Site navigation

Change font size: SmallerLargerReload

navigation Disability Rights

Progress update on reference: access to electronic commerce and new information and service technologies for older Australians and people with a disability


Human Rights and Equal Opportunity Commission, 1 December 1999
 
 

International Year of Older Persons 1999

Contents

1. Summary: great potential but significant barriers to address
1.1 Barriers
1.2 Recommended solutions
1.3 Further course of this inquiry
2. Issues identified by the Commission's issues paper
3. Initiatives to extend access to new technologies
4. Education, awareness and training
5. Indirect access and alternatives to automated and on line services
6. Accessibility of technologies used
6.1 Interactive voice response systems
6.2 Automatic teller machines
6.3 Working paper on web accessibility
7. Legal issues
8. Appendix: notes on inquiry process to date
8.1 Reference
8.2 Focus group discussions
8.3 Access to submissions and research resources
8.4 Publicity for inquiry process

Attachment: Executive summary of focus group discussions
 

1. Summary: Great potential but significant barriers to address

"It's very important. It enables people to live independent lives in the community. We want to be independent. We want to be seen to be independent. When it works it's liberating.": Comment in focus group discussion

"Older people are at risk of being excluded from the choice of participating in this vision. Largely because they are out of decision making loop and increasingly are not represented in workplaces where mostly young technically literate people are becoming familiarised with technology as an integral part of their vocational training and career development. ... Without strategic intervention, a low level of computer literacy and the social effects of groupings into the information poor and the information rich is likely to compound negative stereotypes of older people held by the young who in turn are further re-inforcing their advantage through the encapsulation of their values and assumptions in technology itself. The rapid disenfranchisement of hearing impaired people by IVR and telephony queuing and menuing systems is an example." : Individual submission

The Attorney-General has asked the Human Rights and Equal Opportunity Commission to investigate the implications for older Australians and Australians with a disability of new technologies in electronic commerce and the provision of government and other services, and outline their needs in accessing services which use these technologies, and to report by 31 March 2000.

This update on progress with the reference outlines issues raised in submissions, research, community focus group discussions and other consultation so far. It follows from an Issues Paper released by the Commission on 13 September (available on the Commission's web site and in other formats on request).

Evidence obtained so far suggests that

Many access issues are common between older Australians and people with disabilities, including accessibility of automatic teller machines, interactive voice response systems, and internet based services. The proportion of people with a disability affecting access to information and services rises substantially in older age groups.
 

1.1 Barriers


Barriers identified include:

1.2 Recommended solutions

Submissions and research so far have supported measures including:

1.3 Further course of this inquiry


Prior to conclusion of this reference on 31 March 2000 the Commission will

2. Issues identified by the Commission's Issues Paper


Focus group discussions, and submissions and research resources received and published by the Commission to date

The Commission's Issues Paper discusses and seeks comments on different types of access barriers, and options and best practice in different types of solutions, including Comments and further information received so far on these barriers and means of addressing them are outlined in this update.

The Commission's Issues Paper discusses and seeks comment on issues affecting equal access through a range of technologies, including

At this interim stage, issues of web accessibility, in particular regarding Commonwealth government sites, have been dealt with by the Commission in most detail.

A Working Paper on web access issues with particular reference to accessibility of Commonwealth Government web sites is being made available at the same time as this update to assist informed discussion. This working paper will be revised as further information is received and consultation conducted throughout this reference. Papers on several other technologies will follow shortly.

The Issues Paper discusses and seeks comments on issues affecting equal access in a number of areas of information and services, including banking and financial services; other business services (such as retailing and travel services); government information and services and participation in government processes; and education.

Of these areas, the Commission has already made good progress in research and consultation, and received important submissions, regarding banking and regarding government information and services. Less information has been received to date on issues in education. This area will be given more attention in the next phase of the reference.
 

3. Initiatives to extend access to new technologies

People with disabilities and older Australians alike have identified affordability and access to equipment as major barriers in gaining access to, familiarity with, and confidence in using, services through the internet.

Submissions have

Submissions have welcomed and called for expansion of government initiatives, through programs such as the Commonwealth's Networking the Nation grants program and Victoria's SkillsNet, to provide community access points to internet services through libraries and community organisations. A number of submissions and papers recommend more support by governments and business for community organisations providing access to equipment, training and on line services. Some of these are quoted here. "Contrary to popular belief, seniors do embrace new technologies. ... Cost is still a barrier to take-up of technology even though PCs are getting cheaper. Poor after-sales service plus service and repair costs are real disincentives. Most older Australians are on a low income and receive a full or part age pension (81% of women and 65% of men over 65). There must be access for those who cannot afford home based PCs and online charges. Community based access points such as public libraries, older people's organisations, community centres and government information outlets have further potential; other suggestions have been educational institutions, on-line kiosks in shopping centres (trialing in Victoria), and post offices with Net access stations like public phones. There is certainly scope for improving access to the Net by recycling computers ... Government and companies should be encouraged to set up partnerships with older people and their organisations to obtain superseded equipment, to loan equipment and subsidise installation and training." : Helen Scott, Council on the Ageing, Australia, "Information and older people - present and future".

 "Possible solutions to the problems of availability of equipment could include:

"Many older Australians and people with a disability find it hard to afford to buy a computer. New Computer Clubs for Seniors also have difficulty affording the necessary hardware to set up their club. Some Government Departments and corporate organisations dump their old computers. Recommendation:Government Departments and Corporate bodies be encouraged to give their old computers, printers and related hardware to an organisation such as ASCCA, directly or through an organisation such as Technical Aids for the Disabled, to allow them to be distributed to older people or those with a disability who cannot afford to purchase such technology for themselves, or to computer clubs for seniors for the purpose of teaching older Australians or those with a disability how to use them." : Submission, Australian Seniors Computer Clubs Association.Information on the model of provision of equipment and services through Technical Aid to the Disabled is available through the resources page for the reference. This service appears to have the advantage of being able to address needs which some submission have emphasised for some users with disabilities to have adaptive software and/or equipment before they can use a computer effectively.

Technical Aid to the Disabled publishes lists of donors to its Computer Loan Scheme regularly in its journal. There appears to have been limited contribution from government departments and agencies to date.

The Commission understands that there is no fundamental barrier to donation of public resources if the agency responsible is satisfied that this represents appropriate value for the public resources involved.

This may occur if resources should properly be written off – which is likely to apply to many superseded computers which are capable of being restored by community organisations for useful service, but would cost more to dispose of commercially than they are worth to the Commonwealth. Computers that many Commonwealth departments and agencies may dispose of as superseded – high range 486s and lower range Pentiums – appear to be capable of performing an important role in providing at least introductory access to online services for older Australians and people with a disability.

The Commission understands that options for streamlining or encouraging this process have received some discussion within government and intends to pursue this issue further during this reference.

An alternative path may be to consider provision of equipment for community access not because computers are redundant to public purposes, but explicitly as a means of achieving them.

Some banks are now moving towards, or are already introducing, provision of free internet service for their customers. Where other education and awareness activities by the banking industry may result in part from perceptions by providers and the community of social responsibilities, these services appear to be based on purely commercial decisions reflecting reduced costs and improved ability to reach consumers with products in on line environment.

Providers of government services and information, particularly large scale providers, might consider whether they should be taking similar or further measures in the interests of more effective and efficient delivery, in particular regarding otherwise expensive and difficult to reach customers. Centrelink's submission notes that it is already "working to deploy Internet PCs in agent premises in order to improve technology access to all customer segments".

As far as the Commission is aware these initiatives have not yet extended to providing computer equipment for access at home or in community facilities.

Recent analysis of the economics of the internet as a network suggests that even competitive markets will provide less access to networks with positive externailities for increased participation levels than is economically optimal. (N.Economides, The Economics of Networks, International Journal of Industrial Organisation, October 1996; available on line at http://www.stern.nyu.edu/networks/top.html .) Even before any additional value is considered for equity or social participation for its own sake, this is one of the reasons accepted by economists for government intervention to provide services.

Available models of government intervention include direct provision or funding of services, but are not restricted to these.

A long established model of partnership between government, business and community organisations for social goals and redressing disadvantage is through the tax system conferring deductible status on donations in cash or kind to socially beneficial projects.

Information on the Technical Aid to the Disabled computer loan scheme indicates that deductible status is recognised for this scheme. The Commission will be seeking to clarify the basis of reported ineligibility of a service providing PCs and internet access to people with a disability on the basis that internet access services were being provided rather than equipment only, and whether this report (http://www.it.fairfax.com.au/networking/19991102/A15861-1999Oct30.html ) (if accurate) indicates a need for more effective provision of information to community organisations in this area on attaining deductible status, or a need for revision of applicable tax rules or rulings.

4. Education, awareness and training

"If governments (or non-government organisations for that matter) plan to deliver most services via the Internet they must provide training in the middle and older generations to embrace this technology." (Helen Scott)

" ... the government's obvious and cheapest solution to change the computer shy to the computer confident is to utilise existing non-workplace oriented voluntary organisations such as Australian Senior's Computer Clubs Association and the University of the Third Age. For minimal administrative and equipment input funding a nationwide training program could be simply and quickly setup and made to function. This form of peer helping peer is the only friendly solution" : Individual submission

"A major issue for people who are unfamiliar with technology is the provision of opportunities to learn about the technology. Therefore, access to computers and other technology is required in areas that older Australians or people with disabilities can get to, where they feel supported and comfortable, and where they have others around them to ask for assistance - such as local government facilities, senior citizens clubs, or support organisations for people with disabilities, accommodation sites or centres for older Australians or people with disabilities. Government surplus computers and related devices would make it cheaper to set up access points in these places." : Centrelink submission.

Submissions emphasise needs for education and training in addition to measures to ensure access to equipment.

The submission from the Department of Family and Community Services notes that options for addressing education and training barriers for people with disabilities and carers might include:

Submissions on behalf of members of the banking industry Centrelink's submission also notes that it has been co-operating with the Australian Bankers Association to provide training to customers on on line and automated services.

Submissions appear to identify several models worth considering for increased support from government and business.
 

5. Indirect access and alternatives to automated and on line services

"No matter what governments and providers of on-line and e-commerce services do, it is inevitable that some people will not be able to access these services. To ensure that people are not deprived of critical information or vital services, there must always be alternative methods of accessing the service or information that are readily available and clearly advertised." : SubmissionGovernment and some industry sectors have expressed commitment to maintaining more traditional channels of delivery of information and services alongside electronic options. The Commission's Issues Paper noted the Prime Minister's Investing for Growth statement which, while committing the Commonwealth to delivery of all appropriate services on line by 2001, indicated that this should complement and enhance rather than replacing existing services.

Submissions emphasise the importance of such a commitment, although it is fair to say that some question whether it is being effectively met at present in all cases by governments and businesses.

The Government Information Centre pilot program, referred to among initiatives listed in the Commission's Issues Paper, was regarded in submissions as a very positive step which ought to be expanded. This program is intended to provide members of the public with a human contact point, who then uses digital data to negotiate a way to the information or services required without the user necessarily having to master all the technologies used or the structure of the government organisations and resources involved.

Use of electronic technology including web based data to enable staff to provide services to customers more conveniently, effectively and conveniently may not have the profile currently attained by direct provision of services on line. At least pending more widespread accessibility of and familiarity with self service models, however, this and similar intermediate models of delivery of information and services could perform an important part in delivering the stated goals of government and some industry sectors of using digital technology to enhance service and accessibility rather than only to reduce costs.
 

6. Accessibility of technologies used

"Quite simply, we build disability into technology": SubmissionFor many people with a disability, and for some older people, the major issue is seen less as one of lack of their own awareness of e-commerce and other service, than a frequent lack of awareness of community access needs in designing and implementing services and technologies.

Problems of accessibility of equipment and of information formats have been identified across most electronic commerce and service technologies. They are well captured in individual comments published in the summary report of focus group discussions, and discussed in detail in the Blind Citizens Australia report on Accessible E-commerce in Australia as well as other submissions and resources available through the web pages for this reference.

Barriers regarding particular technologies, and some current and recommended initiatives and strategies to address them, are detailed further in research resources linked from the pages for this reference on the Commission's web site. They will be discussed by the Commission in a series of papers to be issued throughout this reference.

Useful findings have been more quickly achievable regarding web page accessibility than other technologies:

A reasonable "first cut" at checking accessibility of web sites is achievable quickly and at virtually no cost (at least for organisations having access to up to date computers and internet connections), using the "Bobby" automated checking program.

Surveying accessibility of automatic teller machines, EFTPOS facilities and similar devices, and of "interactive voice response" systems requires more extensive processes of research and consultation, which have commenced and which will have outcomes reported by the Commission and by other parties involved as this reference progresses.

The Commission has more of its own experience to draw on regarding web accessibility than other technologies. By contrast the Commission has relatively limited direct expertise in providing interactive voice response systems, and no direct experience of providing its services through kiosks, ATMs and similar devices (although it has dealt with a number of complaints under the Disability Discrimination Act concerning accessibility of these devices).

In the web accessibility area there are fairly comprehensive, freely available and reasonably widely accepted (though less widely implemented) standards to refer to : the World Wide Web Consortium's guidelines for web sites generally, and for Commonwealth Government sites Ausinfo's guidelines which reference the World Wide Web Consortium's guidelines and the Commission's advisory notes.

There are Australian Standards for automatic teller machines and for interactive voice systems, which address some accessibility issues, but the Commission is not in a position at this stage to use these or other standards applying to these issues as definitive benchmarks.
 

6.1 Interactive voice response systems

The importance of access issues in this area is emphasised by findings reported by the Rural Development, Centre, University of New England: In a series of focus groups with different sectors we held in four small communities a couple of years ago in every group whether it was a group of business people, older people, farmers etc, issues relating to call centres and automated answering systems were raised. Points included:
 

1. These systems presume a level of knowledge and skills that is usually just not out there in small communities.
2.'Efficiency' is only measured in savings to the provider - not to the person making the call who can be put on hold for extended periods, or who simply does not receive the service they require as they give up in the face of a complex system.
3. Older people, particularly those with poor literacy, become increasingly dependent on others to act as an intermediary in seeking information or services as they cannot deal with the technology. This has important implications for well-being, self-esteem and power relationships and can leave some older people vulnerable to exploitation.
4. Systems which put pressure on the operator to deal with calls in short time periods fail to take into account the needs of many older people: Ros Foskey, comment in Making the Connections online conference forum, http://www.mtc.une.edu.au/ .

Submissions and research materials which address the issue indicate that the Australian Standard on IVR systems could, if more widely implemented, improve accessibility and usability of these systems to address some of the concerns and criticisms raised: All automated telephone services in Australia should be compliant with the Australian and New Zealand standard (AS/NZS 4263) which deals with user interface requirements for interactive voice response services. In preparing this standard, consideration was given to the needs of elderly and users with physical disabilities, including allowing longer waiting times for responses to questions, consistency of frequently used commands etc.: Noonan, Accessible e-commerce in Australia

Centrelink observes the Australian Standard for the use of IVRs and this includes the facility for customers to always have the option of speaking to a human operator or to default to an operator if they do not make a menu selection. Automated services follow the same principle although, outside of normal business hours this feature may not be available and customers may be asked to call again during business hours when a human operator will be available or leave a message (phone number, name, etc.) for a later call back. It is also important to note that there are no IVR prompts that require a caller to respond within a particular time period, so that customers with disabilities that may result in slower response times, are not disadvantaged.: submission, Centrelink.

An issue of possible concern is whether availability of private, voluntary standards for purchase (in paper form or in PDF format on the web) under the existing Australian Standards model is sufficient to ensure access to information on applicable standards for providers of IVR systems and other interested parties. Comments would be welcome on this issue.
 

6.2 Automatic teller machines


The Australian Standard on automatic teller machines deals principally with issues of physical access to machines (accessible location and reach to controls), rather than with the full range of issues affecting accessibility and use raised in focus group discussions, submissions and research resources for this reference, such as the proposed standards currently before the US Access Board. One submission notes that this standard is currently under revision.

The Commission has commenced a small sample survey of accessibility of ATMs and has been discussing access initiatives, including in relation to ATMs, with a number of banks.

The Australian Bankers' Association submission acknowledges barriers experienced by people with disabilities regarding ATMs but notes progressive upgrading of ATMs with more accessible new generation equipment incorporating audio, touch-screen and other aids now appearing.

The Commission and/or the institutions concerned may be in a position shortly to say more about initiatives in this area.
 

6.3 Working paper on web page accessibility


As part of this reference the Attorney-General asked the Commission to conduct an audit of the accessibility of Australian government and business internet sites, in particular for people with impaired vision, by reference to the Disability Discrimination Act and relevant Australian and international guidelines.

A working paper discussing results of a preliminary audit focusing on Commonwealth web pages has been released with this update.

The summary results from this preliminary survey are that :

Findings on accessibility of other pages will be published after further discussions with service and information providers.
 

7. Legal issues

The Commission's Issues Paper asked for comment on legal barriers to reproduction or distribution of material in accessible formats, and in particular on the impact of recent and current reforms to copyright law and through legislation on electronic transactions.

It is encouraging to note that the Electronic Transactions Bill was passed on 25 November.

Regarding copyright issues, submissions

Submissions in the education area express concern regarding current time delays involved in working through copyright issues, and arranging for reproduction of materials in an alternative format, which place students with a disability at a disadvantage.

The Royal Victorian Institute for the Blind notes that transcription into audio or Braille of an average 200-page book currently takes six to eight weeks, and suggests that to reduce delays publishers should lodge electronic files of their publications with a central agency or agencies, with appropriate controls on eligibility for access.

The Commission will seek to explore issues in this area further in the course of this reference.
 

8. Appendix: Notes on inquiry process to date

8.1 Reference

By reference dated 26 August 1999 the Attorney-General asked the Human Rights and Equal Opportunity Commission to The reference states that the term electronic commerce should be interpreted broadly and should include electronic services such as banking.

In conducting this reference the Commission was asked to

The Attorney-General launched the reference on 13 September at a public event in Perth with the Commission's President, Professor Alice Tay.

The Commission released an Issues Paper the same day (based on initial research in response to the Attorney's reference and on its own previous work in this area), as a basis for consultation with interested parties in business, government and the community. This paper is available on the Commission's web site.

The Issues Paper has also been offered in paper and other alternative (non-electronic) formats. To date, on line demand (over 750 hits on the web version, plus some email distribution) has far outstripped demand for paper distribution (less than 100). (This is not unique or solely attributable to the subject matter of this reference, being consistent with recent Commission experience with relative demand for electronic and paper formats of other major publications such as the report of the reference on pregnancy discrimination.) No requests for other formats have been received to date.

Experience in conduct of this inquiry to date illustrates, in a small way, the potential gains in efficiency, effectiveness, reach and participation which is offered to Australia's governments and people, economy and society by use of the internet and other digital technology – if issues of universal access to these technologies are addressed.
 

8.2 Focus group discussions

A series of focus group discussions involving older people and people with a disability was conducted at the commencement of this process, as a means of testing and supplementing the information available through other research and submissions. The Commission thanks the Attorney-General's Department for providing financial assistance to make these discussions possible. Focus groups were organised and led by an expert consultant in this area, who for commercial reasons has asked not to be identified at this interim stage.

A summary report to the Commission of input from focus group discussions was made publicly available on the web page for this reference on 26 November and is included with non on-line versions of this update.

As noted in the summary report, these discussions do not represent a statistically significant sampling process, being based on qualitative rather than quantitative research techniques. Subject to this, the results of focus group discussions offer confirmation that the issues identified in the Commission's Issues Paper, regarding both benefits and barriers in access to electronic commerce and new information and service delivery technologies, are real issues for older Australians and for people with a disability.

Focus group discussions indicate that physical barriers, affordability and equipment access barriers, and attitudinal and awareness barriers prevent some older Australians from accessing e-commerce. Where these barriers are overcome users see electronic banking in particular as cheaper, faster and easier.

Perceptions of problems of security, of personal safety using ATMs and of personal information using internet services were also raised.

Focus group discussions with people with disabilities did not indicate the same problems of awareness of electronic commerce options. The groups were extremely knowledgeable about e-commerce options and could talk at length about transacting business over the net, ATMs, EFTPOS, smart cards, ticketing machines, barcode scanning in supermarkets and libraries, e-tickets and voice technologies.

However, accessibility of equipment and of information formats across most electronic commerce technologies, and affordability and equipment access barriers were problems for these groups.

A major point arising from focus group discussions, as well as from research and submissions so far, is that many access issues are in fact, and need to be addressed as, universal access issues rather than issues to be approached (or overlooked) only as minority issues.

Submissions have emphasised that the Australian community as it really exists is not composed even mainly of urban upper income people who have access to and are familiar with up to date technology, are aged 18 to 40, and will never age, and have perfect eyesight, hearing, mobility, and memory, and will never experience any disability affecting any of these, and have high level analytical and English literacy and language skills.

The issues identified in this reference so far are likely to affect people who might not regard themselves or be identified with any special needs group.

It has been striking the number of times that issues with which we were familiar as disability access issues have been raised as issues affecting older people or members of communities more generally.

It may then be asked, why should an examination be conducted or continued focused on older Australians and people with a disability rather than simply examine issues of effective access more generally, or with reference to other possible categories of disadvantage, such as low income people and people in rural and remote areas.

One answer is that the Commission has clear jurisdiction, under its present statutory mandate, to examine and report on disability access issues and that (although Federal age discrimination legislation has not yet been introduced and remains under discussion) issues for older people in this area are closely related. It is less clear that the Commission would have legal authority to expend resources examining, or to report on, issues regarding technology and social disadvantage more generally or income level or location.

Another answer is that this examination does not exclude other examinations targeted in different ways, and that evidence indicates that an examination in accordance with the current terms of reference focusing on older Australians and people with a disability is necessary and timely.
 

8.3 Access to submissions and research resources

A resources page providing links to relevant on line information from business, community, government and other sources, and a page providing access to submissions made in electronic form, have been published on the Commission's web site.

Much important material has been provided in submissions and research resources. In particular it is appropriate to note the material prepared by Ms Helen Scott for the Council on the Ageing, and the extremely valuable report prepared by Mr Tim Noonan for Blind Citizens Australia on "Accessible E-commerce in Australia", funded by the Minister for Communications Information Technology and the Arts' AccessAbility program and released in September 1999, in which "a variety of day-to-day activities are examined from an E-Commerce and accessibility perspective including:

The Commission understands that this report will be supplemented by further information from Blind Citizens Australia in the near future, including information from this organisation's research on smart cards.

In most cases submissions and resources have been provided electronically and the Commission has accordingly been able to provide public access to them by publishing or linking to them on the pages for this reference on its internet site (which would be quite beyond the Commission's capacity in paper or other forms).

Submissions and links to research resources will continue to be posted to the Commission' s site as they are received throughout this reference so that interested parties may have direct access to them rather than having to wait for summary versions in a later final report.
 

8.4 Publicity for inquiry process

The inquiry has been publicised by Indications are that radio announcements (providing a phone contact point), and provision of email contact details through the press resulted in limited contacts or requests for further information, compared to email and other notification of on line availability of information. This in itself may be seen as evidence of the importance already achieved by the internet for information and communications in Australian government processes - and the importance, therefore, of ensuring equal and effective access.

Attachment: Executive summary of focus group discussions