Systemic issues

A systemic issue is a problem that can affect more than one consumer. We identify possible systemic issues through alerts from TIO officers and data analysis that shows a number of consumers lodging similar complaints about a product or service. A single complaint may indicate a systemic problem if the cause is likely to affect all consumers with the same product or service.

The causes of systemic issues are usually addressed quickly by alerting providers about possible problems in their systems, procedures or business practices. This results in fewer difficulties for consumers and fewer complaints to service providers and the TIO.

If we do not believe that a systemic problem has been resolved, we may investigate it and refer it to an industry regulator.

Systemic issues in 2014-15

We looked into 50 systemic issues in 2014-15. Although the number of total systemic issues was fewer than the 73 examined in 2013-14, we conducted a total of 20 informal and formal investigations compared to only seven last year.

Type of intervention
Informal notification
Formal or informal investigation

Types of issues we looked into

Systemic IssuesSome of the issues we looked into were:

  • disclosure of personal information to third parties
  • accuracy of product advertisements
  • potentially unfair administration fees
  • direct debits without authorisation or sufficient notice
  • variation of contract terms, and
  • unauthorised transfers resulting from misleading sales practices.

Results of our interventions

Most systemic issues were resolved by the service provider after we brought the issue to their attention. Examples include:

  • improvements to technical systems and procedures – including privacy procedures and protection of customers' personal information
  • review of telemarketing scripts and the introduction of quality assurance programs
  • improved accessibility for consumers with special needs
  • changes to advertising material, and
  • better advice to customers about expected connection times.

Referral to regulators

We formally referred four systemic issues to the Australian Communications and Media Authority and the Australian Competition and Consumer Commission. We also raised concerns with these regulators about a further 10 issues, including:

  • privacy and protection of customers' personal information
  • telemarketing practices
  • misleading sales information
  • incorrect billing
  • unfair contract terms, and
  • compliance with consumer guarantees under Australian Consumer Law.