Additional Submission to
HUMAN RIGHTS AND EQUAL OPPORTUNITY COMMISSION
on
Issues Paper: Accessibility of electronic commerce and other new service delivery technologies for older Australians and people with a disability
by
ACROD Ltd
and
the Australian Blindness Forum
29 November 1999
(to be read in conjunction with the Submission
dated 11 November 1999)
Introduction
ACROD
and the Australian Blindness Forum (ABF), since making a submission to HREOC on 11 November, 1999, have received additional information that they consider to be supportive of that submission. This information relates to two areas: World Wide Web Page Accessibility Audit and Accessibility of ATMs, Information Kiosks and Other Specific Purpose Devices.Specific comments
World wide web page accessibility audit
Many web sites are poorly designed. Many sites, include government, use frames for text only sites, even though these are overly complex to understand for most text-oriented users. The relatively simple solution is to conform to W3C recommendations.
Most telephone banking sites or custom software are impossible for people who are blind or vision impaired to access, or are extremely cumbersome to use with adaptive technology.
The excessive use of PDF for presentation of electronic documents is very unfriendly to people who are blind or vision impaired. PDF is a black box – until you download and convert the PDF file, there is no way of knowing whether what it contains is of actual use, interest or even accessible. Both PDF and HTML or text versions of online documents should always be made available to meet the widest possible range of needs.
Accessibility of ATMs, information kiosks and other specific purpose devices
Smartcards are expected to be in wide use in Australia in the next few years. People who are blind already encounter difficulties with the polymer-based cash currency Australia uses and the advent of electronic purses has the potential to be even less friendly. For example, it may not be possible for people who are blind to transfer electronic cash to their electronic purse-smartcard via the Telstra public phone network due to inaccessibility and lack of voice output. This means that people will need to rely on friends and family to perform these fundamental activities, further reducing independence and rights to privacy.
Australian banks have yet to seriously address the needs of people with disabilities in accessing ATM facilities. The trends in Northern America demonstrate that voice output ATMs are practically and affordably possible.
Certain EFTPOS terminals are completely unusable for people who are blind or have low vision. These are so touch-sensitive that just feeling the keypad to establish positioning triggers button presses, making PIN entry next to impossible. Conversely, these same keypads are also difficult for people with prosthetic hands as they cannot trigger the button-presses.
All publicly available keypads should have a minimum of the following properties:
Extracts from "What is an electronic purse?" from the section titled Recommendations, published by the Royal National Institute for the Blind follow. This publication is online at http://www.eyecue.co.uk/eyecue/e.purse/reader/menu.html
"If electronic purses become as widely used as planned, they may become the only acceptable way of payment for some services. The current designs for electronic purses raise concerns about the way elderly and disabled persons will be able to use these systems. If the purse systems are not well designed, they could exclude many potential users. The following recommendations address some specific problems. Our aim is to encourage all designers to test designs with a cross section of potential users, including disabled and elderly people. Good design for people with disabilities is frequently good design for everyone.
Numeric and command buttons
A standard layout for keypads is recommended. There are two common layouts for numeric keys: the telephone layout and the calculator layout. It is recommended that the telephone layout be used.
Screen displays
A high contrast display with larger characters will significantly improve legibility for most people with low vision. A typeface with clear and easy to distinguish characters should be used, for example, 'Screenfont' (see website www.eyecue.co.uk/tiresias
Card entry
It is useful to have a funnel opening to guide the card into the reader – this is particularly useful for users who have low or hand tremor.
Larger buttons and tactual feedback
Larger buttons which have clear visual markings and tactual feedback should be used. Tactual indication can be provided by a gradual increase in the force, followed by a sharp decrease in the force required to actuate the key, and a subsequent increase in force beyond this point of cushioning. To help blind people, there should be a single raised dot on the number 5 key. This should be positioned so as not to reduce legibility.
Card orientation
Blind persons, and many elderly persons, have problems in inserting the card in the correct orientation. All electronic purse cards should include a tactile identifier for card orientation (in accordance with standard EN 1332-2).
Access to terminals
At the retailer's premises, it is important that the visual display is positioned such that the customer can easily read it before agreeing to the completion of the transaction. For customers with low vision, this requires that they can get to the high contrast visual display.
Speech output
The possibility of speech output for some devices should be considered. If this is not wanted for all customers, this requirement could be coded on the user's card (in accordance with standard EN1332-4, see Standards).
Braille
In outdoor conditions, braille has limited value in cold weather since tactual sensitivity is dramatically reduced with decreasing temperature. The estimated number of braille readers in Europe is less than 0.2% of the population, so although useful for some blind users, braille is not a total solution for visually impaired users.
Screen phones
For visually impaired persons, provision of adapted screen phones at affordable prices is likely to be crucial if they are not to be excluded from using electronic purses. These phones might offer other facilities such as caller line identification and access to home shopping services.
Training
Serious consideration should be given to training in the use of the electronic purses and the systems they link into and who is responsible for providing this training. Training schemes should include production of clearly written instruction booklets in large print.
Keeping communications simple
Given that retail or public transport environments tend to be bustling and distracting places to be in, all designs should aim to make electronic purse systems as simple to use as possible. Communication between the devices, terminals and the user should be direct and simple. For example, for intellectually impaired persons, it might be useful to have a simple balance reader which shows the balance pictorially or have that person's card specially coded show pictorial information.
Further information
The publication "Access Prohibited? Information for Designers of Public Access Terminals" gives detailed information on the design of public access terminals. This is available on the world wide web at www.eyecue.co.uk/pats
Since the above report was written, a further standard is being drafted which allows different smartcards to be tactually differentiated from one another:
Gill JM & Devine-Wright H "Selecting Cards by Touch" ISBN 1 86048 0195 March 1999, 24 pp, online at http://www.tiresias.org/tdiff.htm#selectingcards
'Preface
For a blind person, or someone suffering from impaired vision, tactile markings are not just useful, they are essential to enable that person to identify items by touch. On behalf of all the blind and visually impaired people of Europe, I welcome this report. It calls on card issuers to incorporate embossed symbols on all cards to help people differentiate one card from another. This is absolutely necessary when we have to deal with so many cards. It explains appropriate ISO and CEN standards and proposes a new CEN standard. This will meet the needs of those having to operate self-serve terminals, giving them the independence and privacy which they need and deserve. I commend the report and congratulate its authors on a job well done.
John Wall, President, European Blind Union'"
Margaret Verick
Policy Officer (Blindness and Vision Impairment)
ACROD
PO Box 60 CURTIN ACT 2605
Phone: 02 6282 4333 Fax: 02 6281 3488
Email: abfver@ozemail.com.au