4. Strategic priorities and lines of action to be pursued in 2017-2019

The present Multi-Annual Activities Plan sets out the strategic priorities and lines of action to be pursued over the 2017-2019 three-year period, as well as the actions which will contribute to accomplishing these priorities.

ANACOM's strategic priorities for 2017-2019

The Plan also covers other regular activities which are essential for the proper performance of ANACOM's functions, involving the allocation of significant human and financial resources.

As with the strategic guidelines for the 2015-2017 Plan and the 2016-2018 Plan, ANACOM again submitted its proposed strategic guidelines for the 2017-2019 Multi-Annual Activities Plan to public consultation and, for the first time, the list of actions with respective timetabling was also submitted to the consultation procedure.

By following this procedure, ANACOM is enhancing transparency and regulatory predictability; by providing all stakeholders with an opportunity to express their views on the strategic guidelines which ANACOM proposes to pursue over the coming years and opportunity to suggest new priorities and lines of action; as such, ANACOM is ensuring that its Plan provides a response that is line with market needs.

From the proposals received, the majority were accepted and incorporated into the 2017-2019 Activities Plan, as detailed in the consultation report, which has been approved and is published on ANACOM's website.

The principal lines of action to be pursued by ANACOM in the 2017-2019 three-year period are detailed below, with the specific work tasks that will be undertaken to accomplish them, grouped according to strategic priority for the three-year period:

Strategic Priority 1: Assure and protect the interests of users and citizens

Lines of action:

1.1 Oversee and review application of the conditions governing universal service provision (electronic communications and postal services).
 
1.2 Assess the appropriateness of quality of service levels provided. 
 
1.3 Monitor and report on the evolution of retail pricing.
 
1.4 Define and implement actions in the field of security and integrity of electronic communications networks and services. 
 
1.5 Contribute to the definition and updating of emergency civil planning policies in the communications sector
 
1.6 Ensure the proper provision of information to users.
 
1.7 Review sector's complaint management procedures.
 
1.8 Promote out-of-court dispute resolution in cooperation with relevant authorities. 
 
1.9 Ensure the population's access to free television after 2020 (freeing up 700 MHz band).
 
1.10 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television (DTT) platform.
 
1.11 Ensure proper implementation of the TSM Regulation (roaming and net neutrality) in the light of BEREC guidelines.
 
1.12 Ensure legal compliance and transparency of business practices (including contract terms) and organise a review of procedures.
 
1.13 Improve the technical processes of operator switching.

1.1 Oversee and review application of the conditions governing universal service provision (electronic communications and postal services)

This line of action involves a large number of tasks, including a review of the conditions applicable to provision of the universal service as regards its current and potential future components, and provision of advice to the Government in the context of launching public tender procedures for the universal service of public pay-telephones, the fixed telephone service and telephone directories and directory enquiry services. This work also involves an evaluation of levels of compliance with the quality of service parameters and indicators imposed on the providers of the various component provisions of the universal service in electronic communications, as well as analysis of the conformity of the price-cap established for providers of the universal service of electronic communications and of the postal sector. The action also entails auditing of the quality indicators for 2016-2020 as well as definition of these parameters for the period 2018-2020.

In 2017, ANACOM will also define the rules governing the pricing applicable to the universal postal service in 2018-2020, and will monitor accomplishment of postal network density targets and minimum offers of service, as imposed on universal postal service provider, defining the targets to apply to the universal service provider from October 2017.

ANACOM's plan for 2017 includes auditing of the inventory of the concession assets of CTT reported for the period between 2014 and 2019, as part of its work to contribute to the Government's re-evaluation of the conditions governing provision of the universal postal service.

1.2 Assess the appropriateness of quality of service levels provided

This line of action also entails work on the development of tools for gauging the quality of fixed and mobile Internet access services, notably through the NET.mede and NET.mede Pro tools, and particularly as regards the development of solutions for data processing and reporting. Provision is also made for the disclosure of information on the quality of service of mobile networks.

1.3 Monitor and report on the evolution of retail pricing

Provision is also made, in the period of the Plan, for the monthly disclosure of trends in the Consumer Price Index (CPI/HICP) and in the telecommunications prices, based on data from INE - Instituto Nacional de Estatística (Statistics Portugal). ANACOM will also monitor a series of studies from other organisations (EU, OECD, Teligen, etc.), conducting analyses of the trends reported in the pricing of communications.

1.4 Define and implement actions in the field of security and integrity of electronic communications networks and services

As regards the security and integrity of networks, in 2017, ANACOM intends to carry out an extraordinary audit on network security, conducted by an external auditor which will be selected by means of a tender procedure. This is preceded by a regulatory procedure which took place in 2016, where the stakeholders had opportunity to give input.

1.5 Contribute to the definition and updating of emergency civil planning policies in the communications sector

Taking into account the new responsibilities assigned to ANACOM upon inheriting the assignments and powers conferred on CPEC - Comissão de Planeamento de Emergência das Comunicações (Emergency Communications Planning Committee), it is now a responsibility of ANACOM to contribute to the definition and continual updating of emergency civil planning policies in the communications sector. In this context, in 2017, ANACOM will implement and put into practice the key recommendations resulting from the sector's readiness study, held in 2016. This means ANACOM will carry out the actions of coordination and promotion which are identified, including the development of ANACOM's capacity in term of systems, equipment and other specific resources supporting its new assigned responsibilities.

1.6 Ensure the proper provision of information to users

Recognising the importance of information for consumers, who can make better choices when they are better informed, ANACOM discloses a wide range of information, which it makes available on its institutional and Consumers' websites, both the object of a major revamp in 2016 to facilitate ANACOM's relationship with consumers. ANACOM will continue with its ongoing evaluation of the informative content which it provides on the Consumers' Website, adapting this content in line with the development of perceived needs. With the same purpose, it is envisaged that COM.escolha, ANACOM's tariff comparison tool, will see further adaptation with the inclusion of the Ficha de Informação Simplificada (Simplified Information Sheet) and other improvements.

A wide range of information is released by ANACOM on the Internet, covering goods and services, tariffs, sector legislation, ANACOM determinations, statistics on services, trends in complaints, etc.

1.7 Review sector's complaint management procedures

This line of action provides for the regulation of the procedures employed by communications service providers to process complaints. This is a measure of great importance, given the high level of complaints and the amount of litigation that exists between consumers and operators as a result of the market's competitive situation and certain aggressive commercial practices. Internally, to improve its own capacity to manage complaints, ANACOM will adopt a new information system to support this process.

1.8 Promote out-of-court dispute resolution in cooperation with relevant authorities

Under its statutes, it is ANACOM's responsibility to develop steps to promote solutions and mechanisms enabling the out-of-court settlement of consumer disputes. In 2017 and in subsequent years, ANACOM will implement and monitor the solution adopted to promote extrajudicial resolution of conflicts in the communications sector.

1.9 Ensure the population's access to free television after 2020 (freeing up of 700 MHz band)

ANACOM intends to plan and implement decisions which will be adopted on the television access platform as a result of the release of spectrum in the 700 MHz band for electronic communications services. 

1.10 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television (DTT) platform

In its plan for 2017, ANACOM will monitor development of the DTT network, with possible adaptation of the probe network. Based on the information provided by the probes, a study will be developed in late 2017 on the quality of the DTT service.

To conduct verification of DTT coverage obligations at a national level, in each year of this plan, ANACOM will check whether the information provided by the platform operator on two identified municipalities corresponds to conditions on the ground. To this end, measurements will be carried out in order to validate the theoretical information.

1.11 Ensure proper implementation of the TSM Regulation (roaming and net neutrality) in the light of BEREC guidelines

ANACOM carries out an important set of oversight activities. For the duration of this Plan, special attention will be given to the verification of market practices under the rules of the TSM Regulation¹.

1.12 Ensure legal compliance and transparency of business practices (including contract terms) and organise a review of procedures

This line of action provides for the monitoring of practices engaged in by operators. With this objective, a market survey of zero rating offers will be performed and the transparency of these and other operator offers will be monitored. The Plan also includes a sub-action to monitor implementation and execution of the regulation on contractual and pre-contractual information.

1.13 Improve the technical processes of operator switching

The establishment of codes of conduct by operators could contribute to the improvement of the technical processes of provider switching. In this context, ANACOM is available to carry out initiatives which motivate operators with a view to this objective.

Strategic Priority 2: Promote open and competitive markets

Lines of action:
 
2.1 Oversee and analyse/review relevant electronic communications markets.
 
2.2 Review, in line with requirements, wholesale offers arising from obligations imposed on undertakings with significant market power in the various relevant markets.
 
2.3 Develop and improve regulatory costing systems and audit their results, when relevant.
 
2.4 Undertake actions associated with the provision of the universal service with market impact.
 
2.5 Oversee and monitor the development of next generation access networks (NGA).
 
2.6 Develop/consolidate the application of rules on access to infrastructure under Decree-Law no. 132/2009 of 21 May.
 
2.7 Monitor and supervise the activities pursued by various sector agents, enforcing compliance with prevailing rules.
 
2.8 Contribute to the review/negotiation of the new regulatory framework.
 
2.9 Prepare and submit pre-draft legislation to the Government for transposing the regulatory framework for electronic communications.
 
2.10 Review and consolidate procedures for the management of company registrations.

2.1 Oversee and analyse/review relevant electronic communications markets

Analysis of the various relevant markets defined by the European Commission is vital in order to make a diagnosis of the competitive situation in the electronic communications sector. These analyses entail the review and update of previous analyses, taking into account evolution occurring in the markets concerned; they include definition of relevant markets, identification of any providers with significant market power and the maintenance, imposition, amendment or withdrawal of regulatory obligations to which these providers are subject.

As a result of these analyses, there may be: situations where certain markets are fully or partially deregulated; situations of geographic differentiation due to the prevalence of distinct competitive conditions in different regions of the national territory; and/or situations which warrant the withdrawal, modification or enhancement of regulatory measures.

The market analyses planned for the 2017-2019 three-year period include analysis of market 1, market 2 and former market 2 (origination). Analyses of markets 3a and 3b are scheduled for completion in 2016 (analysis of market 4 was completed in September); these will be re-analysed during the period of the plan.

2.2 Review, in line with requirements, wholesale offers arising from obligations imposed on undertakings with significant market power in the various relevant markets

The conclusions which result from market analyses may determine a review of relevant wholesale offers (reference offers). These offers govern conditions of access to networks and services of providers with significant market power by alternative providers in circumstances that enable sustained competition in retail markets. This activity seeks to ensure transparency in technical and commercial information, and to achieve non-discrimination and price control.

ANACOM undertakes reviews of reference offers in the light of updated data, particularly in terms of costing and quality of service, of experience gained and of contributions received from the market. In 2017, reviews will be conducted focusing on the reference offers of access to ducts (RDAO) and posts (RPAO), with further reviews focusing on the Reference Unbundling Offer (RUO), the Leased Lines Reference Offer (LLRO) and the Ethernet Leased Lines Reference Offer (RELLO). During the 2017-2019 three-year period, ANACOM will also consider changes to the Wholesale Line Rental Offer (WLRO) and the Reference Interconnection Offer (RIO).

2.3 Develop and improve regulatory costing systems and audit their results, when relevant

During this Plan, a series of audits will be carried out focusing on the SCA - Sistema de Contabilidade Analítica (Analytical Accounting System) used by MEO - Serviços de Comunicações e Multimédia, S.A. (MEO) (2015/2016, 2017, 2018) and by CTT (2015, 2016/2018).

Provision is also made for determination of the cost of capital of MEO and CTT for the 2017/2019 period and for approval of the review of the SCA used by CTT.

Other considered actions include updating the mobile and fixed termination model and development of a costing model for next generation networks.

2.4 Undertake actions associated with the provision of the universal service with market impact

During the period of the plan, ANACOM will carry out auditing in the context of the universal service provision of telephone directories and directory enquiry services, with audits of reported figures on retirees and pensioners in the period subsequent to designation of the universal service provider by public tender and of the turnover data used in respect of the electronic communications universal service compensation fund.

Provision is also made in the plan to promote the procedures providing for the compensation of net costs incurred by MEO in the period prior to the designation of the universal service provider by public tender and the reimbursement of costs incurred by the universal service provider designated by public tender (payments to MEO and NOS Comunicações, S.A. (NOS).

ANACOM also plans a series of actions related to the assessment and reimbursement of the postal NCUS, should they apply. 

2.5 Oversee and monitor the development of next generation access networks (NGA)

Since there are other undertakings besides MEO in possession of ducts and posts which may be used by telecom operators in the pursuit of their activities, ANACOM intends to make an assessment of the extent to which the ducts and posts held by these undertakings are used, to ascertain whether there are other offers of ducts and posts in the market and whether these offers are being used.

2.6 Develop/consolidate the application of rules on access to infrastructure under Decree-Law no. 132/2009 of 21 May

Definition of the methodology to be used for setting levels of compensation for access to and use of infrastructure suitable for carrying electronic communications networks is expected to be completed in 1st quarter 2017.

2.7 Monitor and supervise the activities pursued by various sector agents, enforcing compliance with prevailing rules

In terms of supervision, a wide range of market enforcement actions are carried out every year, in order to check compliance with prevailing laws and determinations. Some of these actions are scheduled on an annual basis, while in other cases they stem from specific needs perceived following analysis of complaints received by ANACOM.

During the period of this Plan, a special focus will be given to the verification of matters related to consumer rights under sector legislation, in line with the work done in 2016. One of the actions to be undertaken is focused on verification of the conformity of electronic communications equipment under the new Radio Equipment Directive (RED) and Electromagnetic Compatibility (EMC), to determine whether they comply with the essential requirements of efficient and effective use.

2.8 Contribute to the review/negotiation of the new regulatory framework

Over the coming years, ANACOM will be intensely engaged in reviewing the new electronic communications regulatory framework. As part of its advisory responsibilities, and in work to define the Portuguese national position, ANACOM will promote contacts and hold workshops so that it can receive input from different stakeholders; ANACOM will also be responsible for conducting the negotiation process.

2.9 Prepare and submit pre-draft legislation to the Government for transposing the regulatory framework for electronic communications

This line of action includes the preparation and submission to the Government of pre-draft legislation with a view to transposing the regulatory framework applicable to the electronic communications sector, as currently under review at European level.

2.10 Review and consolidate procedures for the management of company registrations

In 2017, ANACOM plans to review and consolidate its procedures for the registration of companies which offer electronic communications networks and services and postal services. This action provides an improvement to conditions of market access by operators. By improving information and making procedures to commence commercial activities more transparent, market access conditions will be improved, with favourable impact on the sector's competitive situation. This action also involves the dematerialisation of processes, by providing electronic forms; this involves implementing software solutions to support the registration of companies and opening a reserved area on ANACOM's website.

Strategic priority 3: Ensure the efficient management of scarce resources

Lines of action:
 
3.1 Implement a plan of action for the 700 MHz band with a view to making it available
 
3.2 Evaluate, on a prospective basis, the development of various radiocommunications services and applications and spectrum needs associated with the provision of new electronic communication services.
 
3.3 Manage the PNN - Plano Nacional de Numeração (National Numbering Plan) establishing appropriate conditions in the context of the allocation of use of numbering resources.

3.1 Implement a plan of action for the 700 MHz band with a view to making it available

Under this line of action, it is ANACOM's intention to assign the 700 MHz band (and other relevant bands) considering the national interest, the European and national regulatory framework, the development of services, networks and technologies, as well as perceived evolution of the UHF band.

3.2 Evaluate, on a prospective basis, the development of various radiocommunications services and applications and spectrum needs associated with the provision of new electronic communication services

In 2017, ANACOM intends to begin the process of assigning and making spectrum available for electronic communications services, taking into account the objectives of regulation established by law, in particular the Radio Spectrum Policy Programme adopted at Community level, the 2019 World Radiocommunication Conference (WRC-19) and national interests in spectrum use. This work includes preparations for WRC-19, involving the creation of a national working group with external organisations, and making bands available for 5th generation mobile, M2M communications and IoT (Internet of Things).

Given the sector's constant evolution and dynamism, over the period of this plan, ANACOM will seek to identify emerging technologies and new models of spectrum management, as well as alternative techniques for sharing the radio medium and evolutionary scenarios resulting from new trends in spectrum management.

3.3 Manage the PNN, establishing appropriate conditions in the context of the allocation of use of numbering resources

Under the 2017-2019 Plan, provision is made for a range of actions related to the PNN and definition, from the outset, of a numbering range for M2M (if necessary including eCall) and preparation of a numbering regulation to update the principal elements of the PNN, which includes conditions governing the use of numbers. Provision is also made for the preparation of rules and the definition of conditions governing the use of calling line identification.

Under this line of action, provision is also made to conclude the review of the Regulamento da Portabilidade (Portability Regulation), began in 2016. This objective is expected for 2nd quarter 2017.

Strategic Priority 4: Promote institutional and technical cooperation

Lines of action:
 
4.1 Ensure active participation at international forums with relevance to the sector (electronic communications and postal services).
 
4.2 Maintain active participation in groups of European electronic and postal communications regulators.
 
4.3 Promote the sector at a national and international level and promote cooperation with other regulators.
 
4.4 Participate in the platforms of collaboration between Portuguese-speaking countries. 
 
4.5 Promote the dissemination of legal and regulatory regimes applicable to the sector.
 
4.6 Promote cooperation with national and international organisations and ensure coordination of activities in relevant areas.
 
4.7 Increase communication with society and market participants (seminars, workshops and hearings).

4.1 Ensure active participation at international forums with relevance to the sector (electronic communications and postal services)

ANACOM provides representation of the Portuguese State at international bodies of the communications sector and on international committees and working groups, where it is charged with the advancement of Portuguese interests and positions.

A range of actions are planned for 2017 in this context: presentation of a proposal to the Government that ANACOM cease providing representation of the Portuguese state at UPAEP - União Postal das Américas, Espanha e Portugal (Postal Union of the Americas, Spain and Portugal); promotion of Portugal's application to the secretariat of the European Telecommunications Satellite Organization EUTELSAT IGO; assessment of an application to the Council of the International Telecommunication Union (ITU) at the 2018 Plenipotentiary Conference (PP-18) and, if applicable, promotion of this application. ANACOM will also advance ways of improving its participation in the ITU, the Universal Postal Union (UPU) and the European Conference of Postal and Telecommunications Administrations (CEPT), in terms of efficiency and available resources.  At the CEPT, the activities taking place in 2017 at the Conference Preparation Group (CPG) will be particularly important given the WRC-19. ANACOM also provides representation of Portuguese State at the bodies with most focus on the implementation of EU policy and on regulation of markets and of the radio spectrum, with particular focus on the Radio Spectrum Committee (RSC) and the advisory group of the Radio Spectrum Policy Group (RSPG).

4.2 Maintain active participation in groups of European electronic and postal communications regulators

In 2017, ANACOM will develop extensive efforts towards the negotiation/review of the new regulatory framework, which will be decisive for the sector over the coming years, ensuring internal coordination of the national position and the pursuit of negotiations at European level in the review of the legislation.

ANACOM will maintain its involvement with the expert and ad-hoc groups of the BEREC and is due to take over as chair of one of the Expert Working Groups (EWG).

ANACOM also intends to maintain efforts in its participation in the European Regulators Group for Postal Services (ERGP).

4.3 Promote the sector at a national and international level and promote cooperation with other regulators

It is ANACOM’s goal to foster the transfer of knowledge and experience with other organisations.

During the period covered by this plan, ANACOM will continue to work towards this objective, while maintaining efforts in its participation in groups which bring regulators together, both in Europe and beyond, such as the European Mediterranean Regulators Group (EMERG) and Regulatel - Fórum Latino-americano de Autoridades Reguladoras das Telecomunicações (Latin American Forum of Telecommunications Regulators). In addition to its participation in the work of these groups, ANACOM is planning to organise a workshop.

4.4 Participate in the platforms of collaboration between Portuguese-speaking countries

As regards its participation in ARCTEL-CPLP - Associação de Reguladores de Comunicações e Telecomunicações da Comunidade dos Países de Língua Portuguesa (Association of Communications and Telecommunications Regulators - Community of Portuguese Speaking Countries), ANACOM will provide the secretariat of this organisation until 2019 and maintain active participation in its working groups. ANACOM also plans to assist in the organisation of workshops and seminars of the ARCTEL training centre and contribute to the completion of studies. At the same time, ANACOM will remain engaged in an important set of activities aimed at bilateral cooperation with CPLP countries, which includes making a priority of ongoing and future bilateral activities, and the strategic redefinition and implementation of bilateral cooperation protocols.

4.5 Promote the dissemination of legal and regulatory regimes applicable to the sector

ANACOM plans to undertake a range of dissemination actions as a result of regulatory changes, in particular as regards the dissemination of the ITED/ITUR regimes. Various seminars and workshops.

4.6 Promote cooperation with national and international bodies and ensure coordination of activities in relevant areas

The present amendment of Decree-Law no. 123/2009 of 21 May calls for intense activity by ANACOM, including coordination of the entities involved in the planning, construction and maintenance of infrastructure. From the outset, legislative changes will require modification of the Centralized Information System (CIS) in terms of infrastructure covered; this may lead to changes to the software which supports the platform and which compiles information on infrastructure suitable for carrying electronic communications networks. As such, further determinations will be needed, preceded by the relevant public consultation procedures.

4.7 Increase communication with society and market participants (seminars, workshops and hearings)

In pursuit of this line of action, which is aimed at strengthening ANACOM's relationship with society/market agents, ANACOM will hold seminars, workshops and other initiatives enabling the exchange of knowledge, experience and compilation of input on various relevant topics, in a context of greater market involvement.

In 2017, ANACOM plans to hold two workshops on the review of the new regulatory framework for electronic communications, and more in the following years.

Strategic Priority 5: Promote internal efficiency and effectiveness

Lines of action:
 
5.1 Implement measures to rationalise expenditure, guaranteeing efficiency
 
5.2 Improve/dematerialise/simplify internal processes and expand the provision of services online.
 
5.3 Implement a structured model of training and development aimed at excellence in human resources.
 
5.4 Consolidate an organisational culture more open to change.
 
5.5 Promote, to the extent permitted given legal constraints, a policy of incentives and development of professional careers, based on the recognition of staff performance.
 
5.6 Ensure better governance, management and operation of information security at ANACOM.

5.1 Implement measures to rationalize expenditure, guaranteeing efficiency

Cost reduction will remain a goal to be pursued by ANACOM. This objective can be achieved in several ways, including: the renegotiation of contracts, reduction in consumption, behaviour change, review and de-materialisation of processes.

The 2017-2019 period will be marked by the implementation of the strategic plan for information systems, which will improve the capacity of ANACOM's existing information systems, increasing their efficiency and significantly reducing associated costs.

ANACOM will also develop an integrated system of performance indicators, given the need for a review of indicators in the light of ANACOM's statutes. While ANACOM already has a system to monitor its activities, which enables it to oversee the evolution of its performance, taking into account objectives of continuous improvement, the goal is to improve this system.

5.2  Improve/dematerialise/simplify internal processes and expand the provision of services online

ANACOM seeks continuous improvement in its efficiency; as such, it will continue to launch projects which enable processes and procedures to be streamlined and which reduce the administrative burden associated with certain work practices. This may result in the release of funds to more added-value functions, while at the same time improving ANACOM's ability to respond to external requests – achieving an improvement in quality and response times. In some cases, dematerialisation also has an external impact, particularly in relation to cases involving services whose provision is brought online, simplifying ANACOM's relationship with its customers. The plan for 2017 includes the development of new features in software applications supporting spectrum management, the availability of spectrum management indicators and the launch of an amateur exam simulator.

5.3 Implement a structured model of training and development aimed at excellence in human resources

Excellence in human resources is a priority for ANACOM. For this purpose, a structured training and development plan has been put in place to provide staff with greater knowledge and new skills, so that ANACOM can face the future with increased optimism. With a current average staff age of 49 years, ANACOM will advance with a talent management programme, carrying out a diagnosis of potential with a view to the establishment of a management succession plan.

5.4 Consolidate an organisational culture more open to change

ANACOM will continue to promote a culture of dialogue at all levels of the organisation, as a way to consolidate the promotion of change.

Meanwhile, ANACOM will continue actions aimed at consolidating an "ANACOM culture" which is more open to society; these actions include social responsibility initiatives, such as actions in support of social solidarity institutions, engaged in individually by ANACOM staff and the development of an internship programme, facilitating the entry of young graduates with high potential into the labour market.

5.5 Promote, to the extent permitted given legal constraints, a policy of incentives and development of professional careers, based on the recognition of staff performance

ANACOM recognises how important it is to have staff who are committed to the organisation and its goals, and will make use of the most modern management techniques to promote excellence among its personnel. Accordingly, while taking into account the restrictive conditions to which staff have been subject in recent years, such as salary cuts, frozen career progression, lack of promotion, etc., ANACOM intends to identify specific incentive measures, taking into account persisting restrictions.

5.6 Ensure better governance, management and operation of information security at ANACOM.

This programme includes a set of actions focusing on organisation, processes, people and technology, enabling an improvement in ANACOM’s management of information system risks and enhanced information protection. The detail of the actions to be developed stems from an ongoing initiative, which will be completed towards the end of 2016 - one result is the specification of concrete actions to be taken in the 2017-2019 three-year period.