By

Brian Hardy, (Project Manager Information Services) and

Geoff Payne (General Manager Information Services),

Vision Australia Foundation

Contact Details: hardyb@ozemail.com.au (03 9864 9525) and geofpayn@ozemail.com.au (03 9864 9280)

11 November 1999

Page

Summary of Recommendations 3

Vision Australia Foundation 5

Context of this Submission 6

Comments on Specific Aspects of the HREOC Issues Paper 7

Details of Recommendations

Support for the Work of the HREOC Inquiry 17

Conclusion 18

Achieving equal access to on-line and e-commerce services for older Australians and Australians with a disability needs action on two fronts. Action should be taken by the suppliers of these services to ensure that the requirements of older people and people with a disability are recognised and taken into account. But action also needs to be taken to ensure that people with a disability and older people are informed about on-line services and e-commerce, have the skills necessary to use them and have ready access to the mainstream and specialised equipment they require to use these services effectively.

While the whole community can contribute, governments at all levels will need to take a lead role if the objective is to be achieved. Governments need to be exemplary role models, to be champions of new initiatives, to support, encourage and cajole the industry to implement good practice and they need to create and enforce a regulatory and legislative environment that sets out clearly the obligations and responsibilities of service providers with respect to equity of access. They also need to provide strategic investments of resources to overcome some of the barriers to access.

Within this overall context, the specific recommendations of this submission are:

1. The Commonwealth Government must take a leading role in promoting the importance of ensuring that older people and people with disabilities are able to effectively access on-line services and e-commerce. This role should include:

• Implementing appropriate standards of practice consistently across all Commonwealth Government Departments and Agencies
• Using its departments, agencies and programs to actively support and encourage all other providers of on-line services and e-commerce to enable older people and people with disabilities to have effective access.
• Supporting international developments in standards and technology that will have the effect of improving access for older people and people with disabilities.

1. State Governments need to take a similar leading role in demonstrating good practice and in encouraging actions that have the effect of promoting accessibility of on-line and e-commerce applications and services.
2. Commonwealth and state governments should be more pro-active in introducing on-line services and e-commerce to older Australians and Australians with a disability. Existing initiatives such as Seniors Online and SkillsNet in Victoria are excellent, but they need to be supplemented by information through a much wider range of channels and in a much wider range of formats. This will enable people to make an informed decision about the value of these services to them personally and about the ways in which they can access them at reasonable cost.
3. The obligations of online and e-commerce service providers with respect to access under the Disability Discrimination Act should be equivalent to those applying to the providers of physical services. HREOC Guidelines need to be strengthened to make the obligations of on-line and e-commerce service providers more clear-cut and explicit.
4. Commonwealth and State Governments need to take action to ensure:

• that information on what is required to make on-line and e-commerce services accessible, is widely available and is pro-actively disseminated to the managers of these services;
• that training in developing accessible on-line and e-commerce services is readily available through both short courses and post secondary training;
• that training of health professionals and computer technical staff in assistive technology is available to meet the growing needs of this industry.

1. Commonwealth and State Governments need to take steps to address the barriers to access created by the additional costs faced by people with disabilities in accessing information technology, whether these costs are incurred directly by the individual or indirectly by organisations seeking to provide low cost open access facilities (eg libraries and community organisations). These costs include:

• The costs of assistive technology that enables people with a disability to use a computer (eg special software or hardware or additional peripherals on top of standard computer costs);
• The costs of specialised assessments to recommend appropriate assistive technology systems to enable people with a disability to achieve their goals;
• The costs of training in the use of assistive technology and the extra costs of training a person who uses assistive technology in standard computer applications.

7. The provision of open-access low-cost technology facilities is a viable and effective means of expanding access to people with limited financial resources. To be successful these facilities:

• Must be accessible for people with disabilities (physically) and be equipped with a range of assistive technologies
• Should have staff available to assist people who are inexperienced with support for general computer problems and to help a person using assistive technology to set up and rectify basic or minor problems.

7. No matter what governments and providers of on-line and e-commerce services do, it is inevitable that some people will not be able to access these services. To ensure that people are not deprived of critical information or vital services, there must always be alternative methods of accessing the service or information that are readily available and clearly advertised.

Vision Australia Foundation is one of Australia's major not-for-profit organisations. Our mission is to reduce the impact of aging and disability on the individual. Enhancing the access of people with disabilities to information is one of our major aims.

As part of our work in this area we have established a Technology Service. This service employs a multi-disciplinary team of occupational therapists, speech pathologists and technical staff to provide assessment, training and support to help people with disabilities to have functional and efficient access to assistive technology. Assistive technology relevant to this submission includes alternative access systems and sight enhancement and sight replacement technology.

The work of the Technology Service gives us direct experience with the issues faced by people with a disability in gaining access to the benefits of on-line service delivery and e-commerce.

Vision Australia Foundation also provides a web accessibility consultancy service. This business works closely with government departments and major corporations to help improve the accessibility of their web sites in accordance with the W3C Web Accessibility Initiative Web Content Accessibility Guidelines.

Vision Australia Foundation operates in partnership with the Adaptive Technology Resource Centre (ATRC) at the University of Toronto in Canada. The ATRC is one of the leading institutes in the world working in the areas of web accessibility and assistive technology. They are playing a major role in the W3C Web Accessibility Initiative.

Vision Australia Foundation liaises with people and organisations throughout Australia that are interested in promoting the access of people with a disability to current information technology developments. We are aware of two other submissions to this HREOC Inquiry that will cover issues similar to those that concern us. These submissions are:

• A submission by Tim Noonan based on his work for Blind Citizens Australia funded by a grant from the Commonwealth Government AccessAbility program. This work is available at www.bca.org.au/ecrep.htm. This is a thorough and comprehensive review of the issues that people with a disability face in making use of new developments in information and communications technology. We endorse the findings of this study and strongly support the recommendations in the report.
• A submission by Larry Stillman, Dr Kirsty Williamson and Amanda Bow. This submission discusses issues related to Equipment Selection and Adaptation for Public Environments and Web Standards, Accessibility and Useability. We endorse the recommendations of this paper, although we believe some of them need to go further.

The Issues Paper raises many questions on which comment is sought. Most of these questions are addressed through the detailed discussion of our recommendations set out later in this submission. However there are two matters on which we would like to comment that are not incorporated in our discussion of recommendations.

The HREOC Issues Paper (page 5) indicates that there are 122,000 people with a vision impairment, as reported by the Australian Institute of Health and Welfare. We believe this figure significantly underestimates the number of vision impaired people in Australia who face serious difficulties in accessing on-line and e-commerce services.

US data estimated from the US National Health Interview survey 1989-1994 estimates that 2.6% of the population has a vision impairment. Projected onto the Australian population this would indicate that 487,500 people in Australia have a vision impairment.

This estimate of the number of people with a vision impairment does not include people who are colour blind. Colour blindness can cause a significant problem in using some on-line or e-commerce services. Estimates of the incidence of colour blindness suggest that well over 500,000 people in Australia are affected.

The Issues Paper requests examples of good practice in pages offering effective accessibility. Vision Australia Foundation has worked with several government departments to improve the accessibility of their web pages. The W3C Web Accessibility Initiative Web Content Accessibility Guidelines were only released in May this year so there are few significant sites that have achieved full conformance, but many sites have substantially improved their accessibility as a result of following these guidelines.

• The Gold Medal site of the Department of Family and Community Services (www.goldmedal.gov.au) is one site that appears to have fully met all the checkpoints in the WAI Guidelines.
• A web site commissioned by OASITO to support the recent partial sale of Telstra (www.t2.telstra.com.au ) consistently achieved a very high level of accessibility despite the need for many rapid updates of content and of the on-line forms that were needed through the short period of the share offer.

There are several other sites managed by Commonwealth and Victorian Government departments and agencies that are currently being redeveloped to comply with the WAI Content Guidelines. Some of these new or revised sites should be launched before the end of the year. Details of these sites are available on request from Brian Hardy (hardyb@ozemail.com.au or Mobile: 0419 102 451).

The Commonwealth Government needs to be an effective role model in delivering accessible on-line and e-commerce services. The services the government delivers are important in the lives of every Australian, particularly older Australians and people with a disability. This is equally true of on-line services. Much of the information provided on-line by the Australian Government is also important in assisting Australians to exercise their rights and responsibilities as citizens. Older Australians and people with a disability must not be disempowered as citizens by lack of access to this information in an accessible form.

The Government also needs to have credibility when it urges other suppliers of on-line and e-commerce services to ensure their services are accessible. Demonstrating how it can be done effectively and economically is an important role for the Commonwealth Government.

In implementing a program to bring all Commonwealth on-line and e-commerce services up to a fully accessible standard we strongly support the staged approach recommended by Jakob Nielsen. Mr Nielsen is one of the world leaders in web site useability and has set out a sensible strategy for prioritising standards compliance, proposing a staged rollout of accessibility.

The Departments and Agencies of the Commonwealth Government have enormous capacity to influence the development of accessible on-line and e-commerce services across the community and in ensuring that particular groups are not denied access. For example:

• Many agencies are directly involved in promoting the development of on-line and e-commerce services and in working with the IT and communications industries.
• The Commonwealth Government can use its direct purchasing policies to ensure that the information technology products and services it buys are accessible by its own employees with disabilities (as is being done by the US Government).
• The Commonwealth Government can use its influence with the States to encourage a coordinated national approach.
• Commonwealth Government programs can provide direct support to individuals to enhance access to IT training, to assistive technology and to professional assessment.
• The Commonwealth Government can use its legislative powers to ensure that the Disability Discrimination Act is adequate to outlaw discrimination in this area.

The World Wide Web Consortium (W3C) through its Web Accessibility Initiative (WAI) is promoting the development of accessible content; authoring tools that assist in developing accessible content; and user agents (browsers and assistive technology) that are able to manage a broader range of content. The Commonwealth Government should use its international influence to support the development of better standards for information and communications technology so that the technology creates fewer barriers for older people and people with disabilities and/or that actually enhances the capabilities of people with a disability.

State and Territory Governments (like the Commonwealth Government) have already taken some action to improve access to on-line and e-commerce services for older people and people with a disability. Tasmanian Communities On-line and the SkillsNet program in Victoria are just two examples. However much more needs to be done to achieve any significant effect. The actions that State Governments need to take are similar to that already proposed for the Commonwealth Government.

These include:

• Using their own on-line and e-commerce services as exemplars of good practice;
• Directly assisting people with disabilities to acquire the assistive technology they need and the training to use it effectively;
• Using their purchasing power to drive product change;
• Ensuring that their equal opportunity legislation is adequate to cover the areas of virtual services in the same way in which other services are covered;
• Working at the national level with other states and territories and the Commonwealth Government.

Vision Australia Foundation has recently completed a project to identify the areas of support that our 20,000 clients with late onset sensory loss most need in relation to enhancing access to information technology. The overwhelming priority for our clients was for basic information - information about the technology, its capabilities and about how someone who has no experience in the area and has a disability can make use of the technology to achieve something important in their lives. The majority of our clients are over 50 years of age. Many feel apprehensive about the new technology and intimidated by "experts". Their first need is for basic information provided in a familiar environment in straightforward language. This empowers them to make an informed decision about whether and how they will use the opportunities the technology provides.

Consistent with this approach, on-line information needs to be made available as part of ordinary life, without having to make an explicit decision to access complex and unfamiliar technology. This submission is promoting the value of open access technology facilities equipped and supported to enable access by people with disabilities. However these facilities will have limited value for people who are unfamiliar with the use of current technology.

The Victorian Government is proposing to trial the provision of on-line health information in places such as hospital waiting areas and community facilities. They intend to use simplified computer browsers and terminals accessing a range of "safe" sites. Their aim is to provide Health Information, not to promote Internet access. In our view this approach of focussing on the product, not on the medium of the message, is an important strategy in improving access to on-line services and e-commerce.

It is our understanding that the jurisdiction of the Disability Discrimination Act has not been tested in the area of on-line services and e-commerce. As an absolute minimum this Inquiry must ensure that the applicability of the legislation to virtual services is certain. The current HREOC Guidelines need to make clear and unequivocal the obligations of service providers to deliver accessible services.

While the population of older Australians and people with a disability is significant, commercial imperatives will not be sufficient to ensure accessible on-line services. Even governments, with their clear obligations to all their citizens, have failed to deliver accessible on-line and e-commerce services. We believe that only a legislated obligation is going to ensure that this happens in Australia.

• that information on what is required to make on-line and e-commerce services to be accessible is widely available and is pro-actively disseminated to managers of these services;
• that training in developing accessible on-line and e-commerce services is readily available in both short courses and in post secondary training;
• training of health professionals and computer technical staff in assistive technology is available to meet the growing industry needs.

The inclusion of accessible design principles in tertiary training is important in providing future skills in this field. The Commonwealth Government in conjunction with the States and Industry has the capacity to make sure that this happens. Action in this area is urgent and overdue. To improve the skills and awareness of current engineers and web designers, the Commonwealth and State governments should support and promote short training programs. These programs are already available and could be delivered quickly and effectively throughout the country. However engineers and designers will only attend these programs in large numbers if they have a strong incentive to do so. This means that the providers of on-line and e-commerce services (who employ or contract the engineers and designers) must have compelling financial or legal reasons for ensuring their services are accessible.

Managers of on-line and e-commerce services also need clear information on what is required to make these services accessible. There is a lot information available from many sources, but most of it is not targeted specifically at service managers. The development and pro-active dissemination of management oriented information is critical if attitudes and behaviour are to be changed. The engineers and designers may have the skills to produce accessible services, but they cannot act independently. Management must be convinced that it is essential and must understand what is needed to achieve accessibility.

In Recommendation 6 we talk about the importance of professional advice in setting up and maintaining assistive technology systems. Both health professional and computer technical support staff need to develop knowledge of and skills in working with the wide range of assistive technology now available. In our experience this expertise is almost non-existent outside of the staff already directly working in this specialised field. This means that computer support people are reluctant to touch a computer that has assistive technology loaded on and health professionals are unfamiliar with the potential and limitations of this technology. To our knowledge, assistive technology options are not available in most health professional or computer courses and there is no short course infrastructure to fill the gap. This is an issue that should be picked up by State, Territory and Commonwealth Governments in the context of their responsibility for the post-secondary education system and by the relevant Industry Training Boards covering the Health and Information Technology industries.

Many older people and people with disabilities will still face insuperable barriers to some on-line and e-commerce services, even if service providers meet all their obligations to accessible service delivery. Both these groups face a cost barrier in common with many other financially disadvantaged people. Basic information technology is still quite costly to obtain and to operate. This problem can be addressed in some ways by the support of open public access facilities and discounted on-line charges.

However many people with a disability face even bigger cost barriers. These extra costs are in three main areas:

• The cost of assistive technology required by some people to enable them to access or use many forms of information technology
• The cost of specialised assessment to identify the assistive technology most appropriate for a person's needs and goals and to set up and maintain an integrated system of technology, support and training
• The cost of training in the use of assistive technology and the extra costs of training in mainstream applications faced by many users of assistive technology

The costs of assistive technology range from modest to substantial. For example:

• A person with a physical impairment who needs to use a non-standard keyboard and keyguard or a trackball instead of a standard mouse would face additional costs ranging from $170 to $450.
• A person who has no useable sight may need a system including a screen reader software program, a scanner and an optical character recognition program. The cost of such a system would be approximately $3,500 on top of the cost of a basic computer.
• A person with low vision, but with some useable sight, may need a large screen monitor and monitor arm, a screen magnifying program, some additional lighting and a document holder. The approximate cost of such a system would be $3,000, on top of the cost of a basic computer.
• A person with a severe physical disability may need a complete alternative access package including switch system and mounting kit, on-screen keyboard and mouse, rate enhancement package and wheelchair accessible desk. The approximate cost of such a system would be $5,000, on top of the cost of a basic computer.

Specialised assessment to ensure that an assistive technology system is appropriate for an individual's goals and needs is essential. The range of assistive technology is enormous. For example, Vision Australia Foundation Technology Service can use 25 different mouse or mouse alternatives as part of our client assessments. This is a representative set from the total range in the market, which numbers in the hundreds. As part of a client assessment, our Technology Service may consider 10 fundamentally different keyboard options, 6 screen reading software programs and 3 screen magnifying programs. Most of this equipment needs to be customised for the individual user, and this needs to be done before final decisions can be made about what combination of equipment is likely to be most appropriate.

These different equipment options are used by our professional team to identify the elements of a system that will be mostly likely to enable a person to achieve their goals. Assessment with a client involves consideration of a range of factors in addition to a person's particular impairments. These include:

• A person's goals;
• Their capacity and motivation to undertake the training and practice necessary to gain the skills required to use the technology effectively;
• The environment within which the system will be used;
• The support that is available in that environment;
• The resources available to the person to purchase equipment.

In our experience, purchase of assistive technology without a thorough understanding of the range and features of alternative options, and of how that equipment can be made into a system that supports a person's particular goals, leads to very poor outcomes - in many cases complete failure and frustration or, at best, very sub-optimal achievements.

The cost of a comprehensive assessment and basic training in the use of any recommended equipment varies widely depending largely on the goals a person is trying to achieve. Indicative costs range from $500 to $3,000 or even more. Currently, there is very limited public funding for such assessment services, so this represents another substantial cost barrier to accessing on-line and e-commerce services faced by people with a disability.

The final particular cost barrier faced by people with disabilities is training. This comprises two elements. Training to use some assistive technology requires resources. Many of the software programs include self-directed training, but for people without a prior high level of computer skills this form of learning may not be enough. Training in these programs usually needs to be one-on-one and to be conducted by a specialist trainer. The costs will vary considerably from person to person, but a cost of approximately $500 to become basically proficient in one assistive technology program would be common.

The other additional cost is incurred in gaining skills in the use of mainstream information technology applications. SkillsNet in Victoria estimates it takes 5 hours on average for a computer novice to learn the skills needed to send and open e-mail and develop basic Internet skills. A novice assistive technology user, but one who has had basic training in using their assistive technology, is likely to take 20 hours to achieve the same learning outcome – incurring four times the training costs.

The various cost barriers identified in this discussion will be overwhelming for most people with a disability. There are some ways to mitigate some of the costs, through the use of volunteers for instance, but the total of the financial commitment required will mean most people with a disability are locked out of accessing on-line services and e-commerce. These individual cost barriers can only be overcome through concerted Commonwealth and state government action and the allocation of public resources to the issue. The number of individuals who need expensive technology, assessment and training will be a very small part of the overall population, so the total cost of any government support will be modest.

Governments and community groups have set up open access information technology facilities throughout Australia. However very few have set up facilities that successfully incorporate assistive technology. Some non-government organisations have established small projects with the support of the Commonwealth Government AccessAbility grants and there will be more outlets established under the 1999/2000 program. AccessAbility also funded a project to address the issues of public access assistive technology systems. This project is discussed in the Submission to HREOC from Stillman, Williamson and Bow (Equipment Selection and Adaptation for Public Environments). Their project examined the type of equipment that may be suitable for installation in public libraries. In our view this project did some good work, but there are questions about the specific recommendations in relation to preferred equipment set up. One weakness of the recommendations of this project is that they do not give sufficient emphasis to the issue of providing support to users in public environments.

The ready availability of skilled support will be critical to the success of any attempt to provide assistive technology systems in open access environments. Particularly for users who are inexperienced, this support needs to available as people need it, so that simple difficulties do not discourage use of public access facilities.

For someone using assistive technology, they may need support:

• To orient themselves to toilets, exits etc.;
• To identify those computers fitted with the appropriate assistive technology;
• To connect appropriate peripheral devices;
• To start the computer;
• To adjust furniture, monitor arms etc.;
• To activate assistive technology in accordance with settings and instructions carried by the user;
• To activate accessibility options built into standard operating systems or browsers in accordance with settings and instructions carried by the user;
• To obtain simple feedback (if they are unsighted) about what is happening on a screen if the system has malfunctioned or if a web site has caused some totally unexpected event.

The skills needed to provide this low-level support could be learned easily and quickly. However if they are not available, an open access facility cannot cater for the needs of the majority of people with a disability that use assistive technology.

Vision Australia Foundation has extensive experience working with people who have a print disability that prevents or restricts their capacity to access information through the medium of print.

There are many reasons why a person may have a print disability. These include:

• Illiteracy in any language;
• Illiteracy in English;
• A physical impairment that prevents a person holding or managing a book, a brochure or a newspaper;
• A cognitive impairment that prevents a person processing information presented in a written form;
• An intellectual disability or an acquired brain injury that makes comprehension of complex information in any form difficult;
• A vision impairment.

The diversity of the population of people with a print disability means that there is no one solution to meeting their needs for information. In our experience information must be presented in a variety of formats and through a variety of mediums if it is to reach the whole population.

Similar issues apply in ensuring equitable access to on-line and e-commerce services.

Action to ensure that on-line and e-commerce service providers take into account the needs of older Australians and people with a disability are important. Actions by Government to overcome the cost barriers faced by people with a disability will be of great assistance. However, some people will still be unable to use these services directly.

For these reasons it is important for several alternative approaches to accessing information to be provided in addition to an on-line service. These should include different formats of information delivery (eg audio, ordinary print, large print and Braille), different mediums (radio, telephone, telephone based browsers etc.) and there should always be a capacity to receive individual assistance or information directly from a skilled and knowledgable person, over the telephone or in person.

Vision Australia Foundation would be pleased to support the Commission in gathering further information for this Reference.

For example:

• Vision Australia Foundation could host a meeting of HREOC and the individuals and groups from Victoria that have made submissions to the Inquiry. VicNet have indicated an interest in working with Vision Australia Foundation and HREOC to organise such a meeting
• Vision Australia Foundation would be pleased to assist in organising focus groups of older Australians and Australians with a disability to discuss issues with HREOC staff
• Vision Australia Foundation can arrange demonstrations of an extensive range of assistive technology so that HREOC staff and Commissioners can appreciate at first hand the potential and limitations of this technology.

If you would like to follow up any of these proposals or would like Vision Australia Foundation to assist in any other way, please contact Brian Hardy on 03-98649525, mobile: 0419102451 or e-mail: hardyb@ozemail.com.au

Vision Australia Foundation applauds the decision by the Attorney General to give a Reference to HREOC to investigate this important issue.

This submission has focussed on those aspects of the Reference in which Vision Australia Foundation has some specific and unique experience. The recommendations are intended to address the fundamental problems that we have found through our practical experience in working with people who have a disability and with the providers of on-line and e-commerce services

We would be pleased to expand on any aspects of this submission in person or by teleconference. Contact details for the authors are provided on the front page of this submission.