Does the Party have an official response to this Draft paper?
Communications Alliance - Copyright Notice Scheme
http://www.commsalliance.com.au/__data/assets/pdf_file/0005/47570/DR-C653-2015.pdf
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We will, once the ALRC freedoms review gets done. Do you want to get started?
I do have some concerns, mainly on some issues on clarification of certain things.
I will be submitting my concerns, through representation of my own media organization. I would be more than happy to also assist in a submission for us.
I will outline my concerns here and we’ll go from there.
Ok, I will throw our submission in when completed. Should be done in coming days.
It is collaborative, please put whatever you have written already in there so others can help as well.
I understand that. I will dump the summary of our concerns up tonight and perhaps PPAU members can then use it as a building block.
Here is a Summary as drafted from our own Submission.
I urge Members of PPAU to contribute to this and their response and suggested action to each concern outlined.
**COMMUNICATIONS ALLIANCE LTD. COPYRIGHT NOTICE SCHEME
Summary of concerns, as drafted by Freedom Publishers Union, in collaboration with Pirate Party Australia.
March 2015
Initial concern
Actual details are not clear and detailed enough as to what each of the three notices informing the Account Holder.
Initial concern
Actual details are not clear and detailed enough as to what are the incursions for ignoring the third/final notice informing the Account Holder.
Initial concern
Actual details are not clear and detailed enough as to what are the incursions and resulting action be for Account Holder ignoring the third/final notice.
Initial concern
No Clause or Provisions set out in this document, for “fair use”, substitute or equivalent.
Initial concern
What exact information is deemed “personal details”.
Initial concern
In reference to Clause 3.12; How accurate is the method(s) and technological techniques used for IP address detection of possible copyright breach of the Rights Holder, from the ISP and Account Holder.
Initial concern
In reference to Clause 3.13; The Clause uses the term “must” when referring to ISP issuing a notice upon request of the Rights Holder. What incursions result when a ISP fails to proceed with issuing a notice to the Account Holder, as requested by the Rights Holder.
Initial concern
In reference to Clause 3.16; This Clause Requires stronger emphasis.
Initial concern
Will require further review when more information on numbers is provided in the document.
Initial concern
Not enough detailed information is provided in the document to describe what a “Preliminary Discovery Application” is.
Initial concern
In reference to Clause 3.9.2 (6); Pop-up; How will this technology be implemented.
Initial concern
In reference to Clause 3.9.2; It remains unclear whether an ISP is required to re-attempt a second (or more) time if one selected contact option fails to the Account Holder.
Initial concern
In reference to Clause 3.10; How can a Account Holder obtain a Challenge Notice.
Initial concern
In reference to Clause 3.10; How does the Account Holder send the Challenge Notice to the Adjudication Panel.
Initial concern
In reference to Clause 3.10.6; In the details of this Clause, it is unclear whether the stated “28 days” applies to the date the Final Notice is sent to the Account Holder or the date the Final Notice is received and officially acknowledged by the Account Holder.
Initial concern
In reference to Clause 3.10.13; The term “Privacy Principles”, as used in this Clause is too broad and non-specific.
Initial concern
In reference to Clause 3.11.1; The period for records keeping at 24 months, as specified in this Clause is too long and unnecessary.
Initial concern
In reference to Clause 3.11.2; Details outlined in the Clause require amending in accordance to Clause 3.11.1.
Initial concern
In reference to Clause 3.11.2; The term “may destroy”, as used in this Clause is not sufficient in terms of respecting the rights to privacy of the Account Holder.**
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I’ve created a pad here: http://pad.pirateparty.org.au/p/commsalliance2015 and pasted in some links and chris’s content above… Just in case people want to add any thoughts, links, resources and bit’s and pieces together before putting more formal stuff in Mozarts overleaf link above.
I have updated the content in the pad.
The initial concerns/recommendations are the exact text that is from the Submission that will be sent to Communications Alliance in response to the Draft text.
Freedom Publishers Union will be submitting our response tomorrow afternoon.
Freedom Publishers Union has submitted our Submission document to the Communications Alliance. You can view it here http://tinyurl.com/kql54mk