Introduction
This document is the IPSTAR Australia Pty Limited (“IPSTAR”) Credit Management & Financial Hardship Policy, prepared for the purposes of Chapter 6 of Communications Alliance Ltd Industry Code Telecommunications Consumer Protections Code C628:2012 (“the Code”).
Chapter 6 of the Code requires Carriage Service Providers such as IPSTAR to, among other things:
- Undertake appropriate credit assessment;
- Provide credit control tools;
- Implement credit management processes; and
- Have a financial hardship policy.
The provisions of this document set out the policies of IPSTAR in relation to the above matters. This document is not a substitute for the Code, and is not intended to be an exhaustive list of Customers’ or IPSTAR’s rights and obligations under the Code. This document should be read in conjunction with the Code. A copy of the Code can be downloaded from the Communications Alliance Ltd website at http://www.commsalliance.com.au/
Application of this policy
This policy only applies to our customers who are end users of our Internet Services.
Credit assessment
If a Customer applies to IPSTAR for the supply of telecommunications services, IPSTAR will, either:
- Undertake an appropriate credit assessment to determine whether to supply a Service to the Customer where such credit assessment will consist of IPSTAR requesting a credit worthiness report from Veda Advantage Information Services & Solutions Limited.
- Supply a Service which includes measures to effectively limit the Customer’s expenditure or usage by implementing:
- A hard cap;
- A pre-paid service;
- Reducing broadband internet download speed or reaching a limit; and/or
- Any other equivalent measure.
In applying for a Service from IPSTAR you authorise IPSTAR to obtain information from credit reporting agencies. If we refuse to supply you with Services due to information we receive from a credit reporting agency about you, we will provide you with the information required under paragraph 6.3 of the Code.
IPSTAR will only provide Services to Customers who meet the IPSTAR credit approval criteria.
Results of credit assessment
If access to Services is restricted by IPSTAR as a result of a credit assessment and restricted services have not previously been supplied by IPSTAR to the Customer, IPSTAR will inform the Customer at the time of imposing any such restrictions:
- Of the restrictions or conditions to be imposed upon access to the Service;
- Of the general nature of the reasons for the restrictions being imposed;
- If applicable, how the Customer may access Services which have been restricted; and
- Any other information required by paragraph 6.3 of the Code.
IPSTAR reserves the right to require a formal guarantee from a third party as security for payment of fees associated with any Service.
Credit control tools / spend management / security tools
Upon request, IPSTAR will notify Customers about the availability of security tools to prevent unauthorised access to or use of Services, how to obtain assistance in using such security tools, and the cost of any security tools offered by IPSTAR, if any.
Details of any options for restricting access to Services will also be listed on our website at
- https://ipstarbroadband.com.au/
If a Customer requests a suspension to a Service, fees or charges Maybe payable during the period of suspension: These are outline in the SFoA that can be found at https://ipstarbroadband.com.au/legal/
A suspension of the service will only be allowed for 3 months. Should you require a longer period, please contact IPSTAR and we will consider your request.
Unbilled amounts
IPSTAR will provide Customers with access to current information regarding any unbilled amounts on their accounts. Information on unbilled amounts can be obtained by telephoning IPSTAR on 1300 464 778 six (6) days per week (Monday – Saturday) during normal business hours Australia-wide.
Credit management action
IPSTAR have implemented processes to assist Customers who are experiencing difficulties paying their accounts, including via the Financial Hardship Policy sections of this document detailed below.
IPSTAR reserves the right to refer Customers’ debts to debt collection agents and for listing a Customer default with a credit reporting agency, and in obtaining Services from IPSTAR, Customers agree and acknowledge IPSTAR’ credit management action rights in that regard. However, IPSTAR will carry out credit management action prior to referring the Customer debt to a debt collection agent or listing a Customer default with a credit reporting agency.
Prior to taking credit management action, IPSTAR will also advise the relevant Customer of the general nature and effect of:
- The time they have to pay for Services;
- Their obligation to pay by the due date;
- Any processes IPSTAR has for:
- Interim billing or changes in the billing cycle for credit management purposes;
- Follow up of overdue accounts; and
- Assisting Customers who are experiencing difficulties in paying their accounts, including IPSTAR’ Financial Hardship Policy;
- Part payment of a bill in circumstances where a number of Services are combined on one bill, and any method for allocating amounts received;
- The reasons for IPSTAR’ actions,
and IPSTAR will provide the Customer with any other information it is required to provide under the Code.
Prior to suspending or disconnecting a Service in the course of carrying out credit management action, IPSTAR must ensure that Customers are given adequate notice (at least five (5) Working Days) of its intention to Restrict, Suspend or Disconnect a Customer’s Service. IPSTAR will also make reasonable attempts to advise the Customer of:
- The role of community financial counsellors and consumer advocates in dealing with financial matters;
- Options in respect to repayment processes;
- The effect non-payment may have on other Services the Customer has with IPSTAR,
and IPSTAR will provide the Customer with any other information it is required to provide under the Code.
In certain circumstances, we may suspend or restrict access to Services without notice. This includes where we:
- Assess that the Customer or the account status presents an unacceptably high credit risk to us; or
- Reasonably suspect fraud or attempted fraud.
We will not take credit management action in relation to genuinely disputed amounts while the dispute is being investigated and remains unresolved by us, the Telecommunications Industry Ombudsman or relevant recognised agencies.
Financial hardship assessment
Financial hardship means a situation where:
- Due to reasonable cause, a Customer is unable to discharge their financial obligations under their contract with IPSTAR; and
- The Customer reasonably expects to be able to discharge those obligations if payment or Service arrangements are changed.
Financial hardship can include circumstances where Customers may be unable to comply with their financial obligations under the Agreement, for example, due to Customer illness. In certain circumstances IPSTAR may be able to accommodate Customers who are experiencing financial hardship by adjusting their payment and/or Service arrangements.
Upon a Customer’s request, IPSTAR will assess a Customer’s eligibility for assistance under the IPSTAR Financial Hardship Policy as set out in this document. IPSTAR, in undertaking that assessment, will take into account the Customer’s individual circumstances. IPSTAR will not charge for the assessment, or for implementing any financial hardship arrangements.
IPSTAR may require supporting documentation in order to consider an application by a Customer for assistance under the IPSTAR Financial Hardship Policy.
Each application for consideration under the IPSTAR Australia Financial Hardship Policy is assessed individually on its merits.
Financial hardship arrangements
IPSTAR will ensure that any financial hardship arrangements agreed with a Customer are sufficiently flexible to take account of the Customer’s individual circumstances.
Some of the options that IPSTAR will consider implementing under a financial hardship arrangement include:
- Waiving disconnection, suspension and/or reconnection fees;
- Waiving late payment or interest fees;
- Agreeing to the payment of a Customer’s debt within a specific timeframe.
If IPSTAR approves a financial hardship arrangement, IPSTAR will:
- Inform the Customer of the agreed terms of the financial hardship arrangements;
- Ensure the Customer is aware of their rights and obligations under any financial hardship arrangement;
- At the time a financial hardship arrangement is implemented, advise the Customer to contact IPSTAR if the Customer’s circumstances change during the term of the arrangement; and
- Be willing and able to review the arrangements if the Customer’s circumstances change.
Financial hardship policy information
IPSTAR will ensure that it has staff who are trained in applying and processing its Financial Hardship Policy. Customers who require any information concerning the IPSTAR Financial Hardship Policy can contact IPSTAR by telephone on 1300 464 778. When calling, please ask to speak to one of our trained financial hardship policy staff.
Our trained financial hardship policy staff will discuss with you options for managing financial hardship, and will provide you with a copy of a summary of how the IPSTAR Financial Hardship Policy may assist Customers. The summary will be provided on the Customer’s request, when the Customer indicates they are experiencing financial hardship or if IPSTAR considers the Customer may be eligible for the policy.
During discussion of any financial hardship arrangements, IPSTAR will not undertake credit management action in relation to the relevant Customer’s account, unless:
- The Customer breaches the terms of the financial hardship arrangement. In that event, if the Customer does not contact IPSTAR to discuss a new arrangement, IPSTAR will take reasonable steps to contact the Customer before taking credit management action;
- It would be reasonable in the circumstances; or
- The Customer agrees at that time.
Further options
There are a range of free financial counselling services offered in each state and territory in Australia that can assist you with information about financial difficulty.
National
National Debt Helpline
Phone: 1800 007 007
Website: www.ndh.org.au
Website: www.financialcounsellingaustralia.org.au
New South Wales
Legal Aid New South Wales
Phone: 1300 888 529
Website: www.legalaid.nsw.gov.au
Queensland
Financial Counsellors Association of Queensland
Phone: 1800 007 007
Website: www.fcaq.com.au
Tasmania
Anglicare Financial Counselling Service
Phone: 1800 243 232
Website: www.anglicare-tas.org.au
Hobart Community Legal Service
Phone: 1800 232 500
Website: www.hobartlegal.org.au
Rural Business Tasmania
Phone: 1300 888 276
Website: www.ruralbusinesstasmania.org.au
Victoria
Finanacial & Consumer Rights Council
Phone: 03 9663 2000
Website: www.fcrc.org.au
Western Australia
Financial Counsellors Association of Western Australia
Phone: 08 9325 1617
Website: www.financialcounsellors.org
South Australia
The South Australian Financial Counsellors Association
Phone: 1800 007 007
Website: www.safca.org.au
Customer credit information
Subject to the provisions of the Privacy Act, IPSTAR will ensure that Customers can obtain information held by it relating to their credit history or credit standing. IPSTAR will not impose a cost on supplying that information, except for abnormal supply costs, or where the fee or charge is not excessive and IPSTAR has informed the Customer at the time of, or prior to, imposing the fee or charge of the amount or method of its calculation.
Complaint Handling Process
At IPSTAR we pride ourselves on offering our customers a high level of service. Our goal is to resolve any customer concerns in the first instance wherever possible. However, we do recognise that, on occasion we made not meet the expectations of our customers. In which case, our customers may wish to express their dissatisfaction with our products, staff or services.
Our goal is to deliver an efficient resolution to any complaint that our customers may receive. Depending on the nature of the complaint our goal is to resolve all complaints in a fair and reasonable manner within 10 business days. Typically you can expect resolution in less than 5 business days. In the case of urgent complaints, we aim to resolve these complaints in a fair and reasonable manner within 2 business days.
In order to assist you in tracking a complaint, you may request a reference number at any stage of the complaint handling process.
Logging a complaint
Our frontline staff are trained to resolve the overwhelming majority of complex issues that our customers may from time to time experience. In some instances it may not be possible to resolve an issue immediately, but you can expect our staff to keep you updated (within the timeframes set out above) as to the progress of your issue. This is especially the case where the issue is more complex or requires third party intervention. Our frontline employees are trained and skilled to typically resolve the vast majority of customer issues in the first instance, without further escalation. At this level you can typically expect a response to your issue within 2 business days.
Escalating a Complaint
In instances where our frontline staff are not able to resolve your complaint it can be escalated to a Team Leader. In many instances a team leader will be instantly available to intervene. However, on occasion this might not be possible immediately. In these cases we will request your account and preferred contact details.
An IPSTAR team leader will attempt to contact you to work towards resolution as soon as reasonably possible and within two business days.
Further Escalation
In rare instances it may not be possible for the frontline staff member or team leader to resolve your issue to your satisfaction in which case the team leader assigned to resolving your issues will advise you. They will then escalate the issue to the relevant manager internally (where the issue resides entirely within IPSTAR), or externally (where the issue may reside with a third party). You contact point within IPSTAR will remain the team leader assigned to your case.
Complaints at this level are typically complex and may require third party intervention. We aim to resolve these complaints within 5 business days. In rare instances, it may require 15 business days; typically most complaints are resolved in less than 5 business days, however some issues may involve third party negotiations and investigations. This may delay resolution. In these cases we will remain in contact with you and provide regular updates. Should we not be able to adhere to this timeframe, we will keep you updated as to the progress of the issue.
Contacting IPSTAR to Lodge a Complaint
IPSTAR offers a number of ways for you to lodge your complaint free of charge.
Telephone
We can be contacted on 1300 464 778 free of charge. We are open 08.00 to 19.00 Monday to Friday, and 09.00 to 17.30 on Saturdays. We are closed on NSW Public Holidays.
Calls from mobile phone services may not be free. You are advised to check with your provider.
Where customers have access to the internet, we can be contacted at this email address [email protected]. Your internet service provider may charge you for the cost of data. You are advised to check with your provider.
Post
We can be sent a letter postage free at the below address. IPSTAR will cover the cost of postage.
IPSTAR Australia
154 Pacific Highway St Leonards New South Wales 2065
Next Steps
Most customer issues are resolved by following the above steps. However should you remain dissatisfied with how your issue has been handled, as a last resort the Telecommunications Industry Ombudsman (TIO) can provide independent advice. The TIO is an office of last resort and deals with complaints that consumers have not been able to resolve with their telecommunications provider after exhausting all possible avenues within the company.
Should you wish to contact the TIO, there contact details are available here http://www.tio.com.au/about-us/contact-us
Should you wish to contact the TIO, we recommend that you exhaust all other escalation paths first. When an escalation is handled internally, without external intervention of a third party (in this instance the TIO), we are able to communicate directly with our customers. We genuinely want to resolve customer issues and in many instances mediation can slow down the resolution process.
IPSTAR also recognises your right to contact your local Office of Fair Trading (or equivalent).
Updates on your escalated issue
IPSTAR are happy to provide you with reasonable and regular updates on your escalated issue. We will notify you with regular updates on your unresolved issue. When speaking with your IPSTAR representative or team leader, please let us know your preferred communication method and we will be happy to negotiate how and when we keep you updated.
Defining Urgent Complaints
We recognise the need to respond to and resolve all complaints as quickly and efficiently as possible. However from time to time we acknowledge that some customers may experience an issue of a very urgent nature. We aim to resolve such complaints within 2 business days. Where we are unable to meet this timeframe, we will endeavour to keep you updated as to the progress of the issue. As a guide, the below examples are what would ordinarily be considered urgent complaints:
- Your issue is life threatening or dangerous to yourself or others
- Your have been deemed to be in need of IPSTAR Financial Hardship (refer to our financial hardship policy). The issue that you are experiencing further contributes to or worsens that hardship.
- A disconnection has occurred in error, or is about to happen.
Business Customers
IPSTAR does not currently offer any business grade plans. We acknowledge that some customers may use their IPSTAR services to support their commercial operations from time to time. However we do not offer a class of service that differentiates between business and residential customers. As such all instances of escalated customer issues will receive the same level of support and assistance as our residential class of service plans. In the event that IPSTAR warrant a customer do be entitled to any form of compensation, we will generally not take into consideration that the customer may have been using the service for commercial activity.
IPSTAR Complaint Handling Policy in Different Formats
Should a customer (or former customer) require assistance with a copy of this policy in a format that meets their disability or language needs, please contact IPSTAR. We will endeavour to assist with providing a format of this policy that meets the needs of our customers (or former customers) within a reasonable period of time.
In some cases our customers may choose to nominate an authorised representative to assist with lodging a complaint. We are happy to accommodate these requests; however we will need to first gain satisfactory approval from our account holder, before we can appoint an authorised representative.
Resolution of your Complaint
Regardless of the escalation point of your complaint, we will ask for your acceptance of the resolution, before we apply the resolution.
