Select Committee on European Union Minutes of Evidence

Annex 1

eEurope: An Information Society for All

Draft Response from the Advisory Committee on Telecommunications for Disabled and Elderly People (DIEL)

  DIEL welcomes the opportunity to comment on the European Commission's Communication, eEurope: An Information Society for All.

  DIEL was set up under the UK Telecommunications Act 1984 to advise the UK Telecommunications Regulator, the Director General of Telecommunications, about the interests of disabled and elderly telecoms consumers. It aims to promote the provision of the additional requirements of disabled and elderly consumers for access to telecoms services.

  DIEL welcomes the eEurope initiative and the adoption of inclusion as one of the key objectives and endorses the statement that the advent of the Information Society is a crucial event and key opportunity for the EU. We agree that an adequate response is essential, and believe that the Information Society could bring particular benefits and greater opportunities for inclusion in many aspects of social and economic life to disabled citizens throughout the EU. DIEL is, however, concerned that, if adequate provision is not made in all areas of the initiative to meet the needs of disabled and elderly people, many of them will be excluded from these benefits and opportunities and hence from full participation in community life.

  DIEL has recently responded to an EU Communication setting out proposals for a Policy Framework for EU Communication Legislation. In our response we highlighted the problems which still make telecommunication services inaccessible to many people with physical and sensory impairments. We argued that the increasing importance of Information and Communication Technologies in all aspects of social and economic life make it essential that the future EU Framework for Communication Legislation should include effective measures to make telecommunications accessible to all.

  Specifically, we urged that to make services accessible, appropriate terminal equipment had to be available to meet the requirements of disabled and elderly people. Disabled or elderly consumers should not be put at a disadvantage by having to pay higher costs for equipment to access services than the costs of standard equipment. DIEL fully supports the adoption of "Design for All" principles to make standard products more useable by disabled people, but believes that for the foreseeable future, additional equipment and services will be required. Provision of these in parallel with equipment for non-disabled consumers will be crucial for developments in communications.

  In responding to the present Communication, DIEL wish to state our belief that the provision of suitable terminals for accessing telecommunications services is a basic essential for inclusive development of the Information Society. In addition, appropriate equipment and software will be essential for people with sensory impairments and severely impaired mobility or dexterity or learning disability to use computers and other interfaces with information services.

Key Concerns

  1.  We are disappointed that the targets and objectives set in the present Communication do not seem to us to include major actions needed to ensure that disabled and elderly people will be fully included in the development of the Information Society in the EU.

  2.  Equally, those actions should be initiated if the EU is to generate the social and economic benefits which will result from all citizens being part of the Information Society.

  3.  DIEL accepts the approach taken in the Communication of identifying key action areas (except that, as outlined below, we would wish to see an additional key area for Older People). The action programmes for each area must not develop in isolation, however. It is essential that the programmes in the key areas include actions needed to achieve targets throughout the initiative. Programme managers inevitably tend to give priority to achieving their own targets, so DIEL believes it is necessary for targets to achieve access for disabled and older people to be made throughout the initiative.

  4.  Omission of Older People from list of key action areas.

  Older people are:

    —  most likely to have problems in adapting to new technologies and to be reluctant to change their ways of obtaining information;

    —  often on low or reduced incomes;

    —  likely to become more disabled making it more difficult to use equipment and services;

    —  at risk of suffering reduced social contacts and increasing isolation; and

    —  many older people may well have no wish to be "online" but all will need direct or indirect access to the information and services which will increasingly be most available over the Internet.

  5.  There should be an additional action area, "Senior Citizens in Europe and the Information Society".

  In this area it is essential that the EU should consult older people and organisations for older people to identify and address the problems and opportunities that the developing Information Society will present for them. Targets should be set for identifying and implementing appropriate interfaces and methods of communicating information, which are acceptable to older people in each Member State.

  The needs of older people should also be taken into account and included specifically in the targets for other action areas such as: Smart Cards, eParticipation for Disabled People, Healthcare Online, Intelligent Transport and Government Online.

  6.  Inclusion of disabled and elderly people should be addressed in individual policy action areas. DIEL welcomes the policy area eParticipation for the Disabled and its objectives to ensure that legislation and standards programmes, information and communications products and services and public websites are accessible. However other policy areas should include specific provision to take account of the requirements of disabled and elderly people where this is needed if these objectives are to lead to full inclusion for them.

  7.  Comments on specific action areas now follow.

  8.1  Section 1: European Youth into the digital age. This section should consider how the targets will be achieved for teachers with disabilities and pupils for physical, sensory and learning disabilities.

  Technology used must be accessible and should include the financing and provision of appropriate terminal equipment and software for children with physical or sensory impairments and learning disability.

  The support services to be provided should include additional support and training for disabled pupils and teachers.

  The EU should adopt Web Accessibility standards for approved educational sites. DIEL supports the amendments to the targets suggested in the submission from the RNIB:

    "All schools should have access to the Internet and multimedia resources for all pupils and teachers, including those with special access needs".

    "Access to Internet and multimedia resources in public centres should be made available to all youngsters including those in less favoured areas and those with special access needs".

    "All teachers should be individually equipped and skilled in the use of Internet and multimedia resources and able to support all pupils, including those using special access technology."

  And the added target suggested by RNIB:

    "All pupils with special needs will be provided with any additional technology and training to enable them to access Internet and multimedia resources."

  8.2  Section 2: Cheaper Internet Access. Disabled people must be able to access information via the Internet on the same terms as others and at no extra cost. For many, this will only be possible if cheap accessible equipment and software is available. This is particularly important if disabled people are to benefit from the employment, training and education opportunities provided by the Internet. Services which are simple to access and to use are particularly important to older people and to people with learning disabilities.

  8.3  Section 3: Accelerating e-Commerce. DIEL believes that access for all to goods and services, including information and learning opportunities, should be a legislative requirement in Member States. If the EU is to encourage SMEs to move into e-commerce, they should be obliged/assisted to ensure that these services are accessible to all disabled and elderly people. These consumers should not face discrimination by exclusion from services offered over the Internet on preferential terms.

  8.4  Section 4: Fast Internet Access for researchers and students. This access should be available to students and researchers with disabilities. Such access can be most effectively and economically provided if the requirements are taken into account during the design phase of enhanced services and applications.

  8.5  Section 5: Smart Cards for secure electronic access. Smart Cards could be particularly useful for disabled and elderly people as they offer the possibilities of overcoming communication difficulties and configuring equipment and interfaces to meet individual requirements such as speech output or large print on terminal screens. It is imperative that the needs of disabled and elderly people are taken into account to enable them to use the new systems on equal terms with others.

  8.6  Section 6: Risk Capital for high-tech SMEs. e-Commerce offers particular potential opportunities for disabled people to engage in economic activities at less disadvantage because of any communication or mobility difficulties they may have.

  The opportunities for flexible working in e-commerce are particularly attractive to many disabled people.

  The Reviews to be conducted and processes to be established should ensure that disabled people have full access to information about the opportunities to be created and are encouraged to make use of these.

  8.7  Section 7: eParticipation for the disabled. (DIEL urges the use of the phrase "disabled people" rather than "the disabled" by the Commission in documents intended for the UK. The phrase "the disabled" is felt by many disabled people to be impersonal and to give an effect of stereotyping and demeaning disabled people).

  We welcome the identification of participation of disabled people as a key area for eEurope and the proposals made.

  We strongly support the approach to access of:

    1.  Adopting "Design for All" principles in design of standard equipment and services to achieve the maximum practicable access for disabled people.

    2.  Where special equipment and services are necessary to provide access, consistent standards should be set across the EU to ensure compatibility and increase the size of the potential market, thus encouraging manufacturers to enter the market and reducing costs. Additional costs should not be charged to disabled people requiring the equipment or service.

  DIEL would like to see earlier and firmer actions than those in the Communication, and supports the amended and additional targets proposed in the submission from the RNIB, quoted at the end of this passage.

  We support the proposal for accessible web design, and believe that the principle of accessibility should be extended to all online information services, including those for which the technology is not web-based.

  We believe that the action programme must take account of alternative means of accessing the Internet. Any guidance should include Internet access via digital TV, digital radio, mobile communication and Wireless Application Protocol devices. The programme should include cheaper and more widely available access technology for disabled people and measures to ensure that manufacturers produce suitable terminal equipment.

  Simplicity of access and of use is important for many disabled and older people, particularly for those with learning disabilities.

  We are disappointed that the programme does not include specific actions to take advantage of the Information Society to increase training and employment opportunities for disabled people. We believe that the eParticipation programme must interact with the other strands of the eEurope initiative to provide the support, training, equipment and environment for disabled people to access employment opportunities on a more equal basis.

Revised and additional targets (RNIB submission)

    By end April 2000: The European Commission and Member States should adopt the standards of the Web Accessibility Initiative (WAI) in relation to the design of websites, Web authorising tools and agents.

    By end 2000: The EC should review the relevant legislation and standards programmes dealing with the Information Society, with a view to ensuring their conformity with accessibility principles and accelerating the standardisation process.

    By end April 2001: All for-profit and public sector websites must adhere to WA1 standards to ensure full participation. Ref WAI Web Content Accessibility Guidelines (WCAG) 1.0

    Note: "Conformance Level Double-A" as minimum standard.

    By end 2001: Development of a piece of browser software that people with disabilities can use to browse the Web, that is written to WAI standards and that can read websites that are written to WAI standards. Ref. WAI User Agent Accessibility Guidelines (UAAG) 1.0. This software should be distributed to disabled Net users at no cost (any cost is likely to be prohibitive and to delay the uptake of Internet access by disabled people).

    By end 2001: Development of a piece of software that authors validated WAI compliant HTML websites.

    By end 2001: The European Commission will support the creation of a Network of Centres of Excellence, at least one in each Member State, that will develop a European curriculum module in "Design for All" to train designers and engineers.

  8.8  Section 8: Healthcare online. Use of information technologies in healthcare should benefit many disabled and elderly people, who often suffer from inaccessible information and services and difficulty in communicating with service providers. It is essential that the targets in this area take account of the access needs and preferences of disabled and elderly people. This programme should work closely with the development of smart cards (Section 5) in ensuring that the access requirements of disabled people will be met.

  8.9  Section 9: Intelligent transport. The provision of information in accessible formats is essential for disabled people.

  New technologies could be used to make information available on demand, at home, at work and during the journey. Digitally provided information could be delivered in speech, large print or braille formats as required.

  Position finding and location tracing systems possibly linked to mobile communication devices could have enormous impact on the lives of disabled and elderly people.

  8.10  Section 10: Government Online. It is essential that national Government and EU information sites should be fully accessible to the standards outlined above, and that consultation processes should be audited and monitored for accessibility and to ensure that the views of disabled and elderly citizens are being properly represented.

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