify barriers to accessibility and modify our processes accordingly.

Objective 4 – physical environment

A disability access audit of our premises was conducted in June 2009. The TIO has made many of the changes recommended by this audit on a one-off basis. Others were made during regular maintenance work.

Objective 5 – monitoring and evaluation

Several performance measures were developed to evaluate the plan. They were:

  • the number of formal staff and complainant grievances relating to disability access
  • the number of grievances dealt with efficiently and effectively with positive outcomes
  • awareness of the TIO among people with disabilities according to TIO public awareness survey
  • feedback from people with disabilities and disability groups regarding accessibility of the TIO to people with disabilities
  • the disability action plan is monitored and reviewed on an ongoing basis
  • the disability action plan is evaluated and revised as required
  • rather than focussing on raising awareness directly with consumers, with the second plan the TIO resolved to focus on intermediary groups representing those consumers
  • the plan was monitored by the TIO's Disability Action Committee, with occasional reports provided to the Ombudsman and Board.

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Excess data charges

Excess data charges

An received a bill with $3,200 in excess data charges, but didn’t believe she had actually exceeded her data limit.

Next step?              

  • make an online complaint
  • 1800 062 058                
  • Write PO Box 276
    Collins Street West Vic 8007                            
  • National Relay Service Call on 1800 555 677 then ask for 1800 062 058            
  • Fax our consumer complaint form to 1800 630 614