Recommendations

We have three themes to guide our implementation:

  • Accountability and transparency (recommendations 3,7,12 & 14)
  • Engagement and information sharing (recommendations 2,4, 8,10 &11)
  • Strengthening capabilities and resources (recommendation 19)

2 Clarify roles and priorities

Status: On track for completion in 2023

Report recommendation

The BCCC should do more to build a shared understanding amongst stakeholders of

  1. its role and how this fits with the roles of ASIC and AFCA and
  2. its proposed priority areas.

Work underway

Working with AFCA and ASIC to clarify respective roles and responsibilities and improve information sharing

Publication of the BCCC’s Priority Monitoring Framework (PMF) to provide greater clarity and transparency about how the BCCC prioritises and undertakes its work

Annual public consultation on BCCC priorities to assist the BCCC in determining its focus areas

Publication of our annual priorities on our website in the BCCC Annual Business Plan 2023-24

3 Improvements to monitoring and reporting

Status: On track for completion in 2023

Report recommendation

The BCCC should continue to evaluate and improve its approach to monitoring and reporting, working with stakeholders to improve outcomes and efficiency over time and reporting back on progress as part of the BCCC Annual Report.

Work underway

Improving our approach to reports and guidance to ensure information is clear, useful, and timely.

Future work

Annual stakeholder survey on the work and publications of the BCCC to inform ongoing improvements.

4 Small business and agribusiness panel improvements

Status: Completed in 2022

Report recommendation

The BCCC should revitalise its Small Business and Agribusiness Advisory Panel, incorporating systematic ways of engaging with it in developing strategy, business planning, in planning inquiries and wherever its expertise can be applied. Once its processes are strengthened, it should also consider adding other useful perspectives from amongst the diversity of the sector.

Work completed

Re-appointment and appointment of panel members drawing on a diverse range of perspectives

Refreshed terms of reference with more regular communication between the BCCC and Panel

A comprehensive induction for Panel members to clarify purpose and objectives of the BCCC and the Panel

Updated our website to share information on the Panel, its role and the importance of its purpose in bringing small business and agribusiness expertise to the BCCC

7 Timeliness of Compliance Statement reporting back

Status: On track for completion in 2024

Report recommendation

The BCCC should commit to a strategic priority of significant improvement within 3 years in the speed of its reporting on banks’ periodic Compliance Statements. To achieve credibility, the BCCC reporting should be complete within 90 to 100 days of the close of the banks’ reporting deadline.

Work underway

Consultation with the ABA and Code subscribers to streamline breach reporting (Part A) and avoid unnecessary duplication

Improve breach reporting (Part A Compliance Statement), incorporating stakeholder feedback

Develop clear guidance on breach reporting to improve the consistency and quality of data received

Review and improve the internal end-to-end business process to deliver more timely Part A Compliance Statement reporting

8 Refinement Compliance Statement data collection

Status: On track for completion in 2024

Report recommendation

The BCCC should work closely with the ABA and banks, bearing in mind the expectations and needs of other stakeholders, to refine the BCCC’s Compliance Statement data collection to optimise the reporting process’s effectiveness and efficiency. In doing so, the following principles should apply:

  1. Credibility – The BCCC’s data collection enables the BCCC to provide assurance to the community as to banks’ compliance with the Code
  2. Clarity – There should be clarity for banks as to the reasons for data requests
  3. Accommodating diversity – Data collection requirements must consider the diversity of banks
  4. Efficiency – Data requirements should be framed to be as resource efficient as possible for banks and the BCCC
  5. Comparability – Banks should commit to data provision practices that maximise comparability
  6. Change management – Changes in data collection should give banks sufficient opportunity to prepare for and respond
  7. Continuous improvement –continuous improvement approach should be taken to evolve data collection over time in light of experience and changes in the external environment

Work underway

Review existing data infrastructure and determine future business needs in consultation with stakeholders

Ongoing engagement to minimise reporting duplication and streamline data collection

Identify, document and communicate to stakeholders the rationale for our data requests

10 Reduce reporting burden

Status: On track for completion in 2023

Report recommendation

Once practices for reportable situation reports by banks to ASIC have achieved a settled rhythm, the BCCC should revisit which of these matters it wants banks to contemporaneously report to the BCCC and how this can occur in a way that is efficient for banks and the BCCC.

Work underway

Working with ASIC to establish information sharing and clarifying roles and responsibilities

Working with ASIC to understand the extent of reporting from banks to determine opportunities for streamlining to ensure we collect the right data to provide meaningful insights

11 Exchange of confidential information

Status: On track for completion in 2024

Report recommendation

The BCCC should prioritise working with AFCA to establish an agreement regarding the exchange of confidential information under AFCA’s rules.

Work underway

Working with AFCA to formalise information sharing between AFCA and the BCCC under AFCA’s rules

Work with the ABA to update the BCCC Charter to facilitate improved information sharing

12 Improvements to inquiries

Status: On track for completion in 2023

Report recommendation

The BCCC should plan, scope and implement its Inquiries in a way that permits timely Inquiry reporting (usually within 12 months of first information collection from the banks). This will likely involve:

  1. scoping its Inquiries more tightly
  2. as appropriate, engaging directly (orally) with banks
  3. to the extent practicable, leveraging banks’ own quality and risk/assurance resources
  4. working with banks to improve data comparability.

Work underway

Improving the way that we scope and undertake inquiries to deliver more targeted, timely and impactful outcomes

Engagement with Code subscribers regarding improved approaches to inquiries

14 Feedback on referrals

Status: On track for completion in 2023

Report recommendation

The BCCC should review its processes for advising organisations of the outcome of referrals of allegations of breaches to ensure that they are given the opportunity to provide any additional relevant information and that they are sufficiently informed of the ultimate outcome.

Work underway

Review operational processes for managing concerns and conducting investigations, including responses to individuals who raise concerns with us, upon completion

Update the information on our website on submitting concerns to the BCCC to clarify our role in receiving and managing concerns, and how we use this information

19 BCCC resources

Status: On track for completion in 2023

Report recommendation

In consultation with stakeholders and taking expert advice as needed, the BCCC should review its resourcing with a view to ensuring that:

  1. data analytics capability and capacity, at a strategic and intermediate level is adequate
  2. its internal team structure is effective and enabling time-efficiency
  3. its ability to engage effectively with stakeholders is keeping up with increased focus and scrutiny
  4. it has the resources for projects to implement our recommendations

Work completed

The team has been restructured to reduce bottlenecks and better support the development of our people

Review of resourcing requirements for the 2022-23 financial year

Work underway

Recruitment of a dedicated data analyst

Future work

Resource needs analysis beyond 2022-23