A Submission to the Human Rights and Equal Opportunity Commission Inquiry into
"Access to Electronic Commerce and New Technology Services by Older Australians and People with a Disability"

Dr Julia Schofield
Jonathan Roper
Justin Flute

19 November 1999

JSC Australia Pty Ltd
E-mail jsc@jsc.com.au

All comments are based on international practical experience over 9 years of work including, where appropriate, user trials. Individual circumstances may alter cases and approaches taken.

This submission to the Human Rights and Equal Opportunity Commission provides comments from JSC Australia Pty Ltd (JSC) on the issue paper titled 'Accessibility of electronic commerce and other new service delivery technologies for older Australians and people with a disability'. The comments are based on JSC's Australian and international experience (JSC Australia has a partner company in Europe Julia Schofield Consultants Ltd who have worked in citizen-centric multimedia systems production specialising in this field since 1983).

Domestic computer use has increased dramatically. It now creates opportunities, sometimes causing temporary barriers and enabling much greater independence. For the groups specified education, work, leisure and quality of life are key. Research alongside leaders such as the Trace Center in Wisconsin for over 15 years, Victoria Government, St Thomas Hospital (London) has proved invaluable. An important finding is providing for all groups together without separating them, unless it is for an individual solution. A second important consideration is maintaining attractiveness and functionality for the population as a whole, while providing also for the groups quoted.

Although there are web guidelines from W3C and brilliant research work from units like the Trace Center, knowledge within the private and public sector is minimal. Fierce criticism of attempts to help may not get the desired affect. It is not sufficient to just implement and understand the guidelines; there is, with all areas, interpretation and knowledge that builds the solution. Those that have built these services have important role to play in the dissemination of information, as do access user groups who have specific demands to explain.

JSC, based in Australia and the UK, is a company that provides interfaces for integrated on-line services. For 16 years JSC has been using technology to help improve both access to services and usability of these services. Providing access is one issue, but making the service easy to use once it is accessed is another. Julia Schofield, the founder director, has no sight and other seriously disabled people have worked at JSC.

JSC has been involved in developing several major on-line services in different countries. Key markets include retail, health, government, entertainment and education. Projects have included a number for the Victorian Government, advice to major retailers, interactive "Medibooks" for hospital waiting rooms, "Skills from Experience" hygiene education for poor readers entering the food industry, etc.

In most projects, the level of access attained is adversely impacted by cost and commercial considerations especially where interactive kiosks are concerned. Additional funding from the Government is needed in order to provide a level of access satisfactory to the combined user groups. Better education of process and technique also gives companies the confidence to approach this difficult subject.

Those who have not encountered computers before are disadvantaged. If the material of interest is available and the interface easy to use, then age becomes less relevant because there is more incentive. Social circumstances can have an impact on knowledge and desire to use an electronic service too regardless of age. Getting people from various age groups interested in electronic services involves providing relevant services that create demand. With elderly people, this may mean increasing social contact in conjunction with use of technology in order to avoid creating more loneliness at home.

Particular groups at a disadvantage are:

• those at retirement age who have not encountered computers
• very young children with severe disabilities so that their general experience can be increased for example deaf blind, those with lockout syndrome, those with serious neurological disadvantage, the visually impaired, etc.
• women over 35 in rural communities or high unemployment sectors (addressing social exclusion groups)

Providing training for mixed age groups is effective particularly in conjunction with the introduction of useful services – out-patient Rheumatology education was found effective at St Thomas Hospital (inner London) for older citizens who's fear decreased as they started using a touch screen. Topics or services of interest are not common especially for older women. Public kiosks and interactive television will have a huge impact on use by these groups. This will be especially true if guidelines for access are set before there are many inconsistent services. The need for users to re-learning constantly in order to be able to navigate and use different services should be addressed by the adoption of with public guidelines for producers.

Many difficulties in providing access for the disabled are generally because of the conflict of needs between them when all are taken together. For example, high contrast screen may help those with one condition but dazzle another; very large touch screen buttons are useful for those with inaccurate movement but difficult for people with serious tunnel vision.

Electronic access to a service has to cater reasonably for all; this is surprisingly difficult to achieve well and it mustn't deteriorate the use for the general population.

Key considerations to address are:

• appropriate materials being available for certain groups. For example to assist employment of those with learning difficulties
• precise use of language, text and audio so that it is useable by all
• conflicts between the different needs of each group and everyone else
• positioning of hardware so it isn't a danger for visually impaired people using canes but is low enough for those in wheelchairs

Commercial issues like payment by time or printouts being charged at the number of pages (large print would then double the cost) also need consideration in each case.

Rarely is the complexity of sight and access difficulties fully understood by those commissioning or building electronic services. While regarded as an area of great interest it is often perceived to be purely "make the screen talk-able" at the extreme. The few who both build systems and have had sight problems themselves often don't communicate this knowledge well widely.

The importance of opening up access for the visually impaired so as they can gain greater independence and more opportunities cannot be underestimated. This is particularly so for those with combinations of disabilities like serious deaf blindness. Access issues are different for the various channels of electronic communication - Internet, Intranets, kiosks, multimedia payphones, new retail devices like electronic whiteboards for the kitchen, aircraft seat controls and entertainment, interactive TV, Interactive Voice Response, etc.

Key considerations are:

• channels require analysis to prioritise the access considerations and practical solutions
• needs, with acceptable solutions, require analysis
• solutions require analysis to avoid unforeseen conflicts with the requirements of others
• manufacturers and service providers, for example airlines, need to be made aware of the needs of visually impaired customers
• realism for the provider has to be considered as to what is financially possible
• knowledge needs better dissemination in ways that are easy for providers to understand

A great solution example is speech recognition, which can solve many problems but create others – try paying a bill via speech input when you have the flu! A solution for one group may lead to problems for another. Groups with conflicting requirements include those with colour difficulties (reported to be 25 percent of males), tunnel vision, centralised vision and long / short sight. Special consideration is also required for those without reading sight at all, and older citizens who form the majority of people with more serious vision difficulties.

NOTE - Development of solutions can be greatly assisted, especially at the pioneering stages, through the provision of grants or additional funding particularly for smaller entrepreneurial companies who, because of their size, are often then able to export these products if the early stages have some pump priming.

Groups which require special consideration include those with:

• multiple disability areas like deaf blindness
• neurological conditions where movement and deafness are combined
• speech impairment with deafness
• very young children who are severely deaf or have multiple disabilities

This assumes public provision of alternate communication channels which assist those with hearing disabilities and that families with young children are provided for financially so that access is available both at school and home.

The use of audio only information and messages, particularly in public areas, has diminished due to their proven inadequacy, and such information is now usually supplemented by text messages, as can be seen in places such as airports and railway stations. Consideration of stronger government guidelines here both for the systems noted above and interactive kiosks is important in order to increase general understanding.

The expansion of telephone services and development of voice recognition inputs (likely for interactive television), brings a new range of access issues which must be worked through for those with hearing difficulties. Some of this work may well build on the foundation and concepts of TTY (TeletypeXX terminal).

Many devices and well documented approaches already exist in this area for kiosks and Internet use. However there are still many basic problems which act to deny people access, for which there are somtimes simple solutions. For example, access to a PC or notebook computer can so easily be denied through something as simple as an unusable on / off switch. Such a problem could be overcome through computer manufacturers adopting simple hardware guidelines, similar to those that govern telephone makers, which result in the dot being placed on the number 5 helping those with poor or no sight.

Groups which require special considerations include:

• the multiple disabled
• those with conditions like strokes where memory or other faculty dysfunction is coupled with sudden loss of physical movement
• those who have conditions like 'locked in' syndrome
• young children

Key considerations are:

• provision of systems that will enable access to different users with minimal fuss (i.e. without the need to load new software, re-arrange keyboard connections etc)
• screen and service design for viewing from a chair
• guidelines to the systems integrators regarding card readers and similar devices
• access to all educational materials
• better access to employment
• financial provision
• training and education for those who are not computer aware
• ensuring that those newly physically disabled know where to find out about access

Like visual disability there are preconceptions of what physical dysfunction is and knowledge is poor outside the needs of those in wheelchairs without other requirements.

People with speech disabilities are poorly understood. Better public education especially for employers.

The key considerations are:

• multiple disability groups have particular needs
• education and speech retraining that is entertaining and rewarding
• identifying employment opportunities
• improvement in text messaging access to key services

An increasingly important public communication channel is call centres. Unfortunately they are usually poorly equipped to deal with serious speech impairments, and often do not publicise alternative means of contact e.g. email.

Speech recognition might be used to simplify communication for some people but ends up making life difficult for this group. Early guidelines from government would help providers.

While electronic service models here have been proven to be hugely effective, key issues are lack of employment for those with considerable learning difficulties and the increased exclusion that text-focussed services like the Internet creates.

Support for those with special language needs may in part be addressed through the provision of publicly available guidelines which assist service providers to improve screen design, wording, signage, and use of meaningful graphics to support textual messages. Similarly those offering technology training frequently do not consider this group nor do the product providers.

Such guidelines could also be applied in the provision of employment and adapting qualifying training. Learning can be supported through images and video etc, enabling people to gain the necessary qualifications through the use of non-textual material.

Multiple disability is the most challenging for access. Improved access must also involve addressing financial hardship. Often for disabled people, particularly families with small children and those who are not employed, the expense of home equipment needs attention. Diminishing social exclusion must be a consideration, where the provision of access must be complemented by equipment and training.

Key questions are:

• What is needed for access within this group (often special devices need to be attached to PCs)?
• Where can opportunities at home, in education, for leisure or at work be created?
• Is there a role for access equipment in rehabilitation and health support?

Australia has the opportunity to lead the world market in addressing these access issues.

It would seem that the following are important :

• better involvement and education of equipment suppliers
• training provision for certain groups and their helpers
• provision of equipment
• proactive work in employment opportunities created through new skills being needed
• new leisure and health independence
• government guidelines for tenders, specifications, obtaining information on disability, interfaces, etc

Often improving access for the disabled enables better use for other groups. For example brief, precise messages might be best for those with sight problems but they are also generally an improvement as people retain information poorly from screens.

Women and those whose first language is not English, in certain sectors are restricted in their use of the Internet, due to the combination of lack of available access and of relevant or interesting material online. These groups are not always slow to take up technology, it is just that they don't tend to be so interested in the equipment or software itself. These problems are also reflected in other community groups who have similar disincentives and fears. Training, material, highlighting an area like health for gaining interest, creation of new job opportunities are all important considerations.

Negative attitudes in education can start the process of disadvantage and lack of access for girls, although this situation is improving as more suitable material becomes available and things like computer games become less macho.

Balancing family life, work, household demands and others needing to use equipment is a disincentive to women to use online services, especially when some of these are far from easy to use. Technology is rarely friendly to this group, unless they are in the industry; there needs to be someone in the family to set it up and help, and there are so often competing priorities.

Women are not targeted in presentation of electronic services, marketing is rarely feminine and fears need addressing.

Key questions to consider are:

• What would women like?
• How would marketing be more attractive?
• How could familiarization be fitted in to the pattern of family life?
• How can the technology providers, with teams being the majority male, alter their attitude and consider women?
• What are the real fears and shortcomings currently?
• Where is education failing?
• Where and how can women fill the skills gap in this industry?

Increasing research is available on the demands of women as regards electronic services. This may be an area for international co-operation as, for example, Patricia Hewitt, E-Commerce Minister in the UK (but Australian born), has a new group started which could be linked to initiatives in Australia.

Although in the discussion paper indigenous people are grouped with non-English speaking people, here they have been separated out because of cultural differences, and attitudes to technology.

Communities vary greatly and issues need more individual attention. There are many experts in this field and it would be presumptuous for a generalist to comment except that the considerations are numerous and results from trials greatly important.

There are some links with the questions raised above for women and great opportunities for access if units are sited and designed correctly for imparting information on, for example health and employment; however great sensitivity is required.

Considerations here might include providing an infrastructure that can be customised so that those in the community can drive delivery of a service that is tailored to their needs and can be incorporated into general activities.

Much greater understanding is needed within government and particularly commercial organisations for catering to these groups.

Non-English speakers are viewed here from the point of view of older Australians. However Australia has a large tourist trade, and many of the new services for this group do not provide adequate assistance for those who have a poor understanding of the language. Translation in to all languages would be impossible but some provision in screen layout, precise and simple wording, signage and even acknowledging a need is important. More exemplary services are required which demonstrate the way in which precise and simple language helps many groups including non-English speakers regardless of age and signage.

It is vital to develop strategies bridging the gulf that separates those producing services from the community. Better understanding is needed of what is possible, for example, where automated translators can be used, if a initial screens can form an introduction with a link to call centres etc. Again government might provide guidance to those in the industry.

So often the focus has been on the service and how it might be accessible rather than on education and general publicity generating interest and desire before release. Such marketing needs to include those with little or no English.

The key considerations are how to generate confidence, how to influence providers to take non-English speakers into account (extra cost to them is a disincentive) and the understanding of needs poor.

Transport is not highlighted here. Observation of people using new systems, for example, the new ticketing system on the trams in Melbourne, show how a little more attention to the needs of the community has the potential to improve use considerably. Aircraft seat and entertainment controls are increasingly visual making it harder for those with sight problems or even the elderly to manage unassisted. Safety videos also rarely take into account the needs of the whole community.

This reference focuses on current technologies because that is where issues have been shown which need addressing. It is hoped that access considerations will influence the use of technologies such as speech recognition, and the design of interfaces for services that are likely to have rapid take up e.g. interactive television.

Finally, there is little mention of those in rural communities who need co-ops, remote training and the provision of access applicable to their needs. Much of the material is city-based although there are many areas where access for remote communities has been greatly improved through Internet access. As with the material available for women, appropriateness is an issue along with awareness. Frequently the commercial services exclude these communities because they have to be considered in a special way.

There are many organisations and companies whose experience in encountering access challenges in Australia is relevant.

These include:

• Centrelink with its aim of multi-channel single citizen focus
• ATO who have the challenge of delivering to professions, businesses and individuals
• the results from across state strategy and implementation within Victoria
• access challenges posed by the Telstra Multimedia Payphone
• multilingual delivery within the Hong Kong government model (just commencing implementation)
• CCTA (UK) Open.Gov site with its links to other departmental information services
• work of the W3C group and associated research units like Trace in Wisconsin
• references being generated by Dr John Gill, Research and Technical Director of RNIB London and others like him who's knowledge does not often go outside those actively seeking it. There is poor industry awareness
• strategic development work within major national and international retail organizations
• provision for the visually impaired in the Science Museum in Paris
• "Rethinking Government" a publication being updated by IBM US (predicted availability first quarter 2000)

Not all of these have completed solutions but they are showing different approaches to some of the considerations raised here; there are, of course, numerous others.

Dr Julia Schofield – Jonathan Roper – Justin Flute
JSC Australia Pty Ltd
19 November 1999

JSC Australia Pty Ltd Level 4, 450 St Kilda Road Melbourne Vic 3004
ACN: 080 986 312 Telephone (03) 9864 4700 Fax (03) 9864 4777
E-mail jsc@jsc.com.au