IIA Code of Practice, Draft Version 7.1

12 April 2002

Mr Peter Coroneos
Chief Executive
Internet Industry Association
PO Box 3986
Manuka ACT 2603

via email

Dear Mr Coroneos

Subject: IIA Codes of Practice, Draft Version 7.1

EFA submits the following comments in relation to the draft Codes issued in March 2002.

We note that the primary changes are:

(a) a requirement that Code-complaint ISPs provide filtering/blocking software products at cost price (which includes the costs of "obtaining, supplying, and supporting" the software),
(b) an additional requirement on scheduled filtering/blocking product suppliers to have a process in place to better support ABA updates,
(c) additions and deletions to the list of filtering/blocking products in the Schedule.

EFA supports changes referred to in (a) and (b) above. In our view, these are an improvement on the existing Code and will be of benefit to end-users who choose to use a scheduled filtering/blocking product.

We make no comment on the changes referred to in (c) as we understand the matter of product capability is beyond the scope of the Code review and, in any case, the recent ABA/NetAlert commissioned CSIRO report is a useful resource for both ISPs and end-users relative to decisions about provision of and use of products listed in the Schedule.

In relation to the other less significant changes to the Code, these do not raise any issues of concern to EFA.

Please note that this submission addresses only the changes to the provisions of the existing Codes. This submission should not be taken to infer support for pre-existing aspects of the Codes that were addressed in EFA's submission to the previous public consultation process.

Yours sincerely

Irene Graham
Executive Director
Electronic Frontiers Australia Inc.