Select Committee on Treasury Minutes of Evidence

Memorandum by The Royal National Institute for the Blind


  1.1  The Royal National Institute for the Blind (RNIB) is the leading charity working on behalf of the two million people in the UK with (uncorrectable) sight problems. We campaign for a society in which barriers are removed and people who are blind or partially sighted are empowered to play a full role within it. One of the major barriers to full social inclusion for people with sight problems is the tendency of Government departments, agencies and service providers to neglect their need for information in accessible formats. With many struggling to read ordinary size print (let alone small print) or unable to access it at all, there is a huge need for information in large print, on audio-tape, on disc or in tactile formats such as Braille. If information is not readily available in such formats then people with sight problems are effectively excluded and disempowered. It is important to set our remarks on the 2001 Census in this context.

  1.2  We are pleased to have this opportunity to inform the Committee of serious shortcomings in relation to the preparatory and consultative work for and the conduct of the Census itself, which prevented blind and partially sighted people from taking part on an equal basis with their sighted peers. This may seem surprising given that the theme of the Census was "Everybody counts". Yet in Census 2001, some counted more than others.

  1.3  Census 2001 involved the use of a census form which did not conform to RNIB's Clear Print Guidelines, over which we were not consulted and which was therefore inaccessible to people with sight problems. While information, including census questions, was made available on request in accessible formats (though often with huge delays) there was a refusal by ONS, up until the eleventh hour, to agree to accept Census returns by people with sight problems in alternative formats to the standard print form. Blind and partially sighted people did not know until after the Census proper had begun whether their right to make independent, confidential returns would be respected or whether they would be fined for failing to make returns on the standard form. Moreover blind and partially sighted people have reported many instances of insensitive or poor customer service by Helpline staff and enumerators.

  1.4  From this it will be clear that RNIB considers the whole Census process to have been deeply flawed and we look to this inquiry to give a strong steer to the Treasury and ONS on what must change for the future. Major lessons need to be learned in order to respect the rights and dignity of blind and partially sighted people and ensure they are fully "counted in" next time around. We are therefore pleased to put on the record our recommendations for change and would welcome the opportunity to give further oral evidence.


  2.1  In short, we find the preparatory work and consultation undertaken with organisations representing blind and partially sighted people to have been inadequate. It is not just that "consultation" happened late in the day it is also that there was a real failure to take many of our concerns seriously and act on them. Steps which we regarded as fundamental to respecting the rights of blind and partially sighted people and indeed eminently reasonable and practicable were rejected because they might cause minor administrative inconvenience. It would be wrong to cast all the blame on ONS. The Treasury should have anticipated many of the issues we raised and ensured that Census regulations dealt with them fully.

  2.2  This was compounded by the contradictory information provided by ONS on the question of accepting returns in alternative formats (discussed in paragraph 2.7 onwards) which left blind and partially sighted people in a state of uncertainty as to what fate would befall them if they tried to give their returns over the phone or in an email or on tape, for example.

  2.3  Timely consultation with organisations of and for blind and partially sighted people by both the Treasury and ONS, married with a fuller appreciation of their rights and needs, could have prevented many of the iniquities and difficulties highlighted here.

  2.4  RNIB's first contact with ONS was in September 1999 when the Community Liaison group invited representatives from charities to attend a meeting. The minutes from this meeting noted our dismay at the inaccessibility of the Census form (poor colour contrast—brown type on a fawn background—with small print and boxes to complete) for anyone with a sight problem. We were told that it was too late to make any changes to the form itself. But we flagged up the need to provide the form itself and supporting information in a range of accessible versions for blind, partially sighted and other disabled people. We also said it would be necessary to put procedures into place to ensure anyone with a sight problem would be able to identify enumerators calling at their door and provide a password system to ensure their security. We also highlighted the importance of staff receiving disability awareness training including a visual impairment component.

  2.5  RNIB was contacted after this to provide quotes to transcribe the information leaflet and questions into other formats. There were no plans to work with us on a wider strategy to ensure the whole process was fully accessible. RNIB's business unit were contracted to provide Braille versions of the leaflet and questions. RNIB also gave advice on the layout of the large print leaflets. Our request that the forms be transcribed into accessible formats and that returns in these formats be accepted was rejected.

  2.6  ONS' argument for not accepting returns on anything other than the standard form was that the forms had been designed to be scanned into a computer and it would be inconvenient for staff to have to manually input data provided in other ways. We pointed out that not accepting returns in alternative formats would deny blind, partially sighted and deafblind people the opportunity to participate in the Census independently. While welcoming the fact that assistance would be available we said that many people would feel that sharing information with a stranger was in breach of their right to keep confidential information private. If individual sighted members of households were entitled to confidentiality why not visually impaired people? We also pointed out that there would undoubtedly be standard forms returned which had not been properly completed or had been scribbled on which would not scan in properly. In those cases staff would be manually inputting data, so why were they not prepared to extend the same service to people who had been denied the opportunity to complete an accessible form?

  2.7  A Parliamentary question was subsequently tabled by Andrew George MP asking among other things: "if Census 2001 returns in England and Wales from blind, partially sighted and deafblind people will be accepted if they are submitted in alternative formats, with particular reference to (a) large print, (b) Braille, (c) disc, (d) audio-tape and (e) e-mail; [141550]". The reply received from Len Cook on 18 December 2000 stated that:

    "We do not propose to provide the Census forms themselves in Braille or in large print version since the Census is being processed using scanning and image recognition technologies which cannot accommodate forms other than in the standard format. Help in completing the form will, however, be provided by Census enumerators, on a one-to-one basis if necessary, and the blind will be able to provide their Census information by telephone to the Census Helpline or via e-mail using the Braille leaflet as a guide to the questions."

  2.8  This reply initially signalled to us a change in ONS policy and we were delighted. Until, that is, we sought confirmation. Several people rang up ONS to be told that this was not in fact the case and that Census returns would not be accepted on anything other than the standard form. Senior ONS officials also confirmed that alternative format returns would not be accepted. We have yet to receive an explanation of why a misleading response to this parliamentary question was given. We wrote to the Economic Secretary demanding an apology and urging the Treasury to intervene to no avail. Subsequently blind and partially sighted people began to complain to ONS in large numbers about lack of provision for their needs.

  2.9  Then on the eve of the Census, ONS went on Channel 4 News to say we had got it wrong! In a subsequent interview on Radio 4's In Touch programme (1 May 2001), John Pullinger admitted maybe they did "miss a trick" as they had not planned to produce forms that could be processed through their systems in alternative formats. He was then asked by interviewer, Peter White, if he had now changed his mind about people returning their forms in alternative formats. Mr Pullinger went through what assistance and materials were already available saying that this was "the surest way to make sure that information is recorded properly, as that's how the system is set up to do it". Peter White then said that he knew for a fact that people were returning their answers in their own preferred formats having completed the forms themselves on a typed sheet for instance, and asked Mr Pullinger if they would be processed. Mr Pullinger replied that where people had made genuine attempts to give the required information they would do their utmost to ensure that it did count, but said again that they were "set-up" to deliver the information on the forms and that was the surest way to make sure your information was there.

  2.10  In effect what ONS had apparently decided was that they would accept returns in alternative formats but they did not want to encourage this. Clearly the policy change should have been communicated fully and pro-actively to blind and partially sighted people to avoid any doubt in their minds that their returns would be counted and that they had choice as to how to make them.

  2.11  If ONS had carried out earlier and more meaningful consultation, it might have been aware how strongly people with sight problems felt about being able to complete their form independently and confidentially just like sighted people. It should also have considered the principles established in the Disability Discrimination Act and the Human Rights Act 1998.

  2.12  Section 21 of the Disability Discrimination Act (DDA) states that service providers should make reasonable adjustments to ensure blind and partially sighted people can access their service—including through the provision of information in accessible formats. ONS were not sure that the DDA applied to them because the Census was not strictly speaking a service to the public. However RNIB believes the Census should still have been conducted in the spirit of the DDA.

  2.13  The Human Rights Act 1998 which came into effect in October 2000 should also have been taken into account. It is arguable that not providing blind and partially sighted people with the opportunity to complete their own forms in confidence would be in contravention of Article 8 of the Human Rights Act 1998—the right to respect for private and family life, home and correspondence—as well as Article 14 which protects people against discrimination in the exercise of such rights. Similarly Article 10 on freedom of expression includes the right to receive and impart information and issues would be raised under this Article and Article 14 if a group of disabled people were systematically excluded in this way.

  2.14  Lack of timely consultation and preparatory work also meant that the Census was not effectively promoted to blind and partially sighted people. In the event, ONS only started placing information in our publications two months beforehand. Combined with ONS' equivocation over the issue of alternative returns the whole strategy for informing blind and partially sighted people of what was involved in the Census, what information they could get in what formats and what assistance they would be entitled to was sorely lacking.


  3.1  In effect the absence of clear, well-targeted information meant that blind and partially sighted people were not able to take part in the Census on an equal basis. Many will have assumed it was necessary to struggle to complete a poorly designed Census form or to hand it over to friends, relatives, neighbours or enumerators to do it for them because ONS did not inform them they could do otherwise. A number will have made alternative format returns, although as discussed below many experienced problems getting the information they needed to make those returns.

  3.2  Poor levels of customer service and misinformation through the Census period proper worsened the situation for blind and partially sighted people. This poor level of service included:

    —  People being told that it would not be possible for an enumerator to help them complete the form.

    —  People being told that there were no alternative format information leaflets and questions available.

    —  People waiting weeks for the information leaflet and questions in accessible formats or, indeed, not receiving them at all. Many people were repeatedly only sent the information and not the questions. One Braille user was asked to return his copy swiftly so they could pass it on to someone else. Another was told there was a delay on the Braille Census information. Enumerators visited her twice and neither had been able to get her the Braille information. The second time she was put under pressure to fill out her form even though they had not provided the information in Braille.

    —  People continuing to be told that they could not make alternative format returns and they would be fined if they didn't complete the standard form.

    —  Census staff making insensitive comments and not being aware of the needs of people with sight problems. For example, one person asking for a large print form was wrongly told that the standard form was large print. When they insisted it wasn't they were told "it's quite large—you should be able to manage it."

  3.3  Other problems and concerns reported to us include:

    —  Not being able to get through to the helpline.

    —  The absence of a password system to reassure vulnerable people to know who they were letting into their house.

  3.4  RNIB has much anecdotal evidence from people with sight problems, who were confused, frustrated and anxious about completing their Census form before the deadline to avoid a fine and were unable to get the correct information in a form they could easily access. It would be interesting to know to what extent complaints direct to ONS were logged or indeed if a complaints procedure was flagged up to people.


  4.1  RNIB would like to see the Census ask more questions about disability to enable the future provision of services to become better targeted towards people who are blind or partially sighted. We had made representations about this, which, again, were ignored.


  5.1  RNIB welcomes this opportunity to place on record our recommendations for the future conduct of the Census to ensure it is fully accessible to blind and partially sighted people.

Guiding Principles for the Next Census

  5.2  If the next Census is to be fully inclusive it must be designed from start to finish according to some key guiding principles or overarching objectives.

  5.3  In general, we seek a commitment from the Treasury and ONS that the next Census will be planned and conducted in such a way as to fully conform with the Disability Discrimination Act 1995 and the Human Rights Act 1998 and indeed go beyond basic standards of accessibility and embrace a best practice approach to meeting the needs of all disabled people.

  5.4  We further seek full acceptance of the principle that people with sight problems and other print disabled people should be able to take part in the Census independently.

  5.5  It will therefore be necessary to consult people with sight problems, and organisations representing them, to discover their needs before planning the next Census. It is also necessary to continue consulting throughout the process to ensure that any decisions made do not have a detrimental impact on people with sight problems.

  5.6  Even with advances in technology opening up the potential of expanding the use of e-mail and the Internet as a means of disseminating and gathering information for the next Census we think it would be wise to assume there will be no one way in which everyone will be able to take part. We think a starting point should be to assume that a diversity of options will need to be present to ensure everyone gets the information they need to take part in a form they can best access and everyone has a chance to make returns in the manner they find most convenient and accessible.

Detailed Recommendations and Specific Design Criteria

  5.7  The design of the standard Census form must be reviewed. As well as providing the form in other formats the most sensible and effective step to ensure "everyone is counted in" is to ensure that the standard forms are designed to be as inclusive as possible. This would involve using a simple font, a larger point size and good colour contrast. Recent research by RNIB suggests that it is not just blind and partially sighted people who have a problem reading small, poor contrast print—there are millions more who find this difficult. The standard version should also promote the availability of other formats and include the Helpline number in large clear print.

  5.8  Blind and partially sighted people should be fully consulted on any proposals to develop the use of ICT for the next Census to ensure its complete accessibility. Currently many people with sight problems face huge disadvantages in relation to ICT. While most have access to a phone, the majority of older people do not have access to a computer and therefore to e-mail or the Internet. Those that do find that web pages are often designed so as not to respond to screen reading software which could otherwise translate them into synthetic speech or temporary Braille displays.

  5.9  Blind and partially sighted people and other print disabled people must be able to get copies of information about the Census and the questions in their preferred format and in a timely way. They must also be entitled to return their answers in their preferred format whether that be in Braille, large print, on tape, via e-mail or an accessible web-form. Again forward planning will be needed to establish what type of accessible versions are needed in what quantities. Of course some people may still need personal assistance to complete the form.

  5.10  Blind and partially sighted people must have access to a free-phone Helpline that is answered efficiently and provides accurate information. Helpline staff should receive disability awareness training. This should involve more than general equality training, staff need to be fully aware of the particular information and communication needs of disabled people in their diversity. Training must include specific modules on visual impairment and deafblindness. This has implications for the recruitment process and adequate time and resources must be set aside for high quality training.

  5.11  Similarly, each enumerator should receive an appropriate level of disability awareness training so that they are aware of and can respond to the information and communication needs of blind and partially sighted people.

  5.12  A password scheme for enumerators must be devised and accessible Braille and large-print ID provided to guarantee the safety and security of those disabled people who want assistance with completing forms and making returns. This assistance, moreover, should be available to anyone who asks for it.

  5.13  Promotion of and awareness-raising about the Census needs to begin much earlier on if hard-to-reach groups especially those with problems accessing print information are to be informed in time. Next time around, resources must be devoted to a specific education and awareness campaign targeted at blind and partially sighted people explaining what information is available and what methods they can use to reply. In addition, provisions for people with sight problems need to be included in mainstream advertising and not confined to speciality press.


  6.1  We have almost a decade to ensure that the next Census is fully accessible to blind, partially sighted and other disabled people. There can be no disagreement as to the importance of getting this right. The more effectively everyone is counted in, the more reliable the results will be. Effective service planning depends upon an accurate information base.

  6.2  By the time of the next Census human rights principles should be more firmly rooted in the culture of public authorities and the DDA will in all likelihood have been extended to cover all the functions of public authorities, making the obligation on Government departments and agencies to respect the rights of all disabled people much stronger and more wide-ranging. That said we would strongly caution against assuming this will necessarily mean the next Census is a beacon of equal access. We would welcome an investigation by the Committee of what can be written into the Census legislation and regulations to ensure our recommendations are at the forefront of Treasury and ONS thinking around the next Census in time to make a real difference.

2 November 2001

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