Telecommunications Interception Legislation Amendment Bill 2002

Last Updated: 29 July 2002


On 27 June 2002, in a victory for online privacy rights, the Senate rejected the Federal Government plan to allow government agencies to snoop on email, SMS and voice mail messages without an interception warrant. The government said it will try again to have the amendment passed in a future Bill. For more info, see EFA's media release dated 28 June 2002 and background information below.

On 12 March 2002, the Attorney-General introduced the Telecommunications Interception Legislation Amendment Bill 2002 into the House of Representatives.

The Bill would change the long-established balance between individuals' right to privacy and legitimate law enforcement needs. It would allow government agencies to intercept and read the contents of communications passing over a telecommunications system, that are delayed and stored in transit, without a warrant of any type (e.g. email, voice mail and SMS messages that are stored on a service provider's equipment pending delivery to the intended recipient). Under current law, an interception warrant is required to access such messages, the same as is required to intercept a telephone call.

This Bill is one of a suite of anti-terrorism Bills, named the Security Legislation Amendment (Terrorism) Bill 2002 [No.2] and Related Bills, that the government had been canvassing for 6 months. The Bills were rushed through the House on 13th March after a brief gagged debate, over the protests of the Opposition because of the limited time allowed for debate. The Senate second reading occurred on 14th March and debate was deferred. The Bills were referred to the Senate Legal and Constitutional Legislation Committee for inquiry on 20th March and the Committee issued its report on 8 May 2002.

Contents

Status of Bill / Recent Updates

26 July 2002: Comments on the contents of a letter from the Attorney General to the Editor of Australian IT added.

27 June 2002: In a victory for online privacy rights, the Senate rejected the Federal Government plan to allow government agencies to snoop on email, SMS and voice mail messages without an interception warrant. The government said it will try again to have the amendment passed in a future Bill. For more info, see EFA's media release dated 28 June 2002.

10 May 2002: The Bill is expected to be debated in the Senate on or soon after 14 May 2002.

8 May 2002: The Senate Committee issued its Report and recommended:

"Recommendation 5
The Committee recommends that the Attorney-General review the current law on access to stored communications of delayed messages services with a view to amending the Telecommunications Interception Legislation Amendment Bill 2002 so that the accessing of such data requires a telecommunication interception warrant."

EFA had advised the Committee that in EFA's view the Bill must be amended to ensure a telecommunications interception warrant is required to access stored communications.

5 April 2002: Submissions to the Senate Committee inquiry closed. EFA lodged a submission and presented oral evidence to the Committee on 17 April.

Overview of Bill and effect on existing privacy protections

The Telecommunications Interception Legislation Amendment Bill 2002 ("TI Bill") changes the long-established balance between individuals' right to privacy and law enforcement needs. Clause 15 of the Bill significantly reduces the existing privacy protection afforded by law to communications passing over a telecommunications system. While the Commonwealth Government frequently cites enthusiasm for "technology neutral" laws, this Bill is certainly not. It treats email conversations (etc) quite differently from voice conversations.

The existing law:

The existing Telecommunications Interception Act prohibits interception of communications passing over a telecommunications system, except when authorised by an interception warrant. Law enforcement agencies are not permitted to access the content of messages (such as email, voice mail, SMS, etc) that are temporarily stored on a telecommunications service provider's equipment during transit, unless they have obtained an interception warrant.

After a message has been delivered to the intended recipient (i.e. has completed its passage over the telecommunications system) law enforcement agencies can lawfully access the content of the message with a search or seizure warrant. Such a warrant may cover the recipient's equipment (e.g. computer containing downloaded email) or the service provider's equipment when a copy of the message remains on their equipment.

Statements by the Attorney-General and the National Crime Authority on the provisions of existing law include:

  • Media release issued by Attorney-General Daryl Williams, 18 December 2001:
    "At present, an agency with a valid search warrant cannot access e-mail communications unless they have been read, or otherwise consciously dealt with, by the intended recipient. The Telecommunications (Interception) Act 1979 will be amended to permit access to unread e-mails where another form of lawful access to the system or device capable of displaying the communication is held by the relevant agency."
  • Parliamentary Joint Committee on the National Crime Authority Report on the Law Enforcement Implications of New Technology, August 2001. Paragraph 1.80 of Committee's report states the NCA said in its submission to the inquiry that:
    "A sent but unopened email needs a TI warrant for interception. Once the email has been downloaded and opened by the recipient it is their property and a search warrant is required. This also applies to Short Message Services (SMS) and voice messages stored in remote locations."

For more detailed information on existing laws, see EFA's page Australian On-line Surveillance and Interception Laws.

The Government's proposed changes to the law:

Clause 15 of the Telecommunications Interception Legislation Amendment Bill 2002 "deems" that a communication temporarily stored on a service provider's equipment prior to delivery is not still passing over a telecommunications system. If the Bill is passed without relevant amendment, enforcement agencies will no longer need to obtain an interception warrant to access the content of communications temporarily stored on a service provider's equipment during transit. They will be able to access email, voice mail, SMS, etc messages that have not been delivered to the intended recipient without a warrant of any type.

The Explanatory Memorandum to the TI Amendment Bill states the amendments:

"legislatively clarify the application of the Act to telecommunications services involving a delay between the initiation of the communication and its access by the recipient, such as email and short messaging services"

However, the Bill does not clarify the law, it changes the existing clear provisions of the law.

The changes are the same as deciding that postal mail remains protected from interception while being delivered by the postman and transported in Australia post vehicles, but not while stored in Australia Post premises awaiting delivery.

No warrant of any type will be required to access communications delayed in transit

At a Senate Committee hearing on Friday 19 April, a representative of the Attorney-General's Department informed the Committee that agencies will be permitted to access delayed/stored communications "under some other lawful authority like a search warrant".

Although the above and other comments have indicated that a search warrant, instead of an interception warrant, would be necessary to access the content of communications delayed in transit, agencies would become able to access such communications without a warrant of any type under existing provisions of the Telecommunications Act such as Section 280(1)(b) and 282(1) and (2).

For example, S282(1) and (2) of the Telecommunications Act permit carriers and carriage service providers to disclose documents and information to agencies on request (without a warrant or even written request) if the service provider considers the disclosure or use is "reasonably necessary" for the enforcement of the criminal law, or the enforcement of a law imposing a pecuniary penalty, or the protection of the public revenue.

The above clauses currently permit disclosure of information such as customer identification details and the source, path and destination of communications (for example, telephone numbers dialled, and the "To" and "From" fields of an email message, etc). In the 2000-2001 year, 524,253 disclosures of information or documents were made to government agencies under S282(1) and (2) of the Telecommunications Act (i.e. without a warrant or certificate) by telecommunications carriers, carriage service providers (includes ISPs) or number database operators. This is over 70% of the total disclosures (733,485) under Part 13 of that Act. (Source: Answer to Question on Notice No. 150, House of Reps Hansard, 19 March 2002).

The above clauses cannot presently be used to access the "contents or substance" of communications delayed and stored in transit because such access is prohibited by the Telecommunications Interception Act. However, if Clause 15 of the TI Bill passes, the prohibition on disclosing content of such messages will cease.

It is understood that as at 10 May 2002, representatives of the Attorney-General's Department were informing journalists etc that a search warrant would be required if Clause 15 of the TI Bill passes, that is, that access to the "contents or substance" of communications would not be available under Section 282(1) and (2) of the Telecommunications Act. It is notable that this was not the view of the A-G's Department in 1999 and that this aspect of the Telecommunications Act has not been amended since 1999. In May 1999, the Attorney-General's Department issued a Report titled Telecommunications Interception Policy Review which states:

Section 4.3 - Access to stored data

4.3.11 Access by enforcement agencies to information held by C/CSPs [under the Telecommunications Act] is by means of two primary mechanism, certified and uncertified requests.

4.3.12 Subsection 282(6) of the Telecommunications Act provides that the certificate provisions in subsections 282(3), (4) and (5) do not apply to the contents of a communication whether or not the communication has been received by the intended recipient.

4.3.13 However, this still leaves the possibility that subsections 282(1) and (2) can apply in respect of the content of stored communications. That is, an enforcement agency (including civil penalty-enforcement and public revenue protection agencies) could get access to the contents of a stored communication if the disclosure of the stored communication is reasonably necessary for one of the purposes listed in subsections 282(1) and (2).

The above appears consistent with the statement made by a representative of the Attorney-General's Department in evidence to the Senate Committee on Friday 19 April 2002. The representative said that agencies will be permitted to access delayed/stored communications "under some other lawful authority like a search warrant". Apparently, "some other lawful authority" would include a request without a warrant under Sections 282(1) and (2) of the Telecommunications Act.

Analysis of Attorney-General's letter to The Australian IT, July 2002

On 16 July 2002, The Australian newspaper (IT section) published a letter to the Editor written by Daryl Williams, Commonwealth Attorney-General. Mr William's letter criticised an article published in The Australian IT titled "Email snooping loses vote" on 2 July 2002 (the date of 9 July 2002 in the letter is apparently a printing error).

EFA has received inquiries regarding why EFA's analysis of the proposed amendments appears to conflict with statements made in the Attorney-General's letter. We address this matter below.

The article in The Australian IT on 2 July 2002 stated, inter alia, that the Bill:

"... sought to give government agencies the power to intercept and read messages without an interception warrant. A warrant would have remained necessary to tap telephone calls.
...
Labor IT spokeswoman Kate Lundy said it was unacceptable for 'stored telecommunications' - email, SMS and voice mail - to receive less privacy protection than telephone calls.
'It's almost a loophole in the telecommunications process by virtue of the fact that emails get stored on a server, and the Government was trying to exploit that,' she said."

Mr William's letter regarding the above article stated:

"...it is incorrect to suggest that, under the legislation, government agencies could snoop on privacy communications without a warrant.
... The provisions did not remove the need for a warrant to access this type of data. In fact, the original legislation merely clarified the type of warrant required - a TI warrant or a search warrant."

The provisions unquestionably sought to remove the existing requirement for an interception warrant to access the content of messages delayed and stored during transit over a telecommunications system (e.g. temporarily stored on an ISP's server). If this requirement was removed it appears not even a search warrant would be required to access such communications because, as detailed earlier herein, government agencies would be able to gain access under provisions the Telecommunications Act. As noted above, the Attorney-General's Department recognised this to be a "possibility" in 1999 and the relevant law has not been changed since that time. (Presently, the requirement for an interception warrant under the Telecommunications Interception Act over-rides the provisions of the Telecommunications Act in relation to accessing the content of messages that are delayed and stored during transit over a telecommunications system.)

The Attorney-General's letter also stated:

"The Government is of the view that these provisions merely reflected the current law and practice in relation to stored communications."

One may ask why, if the provisions merely reflected "the current law", there is a need to change that law. Furthermore, the Attorney General made quite clear in a media release issued on 18 December 2001 that the objective was to change current law and practice. Mr Williams said:

"At present, an agency with a valid search warrant cannot access e-mail communications unless they have been read, or otherwise consciously dealt with, by the intended recipient. The Telecommunications (Interception) Act 1979 will be amended to permit access to unread e-mails where another form of lawful access to the system or device capable of displaying the communication is held by the relevant agency."

The amendment heralded above is contained in Clause 15 of the TI Bill and "another form of lawful access" appears to be access without a warrant under the Telecommunications Act.

In his letter to Australian IT, the Attorney General claimed:

"They [the provisions] recognised that, where communications are kept in a piece of equipment such as a computer, a warrant to search and seize is more appropriate than an interception warrant because there is no need to intercept the message between sending and receiving in order to access the information."

The above statement refers only to accessing messages that have completed their transit over the telecommunications system, i.e. have been received by the intended recipient. EFA understands that, under current law, if a copy of a delivered message remains stored on a telecommunications provider's equipment (e.g. an ISP's mail server, or telephone company's voice mail boxes, etc), it may be lawfully accessed with a search warrant because the copy is not being intercepted between sending and receiving. If the government considers the current law is not clear in this regard, then perhaps the proposed amendments could be regarded as a "clarification" in relation to delivered messages.

However, the Attorney-General's letter does not address the fact that the proposed amendments would permit agencies "to intercept the message between sending and receiving" without an interception warrant (nor another type of warrant as discussed above) while a message is temporarily stored during transit between sender and receiver on a telecommunication service provider's equipment. This would be a change to current law and practice enabling agencies to gain access to unread (undelivered) messages without an interception warrant as is presently required.

Search warrants are subject to markedly less safeguards and are less protective of citizens' privacy than interception warrants

If a Bill to amend the Telecommunications Act was enacted to ensure a search warrant would be required to access content of communications stored during transit, this would nevertheless afford considerably less privacy protection than does the current requirement of an interception warrant.

The longstanding, rigorous safeguards and controls set out in the Telecommunications Interception Act to prevent misuse of the power to intercept do not apply to search/seizure warrants issued to various Commonwealth, State and Territory agencies. For example:

  • Less strict requirements would govern issue of warrants because warrants other than interception warrants could be used. The nominated members of the Administrative Appeals Tribunal who are authorised to issue interception warrants must comply with conditions of issue set out in the TI Act that are intended to ensure privacy is not unduly infringed. Applicants for interception warrants are required to demonstrate that the information likely to be obtained from the interception will materially assist the investigation, that there are no alternative methods available (or that they have been tried without significant success), and that in the case of 'Class 2' offences that the matter is sufficiently serious to justify intrusion into individuals' privacy.

    Issue of search warrants is not subject to such conditions and can be issued by less appropriately qualified persons, including some likely to be biased against giving adequate consideration to privacy issues, such as police officers, officers of government departments, justices of the peace, etc.

  • Access would no longer be restricted to the investigation of serious crime. Agencies would be able to obtain access, without an interception warrant, to the content of stored communications on service providers' equipment when investigating a significantly broader range of suspected offences than is permitted under the TI Act. Interception warrants can only be issued in relation to the investigation of a "serious offence" i.e. Class 1 and Class 2 offences specified in the TI Act. In most instances it is a requirement that the offence be punishable by imprisonment for life or for a period of at least 7 years. (Class 1 offences include murder, kidnapping, narcotics offences and being a party to those offences. Class 2 offences include those which are punishable by a maximum of at least seven years imprisonment, e.g. bribery, serious fraud, drug trafficking, official bribery and corruption, money laundering and offences involving two or more offenders and substantial planning and organisation.)

    Search warrants can be issued for many other reasons and purposes than can interception warrants.

  • Agencies who are not authorised to use interception warrants would be able to access the content of undelivered stored communications on service providers' equipment, i.e. access information that they presently have no power to access. Interception warrants can only be issued to agencies that are specifically authorised under the TI Act (e.g. the AFP and the NCA) and 'declared agencies' under S. 34 of the TI Act. Before the Attorney-General can declare a State agency, there must be State legislating complementing the Commonwealth Telecommunications Interception Act. State legislation must impose parallel supervisory and accountability provisions (including those relating to inspection and reporting requirements) on the State authority. Hence, agencies of States that are not bound by such complementary legislation are not and cannot be authorised to obtain interception warrants.

    Generally, issue of search warrants is not subject to equivalent supervisory and accountability provisions and, as outlined earlier herein, a search warrant will not necessarily be required be required in any case.

  • Enforcement agencies other than criminal law enforcement agencies would be able to obtain access to the content of stored communications without a warrant of any description.

  • Limitations set out in the TI Act on the secondary disclosure and use of information obtained from execution of an interception warrant do not apply to information obtained under a search warrant, or without a warrant of any type.

Potential effect on voice calls using new technologies

It should also be noted that the definitions of "delayed access message services" and "stored communication" in the Bill, in conjunction with the existing definition of "communication", may arguably result in communications using new technology such as Voice over IP (which may replace traditional telephone call technology in forthcoming years) being able to be intercepted without an interception warrant.

EFA Submission to the Senate Committee inquiry

When EFA lodged its submission on 5 April 2002, the intent of the legislation was unknown because the Bill and related government documents are ambiguous. Subsequently it became clear (see earlier herein) that the intent is to enable agencies to access email and other communications stored on service providers' equipment during transit without an interception warrant. EFA drew this to the Committee's attention in oral testimony on 17 April 2002. EFA's written submission to the Committee, lodged before the intent of the proposed amendments became clearer, is below.

Electronic Frontiers Australia

Submission to the Senate Legal and Constitutional Legislation Committee

Inquiry into the Security Legislation Amendment (Terrorism) Bill 2002 [No. 2] and Related Bills

5 April 2002

About EFA

Electronic Frontiers Australia (EFA) is a non-profit national organisation formed to protect and promote the civil liberties of users and operators of computer based communications systems. EFA was formed in January 1994 and incorporated under South Australian law in May 1994.

Our major goals are to advocate the amendment of laws and regulations in Australia and elsewhere (both current and proposed) which restrict free speech, and to educate the community at large about the social, political and civil liberties issues involved in the use of computer based communications systems. EFA is independent of government and commerce and is funded by membership subscriptions and donations from individuals and organisations with an altruistic interest in promoting civil liberties.

Introduction

EFA wishes to comment only on one Bill in the package of Bills which are the subject of this inquiry, namely the Telecommunications Interception Legislation Amendment Bill 2002. According to the Attorney-General's second reading speech, these amendments are intended to clarify the legal position in respect to application of the Telecommunications (Interception) Act 1979 to modern means of telecommunication such as SMS and e-mail. EFA's position is that all means of private communication should receive the same degree of privacy protection as telephone calls, i.e. that an interception warrant should be necessary if law enforcement agencies wish to intercept communications in transit. This is the position enshrined in UK law under the Regulation of Investigatoty Powers Act 2000 [1].

While there does appear to be an intent to legislate certain protections, there are ambiguities in the proposed amendments that EFA believes must be rectified.

Commentary on the Amendments

The Attorney-General, in his second reading speech, stated:

The amendments make clear that a communication will fall outside the definition of interception where it is stored on equipment and can be accessed using that equipment but without reference to the telecommunications network. In these circumstances agencies will be able to access the communications pursuant to other appropriate means of lawful access, such as a search warrant authorising the operation of the equipment. These amendments reflect a much needed clarification, and will assist agencies in the performance of their functions.

The proposed amendments, and the examples given in the Explanatory Memorandum and the Bill itself, indicate that government's view is that e-mail and similar technologies constitute a "protected" communication from the time a message is sent until it has been downloaded to the recipient's computer, i.e. a telecommunications interception warrant is required to intercept e-mail in transit between sender and recipient. If that is a correct statement of the intent of the amendments, EFA fully supports that position.

However, the wording in the Bill is ambiguous, and fails to properly clarify the situation concerning e-mail stored temporarily on, for example, an ISP's mail server. EFA submits that the most important issue that needs to be clarified is whether e-mail in transit on an ISP's server can be accessed by law enforcement under a search warrant on the ISP's premises or whether an interception warrant is required. In other words, is e-mail actually to be given the same level of protection from interception as does traditional voice communication?

The Explanatory Memorandum to the Bill states:

The subsection [6(4)] further provides two examples to assist in the application of the provision to specific types of delayed access message service.

Under the definition, an SMS message stored on a GSM mobile phone SIM card would be a stored communication, as the content of the message is stored on the SIM, and the message can be accessed by using the SIM in combination with a mobile telephone handset or by the use of a SIM card reader. Likewise, an email message that has been downloaded to a computer hard disk would be a stored communication where it can be accessed without connecting the computer to a telecommunications line. A mobile voicemail message would not however be a stored communication, as the retrieval of the message requires the user to use a line to listen to the message. Similarly, fixed voicemail that requires the user to dial a mailbox to retrieve the message would not be a stored communication, while locally stored voicemail would however be a stored communication for the purposes of the section.

Proposed subsection 6(5) deems a stored communication to no longer be passing over the telecommunications system when it is accessed by the equipment on which it is stored, whether alone or with other equipment. The effect of the amendment is to exclude such access from the scope of interception. Accordingly, a telecommunications interception warrant will not be required to access the communication so stored, but rather another applicable form of lawful access, such as a search warrant or seizure order would be appropriate.

This explanation unfortunately does not clarify the situation of messages stored on an ISP's server, since such communications can in fact be "accessed by the equipment on which it is stored, whether alone or with other equipment" without using a telecommunications line. Access to these communications is available to anyone with access to the ISP's premises and the appropriate access passwords. The key question is whether a law enforcement agency, possessing only a search warrant, seizure order, or even merely a certificate issued under the provisions of Part 13 of the Telecommunications Act, covering the ISP's premises, can legitimately access such communications, or whether an interception warrant is required.

The relevant section of the Telecommunications Interception Legislation Amendment Bill 2002 states:

15 At the end of section 6

Add:
Delayed access message services - access to stored communications
(3) In this section, a delayed access message service is a means by which a communication intended for a person can be:
(a) submitted using a telecommunications system, without the person being in direct contact with anyone submitting the communication; and
(b) subsequently accessed by the person (whether or not other persons might also be able to access it).

Note: Some common examples of delayed access message services are e-mail services and voice mail services (if they are provided by means of telecommunications systems).

(4) In this section, a stored communication is a communication that:
(a) has been submitted using a delayed access message service;
and
(b) is stored on equipment; and
(c) can be accessed using that equipment, or that equipment in combination with other equipment, but without using a line, unless the use of the line is merely for the purpose of, or an incidental result of:
(i) turning on equipment; or
(ii) obtaining power required to operate equipment; or
(iii) any other action prescribed by regulations for the purposes of this subparagraph.

Example 1: An e-mail is a stored communication if it has been down-loaded from a service provider onto a computer and can be accessed using that computer without any further use of a line.

Example 2: A voicemail message is not a stored communication if it can only be accessed by dialling a number.

(5) A stored communication is taken no longer to be passing over a telecommunications system when it is accessed in accordance with paragraph (4)(c).

Note: The heading to section 6DA is altered by omitting "for use of listening devices".

Some definitions pertinent to these amendments need to be pointed out. The following definitions in s.7 of the Telecommunications Act 1997 also apply to the Telecommunications (Interception) Act 1979:

line means a wire, cable, optical fibre, tube, conduit, waveguide or other physical medium used, or for use, as a continuous artificial guide for or in connection with carrying communications by means of guided electromagnetic energy.

telecommunications network means a system, or series of systems, that carries, or is capable of carrying, communications by means of guided and/or unguided electromagnetic energy.

The boundary of a telecommunications network is defined in S.22 of the Telecommunications Act 1997 as one of a number of alternative definitions for describing the building entry point of customer premises.

Recommended changes

EFA proposes that Item 15 of the Bill be amended as follows:

  1. The use of the word line in proposed amendment 4(c) above is ambiguous. This term is used in the Telecommunications Act 1997 not only in relation to parts of the telecommunications network but also to refer to private networks. The Explanatory Memorandum refers to a telecommunications line and the wording of the Bill should also make the context clear by using the same terminology.

  2. Section 4(b) of Item 15 should be amended to make it clear that a stored communication refers to the message recipient's equipment.

  3. An example should be added after Example 2 to clarify the status of messages in transit that are temporarily stored on equipment at a service provider's facility.

These changes are illustrated in the following amended version (changes in bold red):

15 At the end of section 6

Add:
Delayed access message services - access to stored communications
(3) In this section, a delayed access message service is a means by which a communication intended for a person can be:
(a) submitted using a telecommunications system, without the person being in direct contact with anyone submitting the communication; and
(b) subsequently accessed by the person (whether or not other persons might also be able to access it).

Note: Some common examples of delayed access message services are e-mail services and voice mail services (if they are provided by means of telecommunications systems).

(4) In this section, a stored communication is a communication that:
(a) has been submitted using a delayed access message service;
and
(b) is stored on the message recipient's equipment; and
(c) can be accessed using that equipment, or that equipment in combination with other equipment, but without using a telecommunications line, unless the use of the telecommunications line is merely for the purpose of, or an incidental result of:
(i) turning on equipment; or
(ii) obtaining power required to operate equipment; or
(iii) any other action prescribed by regulations for the purposes of this subparagraph.

Example 1: An e-mail is a stored communication if it has been down-loaded from a service provider onto a computer and can be accessed using that computer without any further use of a line.

Example 2: A voicemail message is not a stored communication if it can only be accessed by dialling a number.

Example 3: An e-mail is not a stored communication if it is in transit between sender and recipient and is temporarily stored on a service provider's equipment.

(5) A stored communication is taken no longer to be passing over a telecommunications system when it is accessed in accordance with paragraph (4)(c).

Note: The heading to section 6DA is altered by omitting "for use of listening devices".

References

  1. U.K. Regulation of Investigatory Powers Act 2000
       http://www.hmso.gov.uk/acts/acts2000/20000023.htm

  2. Australian Communications Authority Factsheet: Internet Service Providers and Law Enforcement and National Security
       http://www.aca.gov.au/consumer/fsheets/industry/fsi13.pdf

  3. Australian Communications Authority Factsheet: Internet Service Providers Interception Obligations
       http://www.aca.gov.au/consumer/fsheets/industry/fsi12.pdf

  4. Australian Communications Authority: Telecommunications and Law Enforcement Manual
       http://www.aca.gov.au/licence/leac.pdf

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