3 February 2000

David Mason
Secretary
E-commerce Reference
Human Rights and Equal Opportunity Commission
GPO Box 5218
Sydney NSW 1042

Dear David,

After studying your Issues Paper and Progress Update I would like to commend the Commission on its work so far in this important area.

I would also like to make a contribution to your research. But first I would like to explain the vantage point from which these comments are offered.

The Ability Research Centre has a significant role in the application and adaptation of computer technology for people with disabilities in Australia. Our work stretches from national research projects (in areas such as voice recognition and computers for people with brain injury) to hands-on computer training and support for hundreds of people with disabilities. We have conducted assessments for clients with a variety of physical, cognitive and sensory disabilities from all over Australia. We have a national as well as an individual perspective; we also have a research as well as a practical perspective.

My comments are as follows:

Many of the programs and initiatives canvassed in the Progress Update presume a level of access to a standard computer that is not available to many people with disabilities and older persons. I am not sure that the Commission has recognised the extent and significance of this need. To put it bluntly, an accessible Web page or Internet banking options are of no use to people who cannot use a standard keyboard and mouse and who are unaware of alternatives that may suit their special needs.

Some examples from our own experiences may illustrate this need:

• The man with a tremor who bumps the wrong keys as he types. He needed a keyguard.
• Another man with arthritis and experiencing the same difficulty only needed to be shown how to change a setting within Windows.
• The man with a fused wrist who needed an adjustable keyboard so that the right hand and left hand could operate at different angles.
• The young man with a brain injury who found it difficult to find the letters on a keyboard or the cursor on the screen. He benefited greatly from a talking word processor, a large coloured keyboard and a larger cursor.
• The woman with dyslexia who needed a speech recognition system in combination with a program to read text and screen items aloud.
• The girl who could only use two fingers of one hand. She was unable to activate key combinations until she was shown how to access Sticky Keys.
• The man who keeps forgetting basic functions, such as how to print. Until we designed a little on-screen movie for him that he can play as often as he likes, that explains to him how to print.
• The people whose disabilities are combined with language barriers, who need additional customisation in combination with access hardware and software.
• The many people who cannot use a standard mouse, because of spinal injury/brain injury/arthritis/MS/RSI/cerebral palsy, etc, and who have needed touch pads, trackballs, head-mounted pointing devices, laser-pointers, joysticks (with and without special switches), and many other options.

Our experience has taught us that a solution can be found for almost every person with a disability. The problem arises with the process by which the person with a disability becomes aware of the best computer access options available to them.

Clearly in many cases specialised equipment needs to be made available. A choice needs to be made from a range of available options. Assessments for such equipment are provided by only a handful of centres, including our own. These centres are all found in capital cities.

Without such advice, two things usually happen:

1. The person with a disability draws their own conclusion, perhaps based on a visit to the local computer store, that they will be unable to use a computer; or
2. A well-meaning relative or friend gives the person a second-best device that doesn't really solve the problem. In some cases it can make matters worse.

Page 6 of the Progress Update mentions that the computer loan scheme run by Technical Aid to the Disabled (TAD) addresses the need for some users to have specialised software and equipment. This is not the case, certainly with TAD in NSW. TAD refers such people to Ability (or an equivalent organisation) for advice on special equipment. The computers supplied by TAD tend to be 486 computers, without CD-ROM or modems, and tend to be "starting off" systems. They are not supplied with adaptive hardware or software and are usually not capable of running much of the specialised equipment available (such as voice recognition). The TAD computer loan system does not provide a solution to the problem of computer access.

The issue remains: how can this specialised knowledge be made available to more people who need it? This needs to be a major concern of the HREOC study. I offer a couple of suggestions:

Those in remote locations are the ones who are most disadvantaged in this process of obtaining information and advice on access options. This need is the focus of our research project, recently funded under the AccessAbility program. An outline of this project is shown as Attachment A. As you can see, it explores videoconferencing as an option for assessing the access needs of people in remote areas. It also examines the support needs of this group over an extended period.

There are many more useful adaptive devices available overseas than are made available in Australia. The Government's new CEtick system for computer equipment has had the unintended consequence of all but wiping out the possibility for organisations such as ours to import and sell small quantities of specialised products. It costs $1200 to get a product approved.

I would urge the Commission to recommend that the Government exempt products aimed to assist people with disabilities from this process, or else the Government should pay for the process of compliance itself in these cases.

It would make sense in a country like Australia for the Government to fund a process of research and evaluation of computer access products. Such an investment would greatly increase the knowledge base for all of those involved in adapting computers for those with special needs.

There is no substitute for hands-on exposure to new devices. People disadvantaged by disability and location need a way of testing devices to find those that are most suitable for them. At the moment a number of the organisations who provide assessments make sporadic visits to country areas. Perhaps the Government could stimulate these efforts by sponsoring a number of Open Days in regional areas on a regular basis. The Government could pay for a venue, arrange publicity and subsidise the travel costs of the services involved. Such sponsorship would work in conjunction with local/ services and groups.

I did not find any reference to datacasting/interactive television in the Commission's papers to date. I would urge the Commission to include this emerging technology in its deliberations. This technology likely to be a major means of electronic commerce in the future. It is also at a stage in its development where the Commission could make a difference in the way this technology is made available.

Attachment B shows a letter that was sent to the ABA last year. My concern is that the question of access to this new technology by people with disabilities has again been overlooked. What input methods do these devices allow? Do they allow the access devices currently used on computers to be used?

I would encourage the Commission to recommend, indeed insist, that these new television based technologies are accessible.

Many older people do not see themselves as disabled and may resist technologies and assistance targeted at the disabled (even if such technology is beneficial for them). Even though the needs are similar, the ways in which the people are approached must respect these differences.

We have found it helpful in our work with older persons to use different terminology. For instance, we sometimes use the term 'customisation'. We speak of the right of all persons to have the standard computer customised for their own needs. There is, after all, nothing sacred about the standard keyboard and mouse. Customising the computer to meet your needs is acceptable and sensible.

New banking technology has the potential to assist people with disabilities. Yet I have not detected a conscious effort on the part of banks to advise customers with disabilities about the options available to them. Not surprisingly, branch staff are not equipped to give this kind of advice. Nor would one expect them to be, given the wide range of disabilities in the community and the constantly changing technologies available. So we are left with a 'find it if you can' approach.

I believe the banks should pay for a joint information service. The service would be contactable through a variety of means (phone, fax, email, TTY) and would be staffed by people who are knowledgeable about disabilities and the various technologies relevant to banking. Customers enquiring about options that meet their special circumstances would be guided through the alternatives available at their bank.

Such a service would be expensive for individual banks to set up, but would be inexpensive if they provided a combined service. An undertaking should be given that the service would not attempt proselytise customers from one bank to any other.

I hope you find these comments helpful. I also wish the Commission well in its work and look forward to your final report.

Yours faithfully,

Graeme Smith B.Ec (Hons), B.D., M.A. (Hons)

Director

PS. You may wish to include our Web site among your resources: www.abilitycorp.com.au

People with disabilities who live outside capital cities lack access to specialised assessment centres (to determine the correct equipment they require to access a computer) as well as specialised support and training services. Travelling can be expensive and very inconvenient.

This project will test the viability of providing computer support and training for people with disabilities in remote locations from a base support centre, utilising modern communication technology. It will identify the support and training needs of new and experienced users.

The project will also test the viability of conducting assessments for computer access via videoconferencing facilities. This has the prospect of giving people in regional centres access to the best advice available without the need to travel to capital cities.

Both aspects of the project will take place in the Hunter region of NSW. The project is expected to start in February 2000.

Around 30-40 people with disabilities in the Hunter Region will participate in the study. Half of the participants will be experienced computer users. The other half will have computers provided for them. Each participant will have access to a modem and software; these will be set up by TAD members. The support base will be situated at the Ability Research Centre in Sydney.

New users with special access requirements will be offered an assessment via videoconference. This will involve a link between a videoconferencing centre in the Hunter and one at the Ability Research Centre.

For the duration of the project (9-12 months) participants will be offered technical support and advice. Telephone advice would be the first line of support, followed by direct modem link (whereby a technician could diagnose problems from the remote location). As a last resort, a support person will visit the person. All support needs and solutions will be documented on a database.

This project will give us important information about the varying support needs of experienced and new computer users with disabilities. It will show us which issues can be solved by phone, which can be solved by direct modem link and which still require personal visits. The project will also test the viability and cost of conducting access assessments via videoconference.

Once published, these results will provide guidance and encouragement to organisations around Australia who may be in a position to provide these services to their clients.

20 April 1999

Professor David Flint
Chairman
Australian Broadcasting Authority
Level 15, 201 Sussex St
SYDNEY NSW 2000

Dear Professor Flint,

I read with interest (The Australian 13/4/99 p. 53) that the ABA is to conduct a datacasting trial later this year.

New technologies open up exciting opportunities and options for people in our community. However people from our client group — people with disabilities — are sometimes left out. I am concerned that this might be the case with datacasting.

We have worked extremely hard to ensure that people with disabilities have access to computer technology and the Internet. We assess their needs and recommend a range of software and hardware tools that give them this access.

However the experience of ATMs in the banking industry, where the needs of people with disabilities were essentially overlooked initially, illustrates the potential danger of new technology for people with disabilities.

Datacasting, from my understanding, enables interactive services through some form of set-up box linked to a television and a phone line. Questions arise as to how people will send data in such a system. Will it be via a keyboard and/or a pointing device? If so, questions of access for people with disabilities arise.

My intention in writing to you is to seek your assurances that people with disabilities will not be overlooked in the rush to implement this new technology.

Yours faithfully,

Graeme Smith

Director