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
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
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
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
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
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
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
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
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
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
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 http://www.w3.org/TR/WAI-WEBCONTENT/.
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.