'Post-i2010: priorities for new strategy for European
information society (2010-2015)'
European Blind Union Position paper
1
This paper
EBU has responded to the online questionnaire “Public consultation
on post-i2010”. This is an additional position paper which explains in
broader terms our concerns regarding the inaccessibility to blind and
partially sighted people of many products and services in the EU. We
intend it to help inform the planning for post-i2010 work.
In this paper we also elaborate on a few of the answers we gave to
the online questionnaire.
EBU believes that "eaccessibility" and "eInclusion" must be central to
the strategy which succeeds "i2010".
Digital Exclusion
Blind, partially sighted and other disabled people are routinely
excluded from the digital world. This exclusion is felt in all areas
where digital technology is used.
The "eExclusion" of disabled people is a growing, rather than
diminishing problem. This is for two main reasons. Firstly, we live in
an increasingly digitized world with more and more new technologies,
many of which are converging. The lack of accessibility in those new
technologies and delivery of those technologies via new methods is
excluding blind and partially sighted people from participating fully in
society.
Secondly, there is and large and growing number of disabled people
in the EU.
Ageing EU - growing exclusion
The ageing EU population means that there are increasing numbers
of blind, partially sighted and other disabled people. The Commission
2
states in its "Action Plan on Information and Communication
Technologies and Ageing [COM(2007)332]" that "by 1995 70 million
people over the age of 60 were living in the EU, almost 20 % of total
population. By 2020, this figure will rise to 25 %. The number of
people over 80 years of age will more than double." It goes on to say
"21% of persons over 50 experience severe vision, hearing or
dexterity problems"
Statistics on the digital divide
The Commission has studied the exclusion of disabled people from
the digital world sufficiently to understand its seriousness. By way of
brief reminder, it is worth recalling that the 2007 MEAC study
demonstrated that:
Only 2.6% of key public and sectoral /commercial websites in each
Member State were accessible.
For government websites, percentages accessible were 12.5% and
5.3% for automated and manual testing, respectively.
Just 8% of all ATMs that had been installed by the two main retail
banks in the EU 25 countries provide 'talking' output to ensure
accessibility for people with visual impairments, with most of these to
be found in just three countries.
A rights issue
Furthermore, access to the digital world is a clearly- expressed rights
issue.
The EU's Member States and the EC are signatories to the UN
Convention on the Rights of Persons with Disabilities. Articles 9 and
21 of this Convention require Member States to ensure that disabled
people can access ICT systems and the Internet.
EBU strongly believes that blind, partially sighted and other disabled
people should be able to access all the services available to others.
3
We therefore maintain that people with disabilities should have a
“fundamental right" to these services, recognised in EU law.
But also an economic issue
However, eAccessibility and eInclusion are also very much economic
issues. Nowadays access to education, employment, online shops
and services including those provided by governments all require
access to digital systems.
If disabled people cannot access elearning, use laptops, or carry out
online research, they are less likely to be as well educated as their
peers. This problem is now being compounded by a new trend
towards e-assessment and e-examinations, which are being
introduced without due regard to their accessibility. All of these
problems will cause greater unemployment.
Employers using inaccessible IT systems also exclude blind or
partially sighted people, however qualified that person might be. This
weakens the economy by both reducing the breadth of talent in the
workforce, and by impoverishing individuals who are then less able to
participate in the EU's economy. In the UK, the UK Online Centres'
Report: "Digital Economic benefits of digital inclusion: building the
evidence" shows that "Computer/internet use commands salary
premiums (3-10%)" An inaccessible IT system excludes blind people
from such benefits.
Software houses who design their systems according to appropriate
standards ensure their systems are accessible. This enables them to
sell into a broader market. That market includes public bodies where
these have a legal requirement to procure accessible ICT. (This is the
case in the UK, for instance, where it is a requirement of the
“Disability Equality Duty”) Providing choice and competition in the
market in this way sustains the economy.
A lack of access to goods and services that can be bought over the
Internet will prevent disabled people from behaving as customers,
thus weakening the EU's economy in an area (the digital economy),
4
which is supposed to be a driver of the EU's future economic
prosperity. Further, the UK Online study found that by Internet
selling:
"Companies can increase customer base and sales volumes (online
spend is on average 20% higher than offline)."
In the UK, A Department for Work and Pensions estimate in 2004,
stated that disabled people in the UK have £80 billion pounds in
spending power. (See http://www.realising-potential.org/casestudies/industry/e-commerce.html) Inaccessible websites will prevent
access to those goods and services for disabled people, thus
preventing them from spending their money.
We will gain more than most from accessibility
Blind and partially sighted people have perhaps more to gain from
accessible ICT than most people. We want to use the digital world as
much as, and in some cases more, than our sighted peers. What is
more, technology can be empowering for blind people. Whereas a
few short years ago a blind person would have relied on somebody
else to read their correspondence, text-to-speech screen readers
provide a speedy and autonomous alternative. Internet shopping can
enable a blind person -who finds it hard to travel to a shop- to
purchase the goods they need without leaving their house.
For those people who have felt isolated as a result of their disability,
participating in the digital world gives them the opportunity to meet
friends online and participate in a community. Where it is difficult for a
blind or partially sighted person to get access to local services and
government information, accessible online alternatives can be a great
help.
5
Some elaboration on specific questions from the online
questionnaire
"Steps to open access to content to people with disabilities"
"6.9. For persons with disabilities, accessing cultural resources is not
always possible as their right of access is often in conflict with
copyrights. What can be done to ensure equal access to content for
persons with disabilities? "
EBU ticked the following answer:
" The exception foreseen in the Copyright Directive for ensuring
access by persons with disabilities should be stronger"
EBU agrees that there should be a right of access. We respect the
rights of those who own copyright and the need to protect and nurture
the EU's creative industries.
Copyright law is based on the concept of a fair balance between the
rights of rights holders and creators on the one hand, and users on
the other.
A minimum standard of copyright exception for print disabled people
would address the user end of this balance EBU believes that the
Commission should revise the Copyright Directive Directive
(2001/29/EC) to ensure a mandatory copyright exception for print
disabled people, thus providing a minimum standard of harmonization
across the EU. This would facilitate the sharing of scarce published
material in accessible formats between organisations across the EU.
That would save money and time and allow more books to be read by
print disabled people.
6
In terms of content on television EBU urges the Commission to work
actively with Member States to implement Article 3c of the AVMS
directive seriously.
"8.1. what are the key ways to increase take up of eGovernment
services by citizens? "
EBU ticked the following answer:
"Strengthen accessibility and usability"
All of the measures suggested are important to us. However, for the
European Blind Union, “strengthen accessibility and usability” is the
key. It is a simple fact that if a person cannot access these services,
both they and the service provider are excluded from the benefits the
on-line service is supposed to bring. The user misses out on fast,
easy access to vital government services. The Government has to
spend extra money on providing alternatives to "egovernment", thus
negating the potential savings in cost and efficiency an effective
egovernment service might bring.
Standards
"8.2. Do you think there is a need for a common European
understanding on quality delivery of ICT-enabled public services, in
view to improve access and participation for everyone? "
EBU ticked the following answer:
"Common minimum standards"
EBU believes there should be minimum standards for the
accessibility and usability of these services. The EU should play a
role in creating this "common understanding".
EBU notes the link between this aspiration and the DG Enterprise
and Industry consultation "Modernising ICT Standardisation in the EU
- The Way Forward", to which we have also responded
7
http://ec.europa.eu/enterprise/newsroom/cf/itemlongdetail.cfm?item_i
d=3263&tpa_id=133&lang=en
eHealth
Access to health related information is of course vital to all people.
Blind and partially sighted people often find their access to health
related information is barred by the use of inappropriate formats of
communication. For example, a doctor's letter in standard print being
sent to a blind patient who requires braille.
Increasingly, as health information is provided electronically, the
eaccessibility barriers blind and partially sighted people face are
extended to the realm of health. For instance, information in doctors’
surgeries is increasingly being provided on visual electronic
terminals, which are usually inaccessible for blind and partially
sighted people.
In the UK RNIB has launched a campaign to improve the provision of
health-related information called "Losing Patients". For full
information please see the link below:
http://www.rnib.org.uk/getinvolved/campaign/accesstoinformation/acc
essiblehealth/Pages/accessible_health.aspx
Impact of ICT on teaching and learning
The European Blind Union is concerned that education is not fully
accessible to blind and partially sighted people. Educational material
is increasingly delivered by digital means. This should be
empowering for blind and partially sighted students, if its accessibility
is taken fully into account.
It is essential that training of teachers is constantly updated and
delivered to ensure they are always up-to-date on how to use ICT in
the classroom, and on the access needs of disabled students.
8
Conclusion EInclusion must be an EU priority -further legislation
is needed
Mark Twain once said, “If you do what you’ve always done, you’ll get
what you always got.”
In the case of eInclusion, more studies and stakeholder groups will
not solve the problems outlined in the MEAC study and many others
besides. We believe now is the time for the Commission to bring
forward comprehensive eAccessibility legislation, to bridge the digital
divide for disabled people where other measures have failed.
EBU also believes that sector-specific legislation, which can
strengthen eInclusion for disabled people, is needed.
In our response to the online questionnaire we urge the Commission
to strengthen the accessibility provisions in EU procurement law.
We also believe that the Commission should revise the Copyright
Directive Directive (2001/29/EC) to ensure a mandatory copyright
exception for print disabled people, thus providing a minimum
standard of harmonization across the EU
For all the reasons given in this paper, we believe it is vital the
European Commission make eInclusion one of its prime post i2010
priorities.
9
About the European Blind Union
The European Blind Union (EBU) is a non-governmental and non
profit-making European organisation. It is one of the six regional
bodies of the World Blind Union, and it is the only organisation
representing the interests of blind or partially sighted people in
Europe. EBU aims to protect and promote the interests of blind or
partially sighted people in Europe. EBU currently has 45 member
countries, each represented by a national delegation.
We are happy for our contribution to be made public. For further
information or clarification, and to arrange future discussions, please
contact in the first instance:
Dan Pescod
Campaigns Manager, Europe, International and Accessibility
Royal National Institute of Blind People (RNIB)
105 Judd Street
London
WC1H 9NE. UK
Tel: +44 (0) 20 7391 2009
Fax: +44 (0) 20 7391 2395
email: [email protected]
10