Human Rights and Equal Opportunity Commission Inquiry into
Access to electronic commerce and new service and information technologies for older Australians and people with a disability
Submission by TEDICORE
(Telecommunications & Disability Consumer Representation)
16th March, 2000
Background
TEDICORE (Telecommunications & Disability Consumer Representation) is administered by Blind Citizens Australia and is supported by the Commonwealth through the "Grants to Fund Telecommunications Consumer Representations" program of the Department of Communications, Information Technology and the Arts.
The project aims to advance and represent the interests of people with disabilities in relation to telecommunications issues and promote equity and accessibility. A Project Advisory Board represents the views of telecommunications consumers with disabilities in forums including public debate about telecommunications issues.
The main objectives of the Project are to:
Introduction
This submission is necessarily brief to support a number of other submissions including Tim Noonan's project report and to provide recommendations based on the experience of TEDICORE in this area.
With the Commonwealth Government's involvement in drafting the recently-released OECD Guidelines for Consumer Protection in the Context of Electronic Commerce (http://www.oecd.org//dsti/sti/it/consumer/prod/CPGuidelines_final.pdf) and the development of Building Consumer Confidence in Electronic Commerce: A Best Practice Model for Business (http://www.treasury.gov.au/publications/ElectronicCommerceAndConsumerProtection/SecondRoundConsultationOnBuildingConsumerConfidenceInElectronicCommerce-AaBestPracticeModelForBusiness/model.asp) by the Department of the Treasury, it is useful to reflect on the impact of e-commerce for people with disabilities and older people. The OECD Council states that "electronic commerce should be open and accessible to all consumers" (p.2, OECD, 1999) and thus there is a challenge here for Australia to ensure that e-commerce does not exclude the nearly 20% of the population who has a disability and the growing proportion of the population which is ageing. Paragraph 18 of the post consultation draft Best Practice Model by Treasury states that "In accordance with the Disability Discrimination Act 1992, businesses are required to make reasonable adjustment in the provision of goods and services to ensure that they are accessible to people with a disability."
For e-commerce to achieve a significant breakthrough, consumers must have confidence in the processes involved and in the technology. Using technology poses considerable challenges for many people with disabilities and older people.
Diversity
Based on other submissions and findings at conferences such as the University of New England's Making the Connections held in November 1999, it should be emphasised that people with disabilities and older people have diverse needs, interests and backgrounds and this is often reflected in their uptake of technology. While it is obvious that a vision impaired person has different ways of accessing information than a hearing impaired person, this does not mean that all people with a particular type of disability will be computer literate and keen to learn new technologies. Some blind people could be considered as leading the way with regard to technology to suit their needs but there are also a large number of vision impaired people, especially those who are older, who may be more reluctant to let go of the old ways even though they may be considered cumbersome and ineffective. Thus, older people may fall into at least two broad categories:
The recently completed stage one of the Deaf Australia Online project has conducted user studies to ascertain how Deaf people who use Auslan (sign language) as their first language carry out activities in their daily lives such as studying, working and leisure. The studies have found various ways technologies could be designed to accommodate their requirements. The research recognises that "people supplement – not substitute – traditional forms of communications and payment with online services across their activities." (p. 2, sect. 5, Deaf Australia Online interim report, 1999)
Blind Citizens Australia and TEDICORE will soon commence a research project with funding by the Department of Communications, Information Technology and the Arts to study the uses and opportunities of online information services for aged people with a vision impairment living in rural and remote communities. This research will establish the links between contents and services accessed online by the target group and the ways they are used in their daily life. The research will reveal differences as well as common patterns. Once the main patterns of use have been defined, a second stage will "test" the chosen websites from the users' perspectives. Recommendations will be given on what works, on the additional features and contents that are needed, and on aspects of design or information provision that are lacking.
It is important not to be fixated by the technology itself and require people to fit the technology. Instead, the technology should be used to best effect by offering advanced services in a user-friendly environment which has been designed to cater for a broad range of the population. It is also necessary to recognise that some people will prefer to use the traditional means of transactions.
Universal design
IT-based equipment is often designed by young developers who may have limited understanding and awareness of how a broader proportion of the population would use a product or service. With more and more consumer products having online capabilities, it is necessary to ensure that products and services are designed with usability and flexibility right from the outset.
This concept of universal design needs to be incorporated into software and hardware design. Universal design has been defined as follows: "to simplify life for everyone by making products, communications, and the built environment more usable by more people at little or no extra cost." (Center for Universal Design, http://www.design.ncsu.edu/cud ) There are two parts to universal design. The first is to design products and services which are flexible enough, as is commercially practical, to be directly used by people with the widest range of abilities. The second is to design products and services so that they are compatible with the broadest range of assistive technologies for people who can not use or efficiently access the products directly. However, there still needs to be a recognition that, in some cases, provision should be made for people with disabilities to access additional equipment and services. The importance of universal design is that a product or service is designed in a flexible manner to accommodate more people than previously.
Seminars and workshops on universal design to acquaint industry of the advantages of putting this concept into practice should assist in raising awareness. TEDICORE has developed a workshop and seminar programme and Telstra will be the first Australian telecommunications corporation to offer an internal universal design workshop for senior managers in April, 2000. The Australian Telecommunications Industry Association has indicated support for the seminars and it is hoped that further seminars will be offered later in the year.
Awareness-raising
Awareness-raising of access issues should be a joint responsibility of government and industry working together with people with disabilities and older people to achieve the best outcomes.
It is very positive to note that some planning is already under way in this direction. The Internet Industry Association together with the Australian Interactive Multimedia Industry Association and the Information Industry Association have recognised the importance of web accessibility and are developing strategies for alerting their members to ensure that Australian web sites are designed with accessibility in mind.
The National Office of the Information Economy (NOIE) has, in March 2000, established a Community Access Unit to assist people with disabilities, older people and people from non-English speaking backgrounds in using e-commerce. Planning is currently taking place on initiatives in this area.
Training
Because cost is a considerable barrier to many older people and people with disabilities using the internet from home, the public internet access offered by community centres and public libraries is very important. However, staff may require training in assisting people with disabilities effectively, the design of the workstations may require rethinking to make them more accessible, additional equipment may be required and individuals with disabilities and older people may require specific training in the use of the computer and the internet. The research done by Kirsty Williamson of Monash University together with the State Library of Victoria and Vicnet highlights many of these issues.
Training is also important for staff in corporations and government who provide services to consumers. There needs to be increased understanding of the needs of people with disabilities and older people. This is evident from the HREOC-funded survey of ATMs where, in many cases, some banks were not aware of the accessibility problems with their ATMs
Conclusion
E-commerce has the potential to be of real benefit to people with disabilities and older people with online shopping and banking available now and many other types of services just over the horizon. The below recommendations should assist in ensuring that unnecessary barriers are not created.
Recommendations
The programme should offer basic conceptual and practical training in the use of a keyboard and mouse as well as the use of graphical user interfaces, if appropriate. Funding should be made available for the further development of peer-supported programmes such as Seniors Online.
Gunela Astbrink
Policy Officer, TEDICORE
Ph. (07) 3876 0880
Email: g.astbrink@gsa.com.au