Report of the Interception of Communications Commissioner - March 2015
Figure 10 Communications Data - 2014 Inspection Recommendations by Category
notices & authorisations 8%
records
12%
errors 7%
SPoC 12%
streamlining 7%
urgent Oral 5%
designated person
18%
training 3%
other 3%
applicant
23%
national prioirty
grading scheme 2%
7.47 In the vast majority of inspections the inspectors did see ample evidence of
SPoCs challenging applicants in cases where they believed the requirements had not
been met. Although not complete, statistical information obtained by our office indicates
that approximately 20% of applications are returned to the applicants by the SPoC for
development or improvement.
7.48 As was the case in 2013, our inspections in 2014 also identified that a small number
of SPoCs were experiencing serious backlogs in dealing with applications due to a lack of
staff or inadequate systems. This is concerning as it could have an impact on compliance.
In addition it is also questionable whether the necessary and proportionality justifications
are still valid in cases where it takes weeks to process an application. My inspectors also
made a number of good practice (green) recommendations on how efficiency might be
improved within a SPoC e.g. for SPoCs to engage more proactively with applicants to
ascertain the data that is required to fulfil their objective and ensure that the conduct is
not arbitrary or excessive in the circumstances.
Designated Persons (DPs).
7.49 The inspectors made recommendations in relation to the role being performed by
DPs in nearly half of the inspections undertaken. The majority of the recommendations in
this category fell into two key areas; DP considerations and DP independence.
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