• ON CONNECTION
• ON CONFIDENCE
• ON CONTENT
• ON COLLABORATION
• ON ACHIEVING OUR DIGITAL POTENTIAL
• OTHER COMMENTS

ON CONNECTION

What do you think of the new connection goal – is it ambitious enough?

The goal is well worded, but more emphasis is needed on making broadband available over the whole country. Speed and affordability are important, but effort needs to be put into closing the digital divides around rural and remote access.

Connection is important to the Royal New Zealand Foundation of the Blind (the Foundation) as a means of delivering innovative service. The Foundation's talking book library is about to undergo a conversion from a postal library of analogue cassettes to an internet-based system which delivers Digital Talking Books (DTBs) to players in people's homes. The players are designed for blind people who have little experience with technology or computers. It is critical that Foundation members can continue to access the information and entertainment in magazines and talking books. In future, DTB players and broadband could possibly provide a range of support to Foundation members or other people with less severe vision impairments. Broadband could facilitate remote training and care services, medical monitoring and remote healthcare. An example would be the use of e-Health systems to provide “virtual visiting” for the home care of vulnerable members of the community.' ^[1] Health sector strategies support this direction^[2].

 Until broadband access is affordable and available to the whole of New Zealand, such services would not be equitably available to all.

We note that both the Labour-led Government and National believe significant resources should be directed into improving New Zealand’s broadband, and we fully agree with this strategy.

What other key priorities in this focus area (if any) would you like to see considered?

Facilitating 100% penetration of broadband across the country.

How well do the identified challenges and actions contribute to achieving the priorities?

The coverage challenge (97% coverage by 2012) is not ambitious enough in terms of coverage or timeliness. Broadband, through various technologies, should cover 100% of the country before 2012. In terms of the Foundation's service goals (DTB library service and other kinds of remote service delivery), the speed of broadband is less important than its availability. A reliable 256K speed available to all New Zealanders would be sufficient for initial DTB service.

The identified actions which could contribute to the priority of 100% coverage are the revision of the Telecommunications Sector Obligations, improved access to the transport corridor, promoting "broadband friendly councils", and using the National Broadband Map to plan broadband coverage.

What other specific challenges and actions (if any) do you think should be considered? By whom and by when?

Alongside aggregation of public sector demand, Government could play a role in aggregating demand for community groups, so that communities could connect members at an affordable price. Engaging with communities and not-for-profit organisations could allow Government to bridge digital divides more effectively.
 

ON CONFIDENCE

What do you think of the new confidence goal – is it ambitious enough?

The new Confidence goal needs to explicitly include all New Zealanders.

The goal assumes that digital technology is suitable for all users and all that is required for someone to become "digitally capable and confident" is training. While confidence with digital technology can lead to greater inclusion and participation in education, employment and culture, it is not only about upskilling the individual.

Technology itself can present barriers. Universal design principles are needed to ensure that technology is designed to be accessible to print-disabled people from the beginning. For example, current touch screen technology cannot be operated by a totally blind person without modification or additional access technology. Because of the use of touch screens, some EFTPOS terminals are inaccessible regardless of an individual's confidence. It is expensive and inefficient to develop “add on” adaptive technologies so that disabled users can access technology that was created without considering their needs. It has been shown time and again that when designers “get it right” for the blind community, invariably everyone benefits.

 In addition to better design, appropriate training is required for different learning styles and needs, particularly for groups who have been less connected to digital technology or who have specific learning needs. SeniorNet is an outstanding example of a community-based initiative that equips older individuals to access and contribute to the flow of social information. Specifically targeting support to groups with less digital confidence will help increase their confidence, raise their performance and boost their employment opportunities.

What other key priorities in this focus area (if any) would you like to see considered?

Government should adopt or mandate standards for universal design and ensure that publically available equipment is accessible to all users, including people with sensory and other impairments. A comparable standard for access to the built physical environment is NZS4121: Design for access and mobility: buildings and associated facilities.

In developing digital literacy in schools and the community, specific attention should be focused on training for disabled people, for whom technology can be life-changing.

How well do the identified challenges and actions contribute to achieving the priorities?

All of the identified action areas need to specifically address disability and access issues, for example the unified IT skills strategy. This needs to encompass both training for disabled people and training for all so that universal design principles are a basic part of ICT development and common usage, for example in education.

The digital workforce must be educated in digital standards for universal design, to ensure that innovation is inclusive and enabling. Failure to do so would allow for the perpetuation of a disabling society.

Blind, deafblind and vision-impaired people have particular needs. Training programmes must not be designed solely for people who can see and read standard print, and who can use software without altering its on-screen appearance or using adaptive technology. Training should equip all New Zealanders with the confidence and skills so that they can fully benefit from technology.

The unified skills strategy needs to include not-for-profit organisations who would benefit from digital skills, but may lack funding for staff training or technology. Though not-for-profit organisations are not “trying to grow their business”, better use of digital technology should lead to better services for thousands of people.

What other specific challenges and actions (if any) do you think should be considered? By whom and by when?

Government should mandate standards for universal design of publically-available ICT equipment and software.

Government should promote security protection measures that do not discriminate against disabled people. Examples of discriminatory technology include CAPTCHA[3], and copy protection on digital content that locks out access by adaptive technology.

Digital Strategy 2.0 should specifically and positively reference the New Zealand Disability Strategy. Digital technology and content can be a powerful means of reducing the disabling effect of a society that does not provide all citizens with the same level of access to information. Equity of access is not inevitable - digital content needs to be created with standards, thought and care. Technology needs to be developed from the beginning with universal design principles in mind. From the Disability Strategy[4]: "Although New Zealand has standards for accessibility, schools, workplaces, supermarkets, banks, movie theatres, marae, churches and houses are, in the main, designed and built by non-disabled people for non-disabled users. This is our history of disability in New Zealand." There are parallels in "Digital New Zealand". E-government guidelines have not yet meant that print-disabled people can access government information and processes equitably, even where they use digital channels. The digital community simply is not inevitably inclusive.

The current e-government programme should be reviewed annually in terms of how well it delivers equitable access to government services for print-disabled people. Our experience has been that the e-government has not yet enabled print-disabled people to routinely read public information or fill out forms on government websites. This said, there have been some very enabling examples of good practice. For example, the most recent online census provided the first opportunity for some Foundation members to complete their own census forms independently.

Digital voting is one area where the e-government programme is not moving quickly enough. Electronic voting could help blind people engage in the political process, but the Government's current proposal is to introduce a very limited pilot in 2014 with slow expansion over the following 10 years. This should be fast-tracked, and the Foundation is able to assist.

Government should ensure that all digital initiatives supported by the Digital Strategy contain explicit commitments to deliver equitable access for people who are print-disabled.

ON CONTENT

What do you think of the new content goal – is it ambitious enough?

The goal is fine - the difficulty is in implementation.

Digital content needs to be specifically designed to be accessible to all. Digital standards like HTML were designed to facilitate universal information access[5], but due to oversight or lack of awareness, content is not routinely created in accessible ways. Currently there are serious gaps in the accessibility of digital information even at government level, and there is virtually no legal redress if information is not made available in an accessible format. Digital content has the potential to be profoundly empowering to print-disabled people, who are disadvantaged by a society which still presents its information in primarily visual ways. Only 5% of information available in print is also available in formats accessible to print-disabled people. There is no reason for this statistic to be replicated in the digital information sphere.

Universal accessibility of digital content will mean that all New Zealanders are able to leverage the opportunities that digital content provides for social participation, life-long learning and business interaction. Failing to ensure accessibility will almost certainly create new disparities.

What other key priorities in this focus area (if any) would you like to see considered?

Government should ensure equitable access to all content for all New Zealanders regardless of sensory or other impairment. Digital does not always equate to accessible - accessibility standards and user testing with disabled people are required.

How well do the identified challenges and actions contribute to achieving the priorities?

In switching to digital television, there is an enormous opportunity to introduce accessibility standards. The review of the regulatory environment for digital broadcasting and media should address mandatory audio description[6] and captioning, and universal design standards for equipment. Internationally, legislation is being introduced to require audio description and captioning of digital video content. In New Zealand, this should be built in from the beginning. Sadly, New Zealand is lagging well behind in this area.

 All digital culture initiatives supported by the Digital Strategy should have accessibility standards built in and explicitly state a commitment to deliver equitable access for people who are print-disabled. Criteria must be developed to ensure that funding is denied to projects that create access barriers for disabled people, for example inaccessible websites and media campaigns that do not provide for people who cannot read standard print.

The actions identified in this area are all excellent initiatives which will enhance New Zealanders' access to information and culture, but care is needed to ensure this access is equitable for all. NZ On Screen should be required to include audio description and captioning. Digital New Zealand and the Kiwi Research Information Service should be required to include accessibility standards for digital content to ensure all New Zealanders can participate and benefit.

What other specific challenges and actions (if any) do you think should be considered? By whom and by when?

Government should:

• help set and then enforce accessibility standards for content creation across all sectors (cultural, government, business, education, etc).

•  develop and adopt accessibility criteria for projects supported by the Digital Strategy to ensure usable, standards-based frameworks are employed which can be equitably accessed by users with impairments.

•  provide support to publishers so they can use new technologies to make published content accessible.

• introduce legal requirements for accessibility e.g. through human rights legislation.

•      include accessibility requirements in Government contracts and procurement policies, similar to Section 508 in the US.

•   review e-government guidelines annually in terms of access for print-disabled people and strengthen as necessary.

ON COLLABORATION

How important do you think collaboration across sectors is to achieving our digital potential?

Collaboration is of critical importance to the Foundation and the country. Only through collaboration can we increase information access and reduce costs associated with making information accessible to all. Digital ways of working can knock down traditional silos and allow new ways of collaborating. Collaboration which assists government departments and social enterprises to minimise inequity is a social investment.

Apart from the ones already identified, what other collaboration partners or sectors (if any) are vital to achieving our digital potential?

Business, including publishers of non-digital content like books. Publishers are a key collaborative partner for the Foundation as they are increasingly making their digital files available to us for conversion into accessible formats. This could allow for accessible formats to be made available to blind readers at the same time print versions are available to fully sighted people. Presently, this is the exception, but it should be the rule.

 
Creators of web and other online content. The creation of local content is key to New Zealanders' engagement with the digital world. Standards and testing are needed to ensure opportunities are available to all - the Foundation works with digital content creators to provide advice on accessibility.

 
The cultural sector, including galleries, libraries, archives and museums. The National Digital Forum is a key representative group and a prime example of sector collaboration - it is surprising and disappointing that the Forum is not referenced in the Digital Strategy.

Educators, librarians and information workers. The whole of society needs to understand and be able to leverage opportunities from digital technology. Opportunities include educational outcomes, creativity, social and democratic participation and productivity, as well as enhanced economic outcomes.

The overarching sector forum needs to include disability organisations as part of the "community".

What unique contribution do you see for Mäori, for communities, for business groups, for local government, for researchers or for other contributors you identify as having a key role?

Disability groups can contribute expertise on issues of usability for universal design. Expertise in "getting it right" for a group with specific access needs can improve usability for everyone. For example, digital content which is "unlocked" for print-disabled people can be enabling for everyone, not just for people who cannot access analogue formats. A digitised archival document delivered as structured machine-readable text alongside a high-quality image can be read using screen readers or a range of adaptive technology. It can also be searched efficiently, can be delivered to cellphones and devices with different sized screens, can be repurposed into a synthetic-speech podcast, and can be reused in creative ways by all New Zealanders, all with little or no extra effort or investment.

What would you like to see the overarching sector forum focus its work programme on?

Bridging the digital divide and ensuring all New Zealanders have equitable access to connection, confidence and content must be the prime focus so that disadvantaged groups can benefit from technology. By focusing attention on solving the most difficult access issues first, all kiwis will benefit.

ON ACHIEVING OUR DIGITAL POTENTIAL

Using digital technology, what contribution will you make to improving our productivity (achieving a creative, knowledge-based, high-income economy)?

The Foundation is and will continue to be a best practice example of accessibility, and will continue to advise government, business and the community on inclusive standards to ensure that print-disabled people can participate and contribute equitably.

Using digital technology, what contribution will you make to enriching and valuing New Zealand communities and cultures, and promoting our unique national identity?

The Digital Talking Book programme will help preserve and promote New Zealand literature and culture for people not able to access print. The Foundation will engage in collaborative projects such as our current work with NZETC, supported by the Community Partnership Fund, to convert their store of digitised New Zealand content into Digital Talking Books. The importance of this to the blind community cannot be overstated. At present, the blind community is in large part separated from their "literary culture".

Using digital technology, what contribution will you make to achieving sustainable growth as a nation?

The Foundation’s Employment Services are helping blind, deafblind and vision-impaired members enter the workforce or maintain their jobs despite vision loss. Digital technology will provide additional ways and means of supporting members into employment.

The link between technology and employment is obvious today, and it will be more critical in the future. Employment is of enormous importance to the RNZFB and its members. Despite record levels of employment in New Zealand, the unemployment rate for working age RNZFB members is staggering.

 “The Cost of Blindness in New Zealand”, published in March 2006 by the Royal New Zealand Foundation of the Blind, analyses data on unemployment in the blind community:

 “The impact of blindness and vision impairment on employment and economic status has been widely examined. La Grow (2003) in a review of overseas studies notes that employment rates for this group are typically low worldwide, estimating only 25-30% of working age blind and vision impaired persons in developed countries to be meaningfully employed…

 … A study by the European Blind Union (EBU, 2001) reports an average of 60% unemployment amongst blind and vision impaired people in European countries. Particularly high rates of unemployment are reported for Poland (87%), Hungary (77%), Germany (72%), Denmark (69%) and Norway (98%). A recent American study showed that persons 'blind in both eyes' had lower economic status than those with less severe vision impairment and those with hearing impairments. Economic status was, however, similar to those reporting other serious impairments such as paraplegia, hemiplegia, quadriplegia and mental retardation (Houtenville, 2003).

Findings from the 2001 New Zealand Disability Survey show a relatively higher level of economic and employment disadvantage experienced by those blind and vision impaired compared to other disability types. Compared to other disabilities, the survey shows those with a seeing disability to have the lowest level of employment and greatest likelihood of not being in the labour force (refer to Table 12).”[7]

The RNZFB’s vision is that blind and vision-impaired people have the same opportunities and choices as other citizens to participate fully in society. Our mission is to remove the barriers (including those related to technology) that inhibit independence of blind and vision-impaired individuals, and to promote their participation in all aspects of life.

The Foundation urges Government to ensure that technology is used to remove the obstacles that prevent blind, deafblind and vision-impaired people from securing meaningful employment. The Foundation’s Employment and Adaptive Technology services help members learn new skills and, if they desire, transition into higher education or into employment. Government support of these initiatives would be a logical and concrete step to reduce the unacceptably high unemployment rate of blind, deafblind and vision-impaired people.

What contribution do you think others need to make to achieve our digital potential?

Every agency, organisation and business should commit to accessibility and equitable access to digital technology and content.

OTHER COMMENTS

Do you have any further suggestions or comments?

In the built environment, when you “get it right” for blind people, everyone benefits through easier and safer access.

The Reserve Bank ensured that the needs of blind people were considered when it created and distributed new coins in 2006. As a result, all kiwis have benefited. The size and texture of the coins allow people to identify the coins in the dark, or while in their pocket, simply by touch.

If the needs of those in the blind community are considered from the outset – in all things digital - everyone will benefit.

New Zealand has much to be proud of in the area of disability. New Zealand won the prestigious Franklin Delano Roosevelt International Disability Award for 2007. The award recognises the work done by the Labour-led government and the disability sector in developing and implementing the New Zealand Disability Strategy.

New Zealand also won this award for its achievements in shaping and negotiating the intent of the United Nations Convention on the Rights of Persons with Disabilities over a number of years.

Internationally, New Zealand is seen as a clear leader in disability. Getting the Digital Strategy right for blind, deafblind and vision-impaired people will help ensure that everyone benefits, and that New Zealand continues to show leadership on the world stage.

Background on the Royal New Zealand Foundation of the Blind.

RNZFB is a disability support service constituted under the Royal New Zealand Foundation of the Blind Act 2002. The Foundation is the primary provider of vision-related habilitation and rehabilitation services to approximately 11,700 blind, deafblind and vision-impaired New Zealanders.

 
Half of our members are over age 80. Two-thirds are over age 65. Their ability to easily access information and to enjoy the benefits of technology are prime concerns of the Foundation. Accessibility is directly related to independence, community involvement, education, employment and, in reality, normal daily life in the 21^st Century.

 
While this submission is made on behalf of our approximately 11,700 members, we note that more than 90,000 people self-identified in the New Zealand Disability Survey undertaken in 2001 by Statistics New Zealand as having a vision impairment that cannot be corrected by glasses. Therefore the Government should understand that “getting it right” for blind, deafblind and vision-impaired people would likely mean that it got it right for these other 90,000 people. This number will only increase as New Zealand’s population is ageing, and Baby Boomers will soon be entering ages which commonly experience higher levels of vision impairment. Bridging the digital divide that separates the blind community from the printed word is absolutely essential. Getting the Digital Strategy right will be a significant step in the right direction - the direction of equity.

For more information about this submission, contact:

Mary Schnackenberg, Divisional Manager Adaptive Support

Royal New Zealand Foundation of the Blind

Private Bag 99941, Newmarket, Auckland

+64 9 355 6929

mschnackenberg@rnzfb.org.nz