Prepared by Tim Noonan (trading as SoftSpeak Computer Services)

On Behalf of Blind Citizens Australia

More details on most of these issues can be found in my published report 'Accessible E-Commerce in Australia'. Because that paper is tutorial in nature, this response raises distinct issues that risk the accessibility and useability of EC facilities.

At present there are only two significantly developed zones of accessibility momentum – PC access, predominantly via Microsoft's Windows32 operating systems; and

Web accessibility, predominantly driven by the WAI (Web Access Initiative).

A third area with some work happening is the ATM and Information Kiosk area, but this is more often than not, still in the lab or user interface research phase of development.

Java accessibility is a further area with some promise, however it needs to be recognised that developers still need to add accessibility thought to design, and even if a JAVA program has accessibility hooks, the platform on which it is deployed also needs accessibility support.

This summary of accessibility developments is important to consider when we note recent projections in the IT industry that more than half of the internet connections by 2002 (or 2005 in other estimates) are expected to be from non-PC devices. This means that they will be from technologies which, currently, have no means of accessibility to their visual output.

This raises the important question as to how people will be able to access set-top-boxes, WAP-capable mobile phones, personal organisers, smart domestic appliances and the like, which are solely visual (and non-textual) in output.

The present frantic concern with accessibility to services, information and equipment by people who are blind and vision impaired may, at times, seem to be somewhat aggressive and emphatic. However this needs to be viewed in the context of the continually increasing reliance society places on the visual sense for information access and presentation. This is because computing, at present, is squarely seated in the visual domain of interaction.

Whereas people who have restricted movement have difficulties inputting information, people who are blind or vision impaired have often insurmountable problems accessing or interpreting the output from computers and other electronic devices – and at present it is access to output that is what the information society is all about. Although new technology offers potential opportunities to gain access to information which was previously inaccessible in its paper form, quite often it fails to do so.

It is a momentous challenge to actually convert a visual message, designed for the eyes into another modality (such as hearing or touch) in order for the person to substitute other facilities for restricted or non-existent vision.

Intellect is a leading manufacturer of magstripe and smartcard terminals. Many of Intellect's existing mag-stripe card readers are completely inaccessible to people who are blind, or who have prosthetic hands, because they are heat/touch sensitive. In an attempt to orient oneself to the keypad, the keys are triggered, making pin entry difficult or impossible.

Several years ago there was a positive and quite effective Australian project involving the Royal Blind Society of New South Wales, Woolworths Supermarkets, Ingineko (EFTPOS terminal manufacturers) and St.George Bank. this programme worked to make the Woolworths Supermarkets EFTPOS terminals more accessible. This involved designing and developing a brailled overlay for the keypad device, as well as a tactual representation on the under-side of the machine to tactually inform the user as to correct card orientation. These terminals have push buttons and some of them provide auditory (beep) feedback. This was a good example of minor relatively cosmetic alterations which improve the confidence of interaction for blind and vision impaired people in Australia.

All publicly available keypads should have a minimum of the following properties:

A. physical buttons which can be pressed.

B. Auditory and tactual confirmation of a button press;

C. conform to the telephone-style layout (1, 2, 3 as the top row of the number pad);

D. a dot on the five key;

(More information and guidance on display and bold print on keys can be obtained from the RNIB extract on smartcard terminals which appears at the end of this note.)

No Mag-stripe or smartcard balance readers or terminals are known of which can provide auditory output of transaction details.

A paper expansively covering Smart Cards in Australia is being prepared and should be available from Blind Citizens Australia shortly. It examines the potential impacts of Smart Cards on PWD.

It should be noted that although Telstra is aware of the smartcard standards efforts described in the RNIB extract below, It is our understanding that Telstra has no current plans to adopt these in its smartcard program. Since this program is not fully established, this is indeed a significant concern to people with disabilities, and says something about Telstra's widespread commitment to accessibility in design.

During the Olympics and its lead-up Telstra plans to issue 200,000 or 400,000 smartcards in Sydney. The majority of Telstra's pay-phones are smart-card capable and the new multimedia payphones, currently being trialed are based around smartcards.

At present people who are blind or vision impaired are able (with some obvious difficulties) to participate in the cash economy, sometimes being able to obtain cash via EFTPOS, ATMS or bank branches. The notes are different in length, facilitating accurate denomination in some situations.

Smartcards in widespread use for electronic purse applications present the possibility that blind people won't be able to transfer funds to their cards with independence or privacy. Because the advent of electronic purses will result in no change being provided after a transaction, the in-built check of the change that the correct funds have been taken is no longer available to the customer.

Although sighted purchasers can see the display on the vendor's counter, and have some confidence that their transaction went as expected, this isn't an option for blind customers. Similarly, banks and other providers are expected to issue portable, low-cost card balance readers (maybe in the form of a key-ring) but the displays on these devices are very difficult for anyone to easily read, let-alone a person with severe vision impairment. Obviously someone who is blind will be unable to access the display.

PCs may be one means of being able to gain access to card balances and the like, but this will be dependent on the security adopted by the smart-card reader device manufacturer. Will the card reader have an internal display, or will it use the computer's screen to display balance and transaction information? If it has an internal display, then its not likely it will be accessible.

Future mobile phones are another area where smartcards will be in widespread use. The phone may be able to support two smartcards – one the SIM containing the details of the user and telephone service, the other supporting a smartcard for E-Commerce facilities.

Because the screens of mobile phones are unusable by most blind or low vision individuals, the use of this device for accessing smartcard details will be limited. A possible solution to this would be to integrate phone-network-based audio IVR technology which accompanies screen display so that a person can use their phone to check details on their smartcard. This would support a range of people who are non-visual, and who want audio feedback of what is appearing on their phone display when using their smartcard.

Most internet banking sites and custom online banking packages are just impossible to access using adaptive technology for people who are blind or vision impaired. If they aren't impossible, they, generally, are extremely cumbersome to use. Considering that it is difficult to access statements and balances, as well as problems with accessing printed literature from banks, access to online banking services would be of particular benefit to people who are blind or vision impaired.

The excessive and often exclusive 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 go to all the effort of downloading and converting the PDF file, you have 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.

Even using the optionally down-loadable access plug-ing for Adobe's reader, crucial formatting information is lost when the plug-in converts the information.

Following is an extract from a RNIB publication on electronic purses relating to accessibility: titled 'What is an electronic purse?' from the section titled 'Recommendations'. 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 their designs with a cross section of potential users, which will include disabled and elderly people. Good design for people with disabilities is frequently good design for everyone.

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, as shown.

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, eg. 'Screenfont', see web site www.eyecue.co.uk/tiresias.

It is useful to have a funnel opening to guide the card into the reader; this is particularly helpful for users who have low vision or hand tremor.

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.

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).

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 close to the high-contrast visual display.

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 prEN 1332-4, see Standards ).

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 0.02% of the population; so although useful for

some blind users, braille is not a total solution for visually impaired users.

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.

Serious consideration should be given to training in the use of the 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.

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 to show pictorial 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 J M & Devine-Wright H

Selecting Cards by Touch

ISBN 1 86048 0195, March 1999, 24 pp. Online at http://www.tiresias.org/tdiff.htm#selectingcards

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-service 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"