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
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 contrastbrown type on a fawn backgroundwith
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
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
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; ".
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 serviceincluding 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
1998the right to respect for private and family life, home
and correspondenceas 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
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 largeyou should
be able to manage it."
3.3 Other problems and concerns reported
to us include:
Not being able to get through to
The absence of a password system
to reassure vulnerable people to know who they were letting into
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
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
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 printthere
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
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
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
2 November 2001