ࡱ> Y g|bjbjWW ==Xx]8,<tffHL b b b = 6s  Tnfpfpfpfpfpfpf$hjfk = = k k f b b    k 2b b nfk nf  b t]$nfb Tgp4lePEOPLE WITH DISABILITIES (NSW) INC SUBMISSION TO HUMAN RIGHTS AND EQUAL OPPORTUNITY COMMISSION INQUIRY INTO THE ACCESSIBILITY OF ELECTRONIC COMMERCE AND OTHER NEW SERVICE DELIVERY TECHNOLOGIES FOR OLDER AUSTRALIANS AND PEOPLE WITH DISABILITY For further information contact: Darren Fittler Advocate People with Disabilities (NSW) Inc PO Box 666 STRAWBERRY HILLS NSW 2012 Telephone: (02) 9319 6622 Facsimile: (02) 9318 1372 Telephone Typewriter: (02) 9318 2138 TABLE OF CONTENTS  TOC \o "1-3" INTRODUCTION:  PAGEREF _Toc467834238 \h 3 People with Disabilities (NSW) Inc  PAGEREF _Toc467834239 \h 3 PWDs interest in this issue  PAGEREF _Toc467834240 \h 3 Development of this submission  PAGEREF _Toc467834241 \h 4 What is E-Commerce?  PAGEREF _Toc467834242 \h 5 E-COMMERCE AND THE DISABILITY DISCRIMINATION ACT, 1992  PAGEREF _Toc467834243 \h 6 Objects of the Disability Discrimination Act, 1992  PAGEREF _Toc467834244 \h 6 E-COMMERCE AND PEOPLE WITH DISABILITY  PAGEREF _Toc467834245 \h 7 E-Commerce and People with Sensory Disability  PAGEREF _Toc467834246 \h 7 SCENARIO 1 Janes Story  PAGEREF _Toc467834247 \h 7 E-Commerce and People with Physcial Disability  PAGEREF _Toc467834248 \h 12 SCENARIO 2 Bills Story  PAGEREF _Toc467834249 \h 12 E-Commere and People who are Deaf or Hearing Impaired  PAGEREF _Toc467834250 \h 16 E-Commerce and People with Cognitive Disability  PAGEREF _Toc467834251 \h 18 E-Commerce and People with Neurological Disability  PAGEREF _Toc467834252 \h 21 CONCLUSION  PAGEREF _Toc467834253 \h 21  INTRODUCTION: People with Disabilities (NSW) Inc People with Disabilities (NSW) Inc (PWD) is the peak and state wide cross disability advocacy agency in NSW. Its primary membership is constituted by people with disability and organisations with governing bodies constituted primarily by people with disability. PWD also has a large associate membership of individuals and organisations committed to the disability rights movement. PWDs mission is: To be an organisation of and for people with disability working for a socially just, accessible and inclusive Australian community, in which the human rights, citizenship, contribution and potential of people with disability are respected, supported and celebrated. PWD is the major NSW organisational member of an equivalent national body, Disability Australia Inc, which is in turn, the Australian member of Disabled Peoples International. Disabled Peoples International is a major international non-government organisation made up of national associations of people with disability drawn from more than 160 countries. It has Observer status on a variety of United Nations organs and committees. PWDs interest in this issue PWD provides extensive individual advocacy to people with disability and their associates through its major service, the Disability Complaints Service of NSW. In the course of this activity, we deal on a daily basis with complaints about the accessibility to people with disability of electronic commerce and related technologies. For the most part, these complaints relate to ordinary life activities, like banking and purchasing, which in some cases are becoming less, rather than more, accessible as a result of the introduction of electronic technologies. Many of the comments we offer following are drawn from our experience of dealing with these complaints. PWD is also constantly involved in systemic advocacy on behalf of people with disability. The exponential growth and pervasiveness of electronic commerce and related technologies is of major systemic importance to people with disability. It is an area in which we have recently initiated some exploratory qualitative research. The comments we offer following are also drawn from this experience. Development of this submission In developing this submission, PWD has consulted extensively with its members, as well as with a number of clients of the Disability Complaints Service of NSW. We acknowledge their contribution with great appreciation. We have taken great care to consider this issue from a cross disability perspective. This submission attempts to demonstrate the difficulties encountered by people with different types of disability, including: People with sensory disability (blindness or vision loss; deafness or hearing loss; loss or diminished touch sensation) People with physical disability (including limited strength; reach; dexterity; tremor etc) People with cognitive disability (intellectual disability; dyslexia; brain injury; psychiatric disability which may affect a person ability to think, remember, and or sequence); People with neurological disability (epilepsy). To illustrate their experiences, we have developed a number of scenarios that highlight many of the barriers encountered by people with disability in using electronic commerce and related technologies. These scenarios are substantially based on actual events. However, in order to protect the privacy of those who have shared their experiences, names have been changed and the use of actual business names has been avoided. In reading these scenarios, and in considering this submission generally, it is critical to comprehend that the barriers to people with disability using electronic commerce are not inherent in the characteristics of the individual, they lie in the structural discrimination of the external environment. What is E-Commerce? For the purposes of this submission, the term electronic commerce (or e-commerce) has been interpreted in a broad sense as any interaction of a commercial nature involving the use of electronic or automated technology. Forms of electronic commerce to which the comments made in this submission apply include: banking and financial services (eg, Automatic Teller Machines (ATM); Electronic Funds Transfer at Point of Sale (EFTPOS); telephone banking, banking and finance information; automated billing etc); retail services (eg. telephone shopping; Internet shopping etc); Government information and transactions (eg e-commence related developments in Telstra and Centrelink etc); and Other Internet based information, services and transactions. The barriers for people with disability in using e-commerce are multifaceted and include: Inaccessible software platforms and document formats (especially for people with sensory and/or cognitive impairment); Inaccessible hardware platforms and associated infrastructure; Cost; many people with disability simply cannot afford to purchase computer hardware or pay for access to on-line services; Limited information about, and experience and confidence in using, computer based technologies. E-COMMERCE AND THE DISABILITY DISCRIMINATION ACT, 1992 Objects of the Disability Discrimination Act, 1992 The Objects of the Disability Discrimination Act 1992 are set out in s 3 of that Act. They are: (a) to eliminate, as far as possible, discrimination against persons on the ground of disability in the areas of: work, accommodation, education, access to premises, clubs and sport; and the provision of goods, facilities, services and land; and existing laws; and the administration of Commonwealth laws and programs; and to ensure, as far as practicable, that persons with disabilities have the same rights to equality before the law as the rest of the community; and to promote recognition and acceptance within the community of the principle that persons with disabilities have the same fundamental rights as the rest of the community. The current and rapidly increasing prevalence of e-commerce makes it abundantly clear that the ability to understand, operate and participate in e-commerce is essential for the ongoing inclusion and participation of people with disability. If the e-commerce explosion is not guided or managed correctly, many people with disability could find themselves increasingly isolated, unable to obtain basic services, or paying considerably more for alternative services. This is obviously seriously contrary to the objects of the Disability Discrimination Act. E-COMMERCE AND PEOPLE WITH DISABILITY E-Commerce and People with Sensory Disability SCENARIO 1 Janes Story Jane, a woman who is totally blind, wishes to go shopping for a gift for a friends birthday and begins her day with a visit to her local banks ATM with the intention of withdrawing some money. The first difficulty Jane encounters is that she is unable to locate the exact position of the ATM, and she spends a few minutes searching until she hears the familiar noise of the ATM in use allowing her to approach the area, locate the line, and wait her turn. Janes turn comes and she is unable to ascertain which way to insert her key card, as this instruction is only given visually. After inserting the card incorrectly three times, the ATM finally accepts the card. The keypad is labelled with braille giving Jane the ability to type in her personal identification number (PIN). The next step is not so easy. It is now the time to instruct the machine on what transaction Jane would like to complete. The keys that enable such a transaction are only braille labelled 1 to 4. This is because each number corresponds to a written prompt displayed visually on a screen. The particular number will correspond to a different prompt, depending on the previous choice. (For example, in the first instance number 1 may correspond to withdraw cash, but once pressed number 1 may now correspond to the prompt cheque account which may next correspond with yes, telling the machine that you do indeed wish for a receipt). Fortunately Jane has memorised the sequence required to withdraw the desired amount of money. The requested receipt is then provided in print only, hence Jane is unable to read the transaction information or her bank balance. Jane now travels to a local department store where she finds an item she would like to purchase. However it is more costly than she had anticipated and she decides to use the stores EFTPOS facility instead of paying cash. Jane hands over her card and says that she would like to use her savings account. The EFTPOS number pad is passed to her but Jane finds that the keypad is unusable for two reasons. Firstly there are no raised dots indicating the position of the number keys, and secondly, when feeling the pad Jane accidentally triggers all buttons she comes into contact with even though she has only brushed them with the slightest contact. To make the transaction Jane is therefore forced to tell the Cashier her PIN. (This is a major breach of privacy and puts Jane at risk of exploitation). After arriving home Jane attempts to visit her bank online in the hope that she may be able to ascertain her bank balance electronically. She is unable to find out whether or not this service is even available, as the banks website has not been designed with the access needs of a person with vision impairment in mind. Janes story highlights the fact that many electronic machines and interfaces depend greatly, if not solely, on the ability to see. For this reason, people who are blind or have a vision impairment often experience considerable difficulty in independently locating, gaining access to, understanding, and operating systems which depend on a platform developed to be understood and used through visual cues. Another major barrier highlighted by Janes story is the failure to provide information in formats that are accessible to people who are blind or have vision loss (whether this is in tactile alternatives to printed information or through software and document formats that are capable of being read by screen-reading technologies). Many of these barriers can be easily overcome, for example, through the use of talking signs to direct people who are blind or vision impaired to an ATM location the voice gets clearer as the person gets closer to the destination (see A Woo, ATM offers blind much needed talk The Sanfrancisco Examiner 2 October 1999). The introduction of talking sign technology may be a very useful tool for directing people who are blind or vision impaired to particular facilities or premises etc. Some ATM and EFTPOS systems are safer and more accessible than others for people with disability to use. When we asked people with disability what features would make an ATM or EFTPOS system safer and more accessible for them they identified the following features: Well defined and spaced buttons Buttons which are labelled with braille or raised numbers/letters Buttons which give an audible tone when pressed Buttons which are responsive, ie the button will noticeably depress when pushed Where the machine gives a spoken instruction that guides the user through the various prompts, and gives audible information (such as current account balance etc.) Where the ATM is positioned in a safe location Designing all ATMs to accept a key card in the same way. In particular, it was recommended that new smart card technology should have some indicator that permits a vision impaired or blind user to distinguish which way to insert or hold the card. Janes story also highlights the complete or partial inaccessibility of a large number of banking and commercial web pages as a major issue for people with disability. The World Wide Web Consortium is working on many aspects of web site design and accessibility. If accessible standards are developed, agreed on and adhered to, barriers currently faced by people who are blind or vision impaired or have other disability, may be removed. For more information on the World Wide Web Consortium and its work on web accessibility see: T Noonan, Accessible E-Commerce in Australia: A Discussion Paper 鱨վ the Effects of Electronic Commerce Developments on People with Disabilities which can be found at  HYPERLINK http://www.bca.org.au/ecrep.htm http://www.bca.org.au/ecrep.htm. The inability to fill in online forms independently is also a major issue for people with disability. These forms may be used to identify the user, purchase goods or services, make a transaction, sell or buy stocks etc. They are, consequently, an integral part of online e-commerce. Yet they are frequently inaccessible to people with disability who may not be able to read them due, for example, to their incompatibility with screen reading software. The inability to successfully view, buy or sell stocks over the internet is a very specific concern raised by a number of people consulted in the development of this submission who are blind or vision impaired. If accessibly designed, online trading would provide an unprecedented level of access to the marketplace (in terms of being able to read formerly inaccessible printed financial papers, stock reports, and generally research possible investment opportunities). Similar to the use of online trading, the use of online media such as newspapers, magazines, catalogues and brochures are becoming more and more prevalent. Currently many online services are inaccessible due to poor design. If designed properly, this technology has the ability to increase the opportunities for a person who is blind or vision impaired to acquire information, buy and/or sell stocks or shares, purchase goods such as books, compact disks, wine, groceries etc). The inaccessibility of online security measures is a major issue for people with disability. Many of the online security systems for the use of credit cards over the internet involve measures that are inaccessible to people who can not see the computer monitor, so excluding people who are blind or have vision impairment. The non-provision of statements/accounts in formats which allow people who are blind or vision impaired to independently read the status of their accounts is of obvious importance. It makes it extremely difficult for a person to manage their own finances. A person who is blind or vision impaired is therefore dependent on another person to read them this information, which, again, involves a violation of privacy and places the person at risk of exploitation. The provision of braille, large print, audio, or electronic versions of statements or accounts would greatly increase the independence of a person who is blind or vision impaired. The non-provision of other information (particularly that produced by government departments) in accessible formats is also a critical issue to be addressed. The use of equipment or devices dependent on touch screen technology poses particular difficulties for some people with disability. Touch screens are dynamic and require the touching of the correct part of the computer screen to let the machine know what the user desires. Touch screens are rarely, if ever, labelled in any way. As a consequence, a person feeling the screen for the correct place to touch risks touching other parts of the screen, hence triggering incorrect or undesired prompts. This technology has been introduced into many government departments. Alternative methods of receiving information or completing transactions should be provided. For example, the provision of staff who can deliver the same information or can provide the same service as the touch screen, and/or the integration of voice recognition and voice out put technology into the same system, allowing a person to speak commands and hear the information presented. Alternatively a separate keypad or keyboard could be provided for data entry, and there could be voice or braille output (see Noonan op cit for further discussion of these issues). E-Commerce and People with Physcial Disability SCENARIO 2 Bills Story Bill, a man with prosthetic hands, is on holiday and wishes to visit some of the local tourist attractions. Before venturing on his days activities, Bill visits an ATM. He inserts his card, types in his PIN, and successfully instructs the machine on what he wants to do. The ATM returns his key card, however, due to his reduced dexterity Bill can not retrieve the card as it has not been ejected far enough for him to grasp. Bill is required to request the assistance of a passing pedestrian to retrieve his key card. Bill consults his map and finds the nearest tourist information centre. On arrival he finds that it is an un-staffed information kiosk with information being provided only by touch screens. Bill touches the screen with his prosthetic finger and finds that he is unable to trigger the machine and therefore cannot access any information. Again Bill is forced to request the assistance of another kiosk user and eventually decides upon a tourist destination. In order to get to the destination of his choice, Bill is required to take public transport. On arrival at the train station he finds that there are no staffed ticket booths and he is therefore required to use an automatic ticketing machine. After inserting the required note with great difficulty, Bill discovers that he is faced with the same difficulty as with the ATM, ie the ticket he has purchased has not been ejected far enough for him to grasp. Not only this, but the change retrieval area is small and covered by a flap. Bill again is forced to depend on a passer by to retrieve his ticket and his change. Bill then approaches the automatic ticket gates, inserts his ticket, passes through, and when attempting to retrieve his ticket from the other side finds that again he can not retrieve the ticket as it has not ejected far enough for him to grasp. After shouts of abuse from fellow passengers and railway staff, a staff member approaches. Bill is required to explain the circumstances, including his disability, in front of many passengers. The staff member retrieves the ticket for him and suggests that in future he use the wide gate, which does not require the use of the automatic system. When exiting the railway station at his destination Bill follows the advice of the railway staff member and attempts to use the wide gate. He is confronted by another staff member who abuses him for not using the electronic gates. Bill is again forced to explain his disability and the reasons why he was instructed to use the wide gate. Bills scenario illustrates a number of barriers faced by a person with low or no dexterity in their hands. A limitation of function or movement can apply to all parts of the body making it difficult or impossible to walk, reach, turn or swivel, grasp, lift, push or pull, hold etc. Examples of people who may have low or no dexterity in parts of the body are people affected by stroke or spinal injury, people who use prosthetic limbs or hands, people affected by post polio etc. Although ATMs, automatic ticketing machines and electronic gates are highlighted in Bills scenario, similar difficulties are encountered in the use of any device that requires the inserting of cards or money and the retrieval of cards, money or goods. Other examples are public telephones and vending machines. Following is a list of difficulties in using e-commerce identified by people with physical disability: The inability to reach or trigger equipment or devices dependent on touch screen technology The height and positioning of a touch screen may make it extremely difficult if not impossible for a person to use. A person who is short in stature, or who uses a wheelchair often find that touch screens are often positioned too high or in such a way that requires them to approach the device side on and then swivel or twist their body in order to access the machine. People who have prosthetic hands or fingers, or use an implement such as a mouth stick, are unable to trigger the prompts on a touch screen. The following design features are essential for many people with disability: Touch screens must be placed at an appropriate height and have enough room for a person with disability to position themselves under the machine. The option of an alternative input device. Similar barriers are encountered by many people with disability in attempting to reach and operate ATMs, ie the ATMs are too high, or positioned on a slope, with no provision to approach the ATM front on. Other difficulties include the amount of strength needed to trigger or activate a button, and the amount of time given to complete a transaction. When we asked people with disability what features would make an ATM or EFTPOS system accessible the following features were identified: The positioning of ATMs at an appropriate height and in an area with a level approach The provision of room underneath the machine to allow a person to access the machine front on Well defined and spaced buttons Buttons which are easy to press For the card, money and receipt to be ejected to a distance which allows the user to retrieve them easily and safely For there to be enough time for a person with low dexterity or slow movement to complete their transaction successfully For the ATM to be positioned in a safe location. People with disability also experience difficulty in using some self-service or automated facilities. As technology increases and becomes more widespread and its applications become more varied, the trend is to replace staff with machines or electronic systems, for exmaple, toll booths, automatic ticketing in car parks and self serve payment facilities such as those found on some petrol bowsers. Some people with physical disability are unable to easily enter and exit their vehicle. This means that systems such as those mentioned above should be designed with the expectation that the user will not be able to leave their vehicle, nor reach long distances. E-Commere and People who are Deaf or Hearing Impaired People who are deaf or hearing impaired experience particular difficulties in using e-commerce stemming from their reduced ability, or inability, to hear audible tones used as cues, reminders or warnings. Some equipment, such as ATMs and public telephones will issue an audible message (usually a series of equally spaced tones) informing the person that they are required to do something. In the case of ATMs the warning sound may indicate that the user should remove their card or that they have run out of time to complete the transaction. In the case of public telephones, the warning sound may indicate that the user has, or is about to, run out of money, or that they have forgotten to remove their card on the completion of their call. People who are deaf or hearing impaired often cannot hear the warning sound, either because they can hear nothing at all, or because their hearing impairment results in them not being able to hear certain frequencies. People who are hearing impaired said during our consultations that some frequencies are more difficult to hear than others, and that most of the equipment which incorporates this warning device does not use the more distinguishable audible tones. The remedies suggested were: To incorporate a noticeable and distinct flashing light. (This may also be of use to other users as background noise may render the tone inaudible) To design the warning tone to be sounded within frequencies more commonly heard by all, including people with hearing impairment The lack of closed captioning, particularly over the internet, is a major issue for many people who are deaf or hearing impaired. It was apparent throughout our consultation that very little material displayed over the internet is accompanied by closed captioning. The obvious solution is to provide closed captioning for any data that can not otherwise be appropriately comprehended through the material already presented. Interference with hearing aids caused by mobile phones was identified as a major issue for a number of people with hearing impairment who use hearing aids. We note that this issue is the subject of a separate inquiry by the Human Rights and Equal Opportunity Commission, but the implications of this issue for HREOCs e-commerce inquiry must also be noted. The inability to use mobile telephones makes it extremely difficult if not impossible for people who use hearing aids to utilise telephone-based services such as telephone banking. Telephones are becoming more and more functional as technology progresses. Many services such as banking, the paying of bills, and the ordering of goods and services can now be completed over the telephone. It is now even possible for people who are blind or vision impaired to use the telephone to read the newspaper. The functionality of the telephone and its further integration into everyday life will only increase. For this reason, it is important to consider the needs of people who are deaf or hearing impaired. Suggested strategies to enable people who are deaf or hearing impaired to be able to utilise this technology are: The integration of telephone typewriter (TTY) technology into all telephone based services The provision of all spoken information to be provided graphically (be it written or signed), through the use of a visual display situated within the telephone unit To ensure that all services offered through telephone technology are also offered through internet technology. E-Commerce and People with Cognitive Disability Some people with cognitive disability may have difficulty understanding what was being asked of them in an e-commerce transaction, while others may know what was being asked of them, but are easily lost by the process (a barrier related to memory and sequencing). Many internet services, particularly those which allow purchasing through credit card, depend on the use of a user name and password. This is to increase the level of security to accounts, personal information, and/or credit card details etc. People with cognitive disability may have difficulty in remembering their user name or password, or may mix them up where they have more than one. People with cognitive disability may also experience difficulties following prompts when using automated telephone systems. A number of people we consulted said that many menu driven telephone information services, like those found at government departments and commercial operators, are too complicated. You get lost before you find out what you need to know or before you have had the chance to pay your bill and I find that I have to hang up and try again many times before I am able to do what I need to do. Two ways of dealing with this issue were suggested: for the user to be put through to an operator who can assist them by providing the desired information or in performing the desired service To simplify the prompts and menu structures. People with cognitive disability encounter similar difficulties in using ATMs. The information provided or the process required is often too difficult for people to manage independently. Suggested solutions were: Simplifying the information and the process Allowing more time to complete a transaction Providing operator assistance through the use of a help line available at the ATM It is also possible that the ATMs interface could be modified to suit the users needs, for example, the user might be identified through a retinal scan. Screens could be modified to a much simpler format. (see further, Noonan op cit). People with cognitive disability may also experience difficulty in following touch screens. For example, they may experience difficulty in understanding and following the process. These difficulties can also be overcome by: Providing operator assistance, Simplifying data, menus and prompts and Allowing for more time to complete the desired interaction. E-Commerce and People with Neurological Disability 53 Some people with epilepsy are placed at risk of seizure if exposed to moving colours or flashing lights. The solution is simply not to use such methods when developing e-commerce technology, be it for web pages or stand alone automatic systems. CONCLUSION The issues raised in this submission are by no means exhaustive. What is presented here highlights, however, the very significant risks of the e-commerce explosion for people with disability. The digital age has enormous potential to break down many of the barriers that have traditionally excluded people with disability from full participation in community life. However, if it does not set out to do so in a conscientious way from the beginning, it may result in new and possibly even more pervasive forms of social exclusion that those we have encountered to date.  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