Centre for Internet and Society

Comments on Mobile Accessibility Guidelines

nirmita — 2018-01-03T02:37:10Z

The Centre for Internet & Society (CIS) submitted its comments on mobile accessibility guidelines to the Ministry of Electronics & IT, Govt. of India.

Consolidated comments on mobile application guidelines:

Overall, this document is very difficult to review and comprehend. It needs to be more structured. If the mobile accessibility practices had provided earlier can be directly adopted that adds more value
Avoid adopting WCAG POUR structure. If it is used use it wisely.
Certain checkpoints do not have appropriate headings. E.g. D, E, G, H must be under perceivable but currently are under Operable. Similarly, I must be under Understandable but currently under Operable.
Some checkpoints are difficult to understand. E.g. Grouping operable elements that perform the same action.
Provide WCAG 2.0 reference with techniques and tools to test wherever appropriate
If any of the checkpoints are differentiated as Mandatory, advisory and voluntary specifically mention them against each checkpoint.
Section specific comments:

In section 1.A, The requirement that since screen size is small we should only use native applications does not make sense.
Section 2.d, 2.e, 2.g and 2.i should go in first section i.e. perceivable.
Section 2.F suggests that buttons should be placed where they are easy to access. But there is no criteria to decide what is easy to access? For example, in iOS, back button is at top left and often important buttons such as end call, ok etc. are placed at the bottom of the screen. Similarly, there are conventions for Android. Please check Android conventions and refer to the same in this document. We could require that app developers should follow conventions for the platform that they are building for
Section 3.a would go in part 2 i.e. operability
Section 4.a and 4.b would go in operability.
Section 4d onwards do not belong in robust, they should be in additional section
Include Mobile Practice 10 from Mobile practices v1.0 that deals with custom actions. Custom actions behave like context menus and help screen reader users.
We also recommend that Mobile Practice 2,3,4 and 5 from Mobile practices v1.0 could be included under principle 4 i.e. robust.

A lot of reflection and deliberations happened during development of Mobile Practices so taking those practices would improve the guidelines. For example, practice 2 has a lot more details about why it is important and how to add labels.

Download the full submission here

For more details visit https://cis-india.org/accessibility/blog/cis-comments-on-mobile-accessibility-guidelines

IDAP Interview Series: Interview with Nirmita Narasimhan

nirmita — 2017-11-26T09:56:06Z

IDIA Disability Access Programme did an interview with Nirmita Narasimhan. This interview was conducted by Madhavi Singh and Anusha Reddy. The interview was transcribed by Veda Singh, IDIA intern and student at Jindal Global Law School.

Read the original published by IDIA Law here

Our interview in this series features Nirmita Narasimhan, a Policy Director with the Centre for Internet and Society. Nirmita did her LL.B. from Campus Law Centre, Delhi University in 2002. She also holds a Bachelor’s degree in German and a Ph.D. in Music. As a part of CIS she has done extensive work on web accessibility and was involved in drafting the Indian National Policy on Universal Electronic Accessibility. She has worked closely with different departments of the Government of India to bring accessibility into their policies and programmes.

In recognition of her path-breaking work in the field of digital accessibility, she has received numerous awards such as the National Award for Empowerment of Persons with Disabilities (2010), the NIVH (National Institute for the Visually Handicapped) Excellence Award (2011) and the NCPEDP-Emphasis Universal Design award in 2016. She played a key role in amending the Indian Copyright Act to incorporate exceptions for people with print disabilities and launched the widely acclaimed nationwide Right to Read campaigns.

Nirmita’s experience is not just limited to policy work – she is a widely published author and has assisted national and international bodies in the creation of several reports on promoting accessibility rights of people with disabilities.

This interview was conducted by Madhavi Singh and Anusha Reddy. The interview was transcribed by Veda Singh, IDIA intern and student at Jindal Global Law School. The interview has been lightly edited for clarity.

Could you please describe to us the exact nature of your disability?

I have something called Stargardt disease. For me it came when I was 9 or so. When I started, I could read with the help of a magnifying glass and I would enlarge things to read and now I completely rely on screen reading software.

Could you please describe to us the reasonable accommodation provided by your school and college, if any?

In school nothing! I used to read and write using a magnifying glass –reading was a bit of a struggle. My handwriting was really bad and people didn’t understand it. I never asked for anything. Only for my Board exams I had asked for a writer because that’s something you really can’t risk.

Most schools use boards to teach. How did you manage?

No, it just depended on the individual teacher and maybe I was also very inhibited at that time in my life. I wouldn’t go up to the teacher and simply say “please read it out.” Consequently, I always regretted that I was not good at math, because it was always on the board. I managed back then with the help of my parents and sister.

You have a large number of educational qualifications to your name. You initially studied German and Carnatic music and only pursued law later. What factors influenced you in deciding to study law?

It may not be anything glamourous as really being passionate about it. But going back to German – I really liked the language, and more so due to the teaching methods because this was the first time I was out of a classroom setting into a setting where there were 10-12 students and the teachers were really good and used unconventional methods. They were accommodative about exams. The teacher could write exams for me or tell me what to do – it was not like a fixed system. Whenever a system came into play, inaccessibility also came into play. Whenever it was an individual, and usually somebody who was not heartless, it was pretty okay.

One time in an exam, they gave a printout, and I couldn’t read it. At that time, I wrote the one answer I could, left the rest of the question, gave the paper and walked out. When the results were declared, I got an A or A+! I was shocked. I went to the teacher and said “How can you do this to me?” He said “I know that had you been able to read it, you would’ve written because I see you every day in class. That was probably wrong of us and we should have ensured that you could’ve read the paper.” I think that was a unique experience. It happens to very few people and it certainly never happens very often in one’s lifetime, unless you’re extraordinarily lucky. But these kinds of experiences during my graduation really helped get a better sense of the world.

After that I started my M.A. When you’re trying to do translation you keep referring to a dictionary. Until my M.A., I used to keep enlarging a basic dictionary into such thick volumes that I couldn’t even carry them. I realised that this couldn’t go on all my life and beyond a point I could not expect my father or mother to read out, because they did not know German and would not always be with me. So, I thought that this is not going to work out and at that time I gave the law entrance exam.

As for music, I did my diploma while I was doing my B.A. I didn’t consciously take up music immediately after my B.A. because people thought that was the obvious career for me since I had a visual disability and that really irritated me. After having finished my law, somewhere along the way I thought that so what if music is the expected career for someone who is visually impaired, it’s just something I wanted to do.

My main motive was actually not to fall into things which people expect are easy. When I was joining law many people said “You shouldn’t join law, you won’t be able to refer to anything.” I got so annoyed and would say – “Listen it’s my life, if I’m going to live for 85 years and if I waste one year in between, I have no problems. So why does it bother you? I don’t mind failure, but at least let me try. If I can’t, I’ll leave it and go back to sociology or some other subjects.” So, that’s why I got into law, and I have no regrets. It was tough for multiple reasons.

Out of all your diverse educational courses (law, Carnatic music and German) with their varied teaching methodology and course work which field do you think was the most exclusionary of people with disabilities and which one was the most accommodative?

I think it depends on the institution. It’s not fair to compare Delhi University with JNU. JNU was more open and the teachers were creative in the ways they taught, recognising individual abilities. It was completely different from DU which had approximately 80 people in a class and typically the lecturer came, gave a lecture and left. I had a good experience in JNU, because it was not bound by systems and is generally a good place to study.

The Faculty for Music and Fine Arts at DU was also very accommodative, especially so because my Guru ensured that I got what I needed. However I found studying law to be really difficult – at that time I didn’t have any books. If I would go to the library, each and every book you pick up would be underlined with a pen. If you try to scan it – at that time the technology was very slow but even if I was ready to do that, if something is underlined the scan is obsolete. How much can one human being read out to you – a constitutional law book is of 300-1000 pages? You have to refer to so many books!

So, I couldn’t read any book, I didn’t know where to start. Then I was actually forced to rely on these dukkhis. I think the main reason they were useful is that they weren’t underlined, I could purchase them, tear them and scan them. By that time I had also been introduced to computers, and had bought an OCR having paid $1000 for it at that time. Even after that since the paper quality was not good I couldn’t read much.

I know this is probably an awful thing to say, and though I would’ve loved to have a more nuanced understanding of the law but it required me to read a lot which I was unable to do – not because I didn’t want to but because I just couldn’t.

You were an exceptional student – topper of your batch and a gold medalist. To what extent was your hunger for success fueled by your desire to demonstrate your capabilities and to not let your vision impairment become your defining characteristic?

Is my success driven by my desire to show the world? No. Even when I did law– forget showing other people, I just needed to do something “normal” or something that other people were doing – something that is a profession, that’s it. Everything else I did was not to prove anything. After a point, I didn’t really think much about having a disability it’s just a part of who you are. I just wanted to study well.

You have worked in the field of policy research, as a lawyer in a corporate law firm as well as in advocacy, how do you think these professions are different in terms of the obstacles they pose to lawyers with disabilities? Have there been any reasonable accommodation?

Policy research is my current work. The fact that I am currently using technology and my office is pro-accessibility shows that reasonable accommodation is provided here. I tried both courts and corporate law, they were never areas I wanted to be in permanently but I thought having studied law I should have some kind of exposure. At that point of time there were a number of documents, annexures, etc. and to file them you could always hire somebody, but it wasn’t something you could have done for yourself– this was around 2002. And in the corporate field, what I found difficult was working with track changes and deadlines. I was not very excited by the work to stick it out and really prove a point. I know some people that did. I think you need to be motivated enough to tackle the issue, I was not motivated enough by the people to conquer these issues and it didn’t excite me.

You started your career in law with Mr. Rungta. Could you kindly let us know your reasons for choosing to work for a blind lawyer?

I wanted to know how he worked. If you mean whether it was difficult getting into other law firms, yes it was. I did try to ask people in firms but they were completely not open to having me. One or two said that we could have a trial – without pay however, to which I asked if they were paying other juniors, and if so then I didn’t want to join. I worked with Mr. Rungta for a few months and then moved on.

This is a problem most students face wherein employers are apprehensive of hiring people with disabilities, so what advice would you give especially to the corporate field?

I think it is a really negative attitude – people see what you cannot do and not what you can do. And at some point everyone has certain skills, and you as an employer need to be discerning– it shows how smart you are whether you can identify how to tap into that person’s skill or not.

It’s not the time for people to be telling them what they cannot do. The students already know that tasks are difficult for them – they don’t need to hear it from their employers too. So, I think there is a huge issue there. It’s for them to figure out and work with the person to see how to make it happen. It can happen! It might not be exactly the same thing that you envisaged but something can be worked out.

I never came across an employer who was willing to do this. Believe me, I’ve gone from door to door after I finished my law degree and it was a very demotivating time. I feel that it is sad especially now with the kind of technology we have. Maybe at that time I could agree and understand their concerns that I wouldn’t be able to look up case law, but things are different now. Another problem is that the student does not know the range of the work there is, hence it becomes difficult to articulate what he/she wants/can do. I think it is important, even for institutions to ensure that they help place their students, in some of these big law firms, starting from internships.

If you had to tell employers why they should hire people with disability, what would it be?

Do not judge a person merely by virtue of whether he/ she has a disability. Be fair and give them a chance as well. There are many people who became great, just because they got a break. There is great value in making your work place more inclusive and diverse. One can evolve work arounds for most issues and technology has made many things possible.

As a Policy Director with the Centre for Internet and Society, you have done extensive work on web accessibility for persons with disabilities. Given that technology has been an enabler for persons with disabilities, do you believe that the government and society (technologists/businesses/start-ups) have a responsibility to design keeping accessibility in mind from the very beginning?

Definitely, there are no two ways about it. They should, but they aren’t doing it. The first policy on accessibility was in 2009 by the NIC and it continued to remain inaccessible. The second one in 2013 was the national electronic accessibility policy. However, even today many websites are not accessible. After that policy, so many government initiatives, some 700 mobile applications, etc. came up, of which most are inaccessible.

Now everything is on mobile apps, whether private or government, so we did a lot of studies on that and wrote about it. We put together a set of guidelines and submitted them to the government to look at– otherwise there’s really no point in Digital India or Inclusive India. Of course the situation is now vastly changed, the Rights of Persons with Disabilities Act was passed in December 2016 and now makes compliance with accessibility standards in different domains mandatory, hopefully this will now be a game changer. It is binding not only on the government, but on the private sector as well.

It is not just a question of ‘responsibility’ –the government’s responsibility to its citizens is also not just regarding disability but about inclusiveness and the kind of society you want to be. It is about being nice and fair not just because you are responsible. It’s how you want your society to evolve.

Very often I think the most accessible products benefit everyone in society. It’s not just a person with disability that is getting benefit out of it. Do you agree?

So a lot of accessibility features came up as just a market feature, for example – in the U.S., so many people read audiobooks, they just listen while they’re driving to their place of work. Another example – those squeaky shoes children wear could help a mother who is blind know where her child is moving. You can say subtitles are for deaf persons, but for a Telugu movie, people who cannot understand Telugu also can go watch it now. I think every accessibility feature has a use. So, for society and the government accessibility should be a universal goal.

For private players a lot of times when you speak to them about accessibility they’re clueless or they think it is an expensive process which requires special knowledge. Do you have anything to say to such private entities like Flipkart, or Ola?

I think they’re not recognising the situation. If there are 1.3 billion people that are disabled in the world, there are 150 million people in India that are disabled – they need to realise that it is a huge market out there. Blind people are using Uber and not Ola. If they made their application accessible their market would grow. For Ola, for example it’ll ask me to rate my previous drive, and it only gives the option of 3 star with a screen reader – I can’t increase or decrease it. Now if I keep giving 3 stars only, I won’t get a driver the next time (laughs)! Uber and Amazon, both are entirely accessible and they’re international brands. You should ensure that your service is accessible in the starting itself when it is not expensive. Later it becomes more expensive and difficult to do. Private entities really need to look more into their diversity and it shouldn’t just be something they do for CSR, it is good business. It’s a good contribution to society.

Recently, in a move to digitise the courts in India, Prime Minister Narendra Modi launched the integrated case management system of the Supreme Court. Given that this move could be a game changer for lawyers and litigants with disabilities, do you believe that accessibility of such platforms will be given foremost importance by the government? If not, what steps can we take to ensure that it is given importance?

The RPWD Act 2016 requires all legal services, documents etc. uploaded to be accessible. If this is not done, it would be a tragedy. Just like the case of the Digital Library of India which has over 5 lakh books, most of which are image files and inaccessible. The government should ensure that this mistake is never again replicated. The website and the documents should be accessible as per notified standards. When you’re uploading documents, sometimes you might need scanned versions in which case you must have an unofficial version or some alternative that is accessible. Even if it is for tracking new cases, or filing things through apps, it should all be accessible as per guidelines – that’s the bottom line. So, involve the experts right from the beginning.

You have worked on digitization of books and general accessibility of educational resources for persons with disabilities. What in your opinion is the most resource efficient solution to the book famine currently plaguing students with print disabilities?

Every time a publisher publishes a book, they should give an accessible PDF to the public library or they should give it to the Sugamya Pustakalaya, which is an accessible online library. They’re anyway creating a PDF, they can make it accessible. As we get more organisations to connect to the library and network, you can reach out to all the students who go to these organisations. Publishers should also consider creating and commercially selling accessible format books such as e-text and audio books.

Could you tell us about your experience so far, in interacting and working with different government departments as part of various projects? As a policy researcher and advocate with a focus on the rights of persons with disabilities, what are the biggest obstacles you face in effectively lobbying for a change?

I think the obstacles are similar to the issues that you face typically while working with the Government on any issue, not just accessibility. It’s about meeting the right person. If you’re interacting only with one person, then that person gets transferred or the other people don’t know about it. I think that they need to see accessibility as something which cuts across every issue, not just something for the disabled, and that’s not happening. One also comes across people who do not consider accessibility a priority issue.

A lot of students with disabilities in India, even after the completion of their education, are not in a position to compete with their able-bodied counterparts. They don’t possess soft skills like knowing how to spell correctly, socializing and corresponding with others and speaking correct English. How can this be addressed at a micro as well as macro level?

I think there is a need for more organisations who are trying to prepare candidates after their education to deal with a corporate situation. Otherwise you’re just suddenly taken and put in a place you don’t fully understand. People might be conscious about their English or other things. If not on the individual level, if corporates are hiring they may also consider seeking help from and supporting such organisations.

You should also have policies for accommodation of persons with disabilities. It is useful to have mentors, networks or groups where they can share experiences and exchange ideas on how they tackle different situations.

What can law colleges do to make the educational experience better for law students with disabilities?

I think starting with the college level or institutions –I feel what we learn there shapes our confidence and grasp of the subject – where it is important to ensure that at least the reading list is available as accessible digital copy. I wouldn’t even accept if they say “2 out of the 10 on the reading list are available and that’s enough for you”, if you’re giving the 10 options to other students to pick from, even these students should get such an opportunity. They must also ensure that the admission process/ entrance exam is accessible.

Just getting admission is not enough if institutions can’t provide the required resources. Once that first step is done, they should consciously have a committee of students and teachers who can help in the process of studying, getting internships, or talking on their behalf to firms or other organisations. They may also consider accessible exam practices suited to the needs of different students. There are several things that can be done, institutions should evolve processes and practices based on discussions with their students with disabilities.

For more details visit https://cis-india.org/accessibility/news/idap-interview-series-interview-x-with-nirmita-narasimhan

Comments on Guidelines for Indian Government Websites

nirmita — 2017-11-26T07:08:25Z

The Ministry of Electronics & Information Technology, Government of India has published the Guidelines for Indian Government Websites (GIGW). Nirmita Narasimhan on behalf of the Centre for Internet & Society gave comments on GIGW.

See the response to suggestions and comments sent on GIGW by committee members here
See the Guidelines for Indian Government Websites here

For more details visit https://cis-india.org/accessibility/blog/comments-on-guidelines-for-indian-government-websites

Why GST Is A Step Backward For The Disabled

nirmita — 2017-07-03T02:39:18Z

Imposing taxes on assistive devices is unfair. The countdown has begun to the implementation of the GST in India. Over the past month, discussions about the GST have dominated the scene with several groups protesting in strong measure about the impact on their business.

The article by Nirmita Narasimhan was published by Huffington Post on July 1, 2017.

This post is concerned with the impact of an underrepresented group—that of persons with disabilities, who are facing severe impediments to their rights to independent living, mobility and participation if the GST is implemented as proposed in the present notification.

It is unconscionable that disability aids and assistive technology are considered a luxury and taxed at a higher rate than rough semi-precious stones or cashew nuts.

The new GST rules seek to impose tax on assistive technologies and goods and services which are essential for the advancement of persons with disabilities and will consequently, hamper their mobility as well as ability to participate in education and employment.

Some noteworthy points are:

5% GST on Braille typewriters, Braille paper, Braille watches and Braillers (originally set to 18% for typewriters and 12% for Braille paper and watches and reduced after protests from organisations like the National Centre for Promotion of Employment of Disabled People (NCPEDP), the Disability Rights Organisations Forum (DROF), and various regional groups. Only Braille books are exempt from the tax.

12% GST on orthopaedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability. Hearing aids have also been listed under the list of goods with nil taxes, which is contradictory.

18% GST on motor vehicles for persons with disabilities.

IT software, consulting and support services, online text, audio and video, software downloads etc. have all been classified but no GST rate has been quoted, which implies that they are taxed at 18%. This means software like screen readers, assistive software for persons with cognitive disabilities, online text etc. which are essential aspects of communications and information access for persons with disabilities will also be taxed at 18%, which will severely hamper their ability to communicate and even carry out daily tasks.

It is incomprehensible that the government should choose to impose a tax on the ability to walk, talk and deliberate using crutches, prosthetic limbs, hearing aids and communicating using assistive reading software for persons who have disabilities. It is unconscionable that disability aids and assistive technology are considered a luxury and taxed at a higher rate than rough semi-precious stones or cashew nuts. On the other hand, items such as kajal and glass bangles are not being taxed at all. Is ornamentation more important than the ability of persons with disabilities to lead their lives with dignity and independence? The current GST structure is discriminatory, making it even more difficult for persons with disabilities to participate in society, and contradicts the vision of an Accessible India.

Until we are able to assure the level of independence, accessibility and resources to the disabled to live a life of dignity like other countries do, we should not levy tax like them.

India is measuring herself against other developed countries where a reduced percentage of tax is levied on goods and services for persons with disabilities. Unfortunately however, the comparison ends there and does not extend to providing world-class services and facilities for the disabled, such as accessible roads, transportation, information. It would be wiser to follow our own lead from the past decade when we had not levied any tax on such items. The progress of this group has been painfully slow thus far anyway, so what will happen if GST rates up to 18% are levied?

As a country, we are not yet ready for this. We are still in a state where thousands of children with disabilities drop out of school even at the pre-primary level because they do not have the resources—technology, books, training and help—to pursue education. We still have a long way to go in terms of achieving basic rights for persons with disabilities, which is no longer the case in the developed countries that we seek to follow. The argument is hence not a blanket opposition to tax for persons with disabilities, just because they are disabled, but on the basis that until and unless we are able to assure the level of independence, accessibility and resources to the disabled to live a life of dignity and inclusion like other countries do, we should not consider levying tax like them. A person using a wheelchair in Germany can travel using public transport, but the same is impossible in India.

Once we are able to achieve the level of inclusion and accessibility of developed countries, we may consider taxing for certain items, although perhaps still not for all on the list. However, that time is not now. To build an inclusive society, we need to support persons with disabilities in all possible ways and imposing taxes on assistive devices will take us many steps backward.

For more details visit https://cis-india.org/accessibility/blog/why-gst-is-a-step-backward-for-the-disabled

GST - A Barrier to Human Rights for Persons with Disabilities

nirmita — 2017-06-25T14:15:05Z

The Centre of Internet & Society made a submission on the Goods and Services Tax (GST) which will be coming into play from July 2017 onwards. In this blog post Nirmita Narasimhan assesses the impact of GST on persons with disabilities.


Logo of Shuttleworth Foundation above

The GST Acts - Central Goods and Services Tax Act, Integrated Goods and Services Tax Act and the Union Territory Goods and Services Tax Act passed on 12 April 2017 and the subsequent notification of the Revised GST Rate for Certain Goods on 11th June 2017 have serious and severe implications on basic rights and freedoms for persons with disabilities, hindering them from living independently and pursuing education, and employment. This note outlines the impact of the GST measures as well as recommendations to ensure that the rights of persons with disabilities are not compromised.

Problem Statement

As per the 2011 census, India has over 21 million people with disabilities which is around 2.17% of the population. Persons with disabilities face many hurdles in education and employment which is reflected in the low effective literacy rate of 59%, far below the national level of 74.04% as well as a low work participation rate at 36.3%.[1]

Lower levels of literacy and employment in turn imply lower income levels for this group. Thus, additional support through policy, financial and operational measures is required to help persons with disabilities participate fully in the economy. The new GST rules however, seek to impose tax on assistive technologies and goods and services which are essential for the advancement of persons with disabilities, hampering their mobility and ability to participate in education and employment thus further compounding the disadvantages already faced by this group.

Main Concerns

The specific GST provisions that negatively impact persons with disabilities include:

5% GST on Braille typewriters, Braille paper, Braille watches and Braillers (originally set to 18% for typewriters and 12% for Braille paper and watches and reduced after protests from organizations like the National Centre for Promotion of Employment of Disabled People (NCPEDP), the Disability Rights Organisations Forum (DROF), and various regional groups)[2]
12% GST on Orthopaedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability. Hearing aids have also been listed under the list of goods with nil taxes, which is contradictory.
18% GST on motor vehicles for persons with disabilities.
Braille books are exempt from the tax while other Braille implements are not.
IT software, consulting and support services, online text, audio and video, software downloads etc. have all been classified but no GST rate has been quoted, which implies that they are taxed at 18%. This means software like screen readers, assistive software for persons with cognitive disabilities, online text etc. which are essential aspects of communications and information access for persons with disabilities will also be taxed at 18%, which will severely hamper their ability to communicate and even carry out daily tasks.

GST – Hampering Accessibility and Inclusion

Under the existing tax regime, many of these goods have traditionally been exempt from indirect taxes such as VAT, excise and customs. Even with the exemptions, assistive technologies have not been affordable. However, with the addition of GST, the situation becomes even more dire. For instance, according to India Today, the current market price for a Braille typewriter is about INR 34,000[3], or over 20 times higher than the monthly income of an impoverished urban Indian. Even with the new 5 percent GST (a reduction from the previous 18 percent), this would work out to INR 35,700. Given that 29.5 percent of the total population of India remained below the poverty line in 2011-12 and had a monthly per capita consumption of less than INR 972 in rural areas and INR 1407 in urban areas, [4] assistive technology would be prohibitively expensive even for the average Indian, let alone persons with disabilities.

GST – Discriminatory against Persons with Disabilities

The proposed GST on assistive technology is not only detrimental to the use of assistive technology, it discriminates against the right to equality of persons with disabilities.

Tools necessary for people pursuing their livelihood, such as agricultural implements and hand tools such as spades, shovels, mattocks, etc. used in agriculture, horticulture and forestry are exempt from any tax. However, assistive technologies which are just as vital for the education and livelihood of persons with disabilities, have been included in the list of items taxed under GST. While the Government of India’s move to protect the livelihood of agricultural workers is commendable, it needs to equally protect the right to livelihood of persons with disabilities who are working - 31% of whom are in the agricultural sector and will suffer from the imposition of GST.

GST – Impacting Mobility

The proposed GST on motor vehicles for persons with disabilities also impacts their right to mobility as per Article 41(2) of the Persons with Disabilities Act which calls for the government of India to “promote the personal mobility of persons with disabilities at affordable cost” through measures including incentives and concessions. The imposition of such a high tax on car purchases by persons with disabilities is in direct contravention of this.

Legal Framework

The proposed GST implementation and tax on products and services that are critical for persons with disabilities to pursue independence, literacy and employment with dignity runs counter to both national and international law to which India is a signatory.

Article 38 of the Constitution of India also requires the government to minimize inequalities in income, status, facilities and opportunities among individuals and groups of people.

The Rights of Persons with Disabilities Act 2016, enjoin the government to utilise the capacity of persons with disabilities by providing appropriate environment (Art 3(2) ) and take necessary steps to ensure reasonable accommodation for persons with disabilities (Art 3(5)).

The UN Convention on the Rights of Persons with Disabilities, which India has signed and ratified, calls on nations to promote the development and adoption of assistive technologies and devices for persons with disabilities, again “giving priority to technologies at an affordable cost.” (Article 4 (g)). Additional provisions include:

Art 4 – General Obligations asks states parties to take into account the protection and promotion of the human rights of persons with disabilities in all policies and programmes;
Art 5 (3) - asks States Parties to take all appropriate steps to ensure that reasonable accommodation is provided
Article 20 also requires nations to facilitate access to mobility aids, assistive technologies and other intermediaries, and requires that they be made available at affordable cost.
Art 24 on Education enjoins States parties to ensure persons with disabilities have access to inclusive education, that reasonable accommodation is provided and use of Braille, alternative modes and formats is facilitated
Art 27 on Work and employment required nations to protect the rights of persons with disabilities, on an equal basis with others, to just and favourable conditions of work
Art 29 on participation in political and public life advocates the creation of an environment that enables persons with disabilities to participate fully and effectively in the conduct of public affairs

International Practices

While developed countries do levy some tax on assistive technology and devices used by persons with disabilities, these are typically lower than the general rates. Countries in the EU levy lower VAT rates on medical equipment for persons with disabilities [5] for instance 6% in Belgium and 3% in Luxembourg. However, a point to be noted here is that the literacy and employment rates for persons with disabilities in these countries are much higher than in India, where the low literacy and work participation mean that even low levels of taxation on assistive technology make items prohibitively expensive.

An alternative approach more suitable in the Indian context, is that followed by developing countries such as Brazil and the Philippines. In Brazil, which has around 16 million [6] persons with disabilities, the import and sale of assistive technologies such as wheelchairs, Braille machines, calculators with voice synthesizers and hearing aids are exempt from major federal taxes. In addition, persons with disabilities wishing to buy a car also enjoy exemptions from several federal and municipal taxes. [7] In the Philippines, where 1.57 % of the population [8] have some form of disability, the Republic Act 9442[9] guarantees a 20 per cent discount for persons with disabilities and also provides assistance for education. Discounted goods and services include:

Restaurants, hotels and other recreation centers
Theaters, concert halls, carnivals, and other cultural and leisure centers
The purchase of medicines from drugstores
Medical, diagnostic and laboratory fees
Medical and dental service, including doctors’ fees
Domestic air and sea travel
Public railways, skyways, and bus fare

In addition to this, Republic Act 10754 [10] adds an exemption from the 12 percent VAT for persons with disabilities as well. Both of these represent a significant discount.

Conclusion

We fully concur with the representations made by different organisations working for persons with disabilities in India seeking a complete roll back of GST for persons with disabilities. India has in the past, refrained from taxing the disabled deliberately, keeping in mind their particular needs and circumstances and nothing has changed in the past few years to warrant this move. Persons with disabilities remain below the poverty line, without access to information, resources and the ability to enjoy even their basic human rights to live a life of freedom, independence, dignity, inclusion and participation. It is unconscionable to place such articles of basic need such as crutches and wheel chairs without which a person cannot even move on the same level as other goods. Certainly these are more basic than other items such as glass bangles or kajal which are not subject to GST or semi-precious stones which are taxed at a very minimum.
Rolling back GST would be in accordance with national and international legal commitment. India cannot place itself on the same level as countries in the EU for taxing the disabled; we do not have the same infrastructure and resources which these countries have made available for their disabled citizens, nor the social security measures which they offer. They are better placed in terms of development and progress of the disabled, with regard to education, employment and daily living. We cannot impose 18% tax on vehicles for the disabled while we are not providing them with a completely functional accessible transport network, accessible roads and a barrier-free environment. A very small percentage of persons with disabilities in India is actually living a full and complete life with access to resources and aids, an imposition of tax will further minimise chances of progress in the years to come of empowerment and emancipation of persons with disabilities. India has been a thought leader in the field of disability internationally in terms of its policies and served as an inspiration to countries around us. We were one of the earliest countries to sign and ratify the UNCRPD, as well as the first country to ratify the Marrakesh Treaty more recently in 2014. We do not lack in spirit, however do not always follow up with action. The roll back on GST would be an appropriate move in line with our commitment to enable human rights for persons with disabilities and empower them with the use of technology and other tools and resources.
Specified exemptions for use of assistive technologies- Technology has proven a source of tremendous empowerment to persons with disabilities. Given that most ICTs are to be taxed at 18%, we strongly urge the government to specifically exclude all ICTs and downloaded software and content which are intended for persons with disabilities from tax. By imposing tax on an enabling technology, it would be tantamount to imposing tax on a sensory organ, i.e., by imposing tax on a hearing aid or screen reader, which would enable a deaf person to hear/ a blind person to read, it would be like imposing tax on ears or eyes. We hence strongly urge the government to reconsider the present move and set right the error which has been committed by subjecting goods and services for persons with disabilities to tax. We recommend review, complete roll back and explicit exemption on all goods and services for persons with disabilities from the purview of GST.

23 June, 2017

[1]. http://www.censusindia.gov.in/2011census/population_enumeration.html

[2]. http://www.thehindu.com/todays-paper/tp-national/tp-otherstates/drag-seeks-rollback-of-gst-ondisability-aids/article19123085.ece

[3]. http://indiatoday.intoday.in/story/gst-goods-and-services-tax-arun-jaitley-narendra-modi-disabledbraille/1/967920.html

[4]. http://planningcommission.nic.in/reports/genrep/pov_rep0707.pdf

[5]. http://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/taxation/vat/how_vat_ works/rates/vat_rates_en.pdf

[6]. https://www.disabled-world.com/news/south-america/

[7]. http://thebrazilbusiness.com/article/tax-reduction-for-people-with-disabilities

[8]. https://psa.gov.ph/content/persons-disability-philippines-results-2010-census

[9]. http://www.ncda.gov.ph/disability-laws/republic-acts/republic-act-9442/

[10]. http://www.ncda.gov.ph/disability-laws/implementing-rules-and-regulations-irr/irr-of-ra-10754-anact-expanding-the-benefits-and-privileges-of-persons-with-disability-pwd/

For more details visit https://cis-india.org/accessibility/blog/gst-a-barrier-to-human-rights-for-persons-with-disabilities

Report of the Global Accessibility Awareness Day 2017

nirmita — 2017-06-19T15:07:28Z

Aditya Tejas attended the Global Accessibility Awareness Day event organized at NIMHANS Convention Centre in Bengaluru. The event had multiple panels and presentations, including a talk on coding for accessibility, a panel on why accessibility is necessary and how India is lagging behind in implementing it, and a presentation on how accessibility principles are integrated into the product life cycle at Cisco.

Logo of Shuttleworth Foundation below:

Global Accessibility Awareness Day is celebrated across the world on May 3 every year. The objective of the event is to get everyone talking, thinking and learning about digital access/inclusion and people with different disabilities.

This year the Global Accessibility Awareness Day 2017 (GAAD 2017) organized by Prakat Solutions and co-hosted by CIS and Mitra Jyoti, was held on May 18 at NIMHANS Convention Centre in Bengaluru. The event was designed to raise awareness around digital accessibility issues for persons with disabilities. The Shuttleworth Foundation also supported this event. Approximately 250 people were in attendance. The URL for the event is here. A detailed agenda can be found here. Video recordings of the event will be made available shortly.

The event ran from 2:30-7:30 PM and featured various discussions and events, including dance ceremonies, skits, and talks by various figures.

The first event was an extended presentation on coding for accessibility by Nawaz Khan of PayPal, in which he discussed how developers can integrate accessibility principles into their software from the design phase, and how persons with disabilities can productively make their issues known to developers. He encouraged developers to adopt international standards such as WAI-ARIA, and also encouraged developers to use accessible open source libraries and testing tools. He took questions about standards for other types of disabilities beyond visual impairment, joining the global conversation around accessibility standards, and accessibility design for mobile platforms.

The main event was a panel on the awareness of accessibility issues in India and how they could be improved, both in the public and private spheres. In attendance were Abhik Biswas of Prakat Solutions, Pranay Gadodia of Deutsche Bank HR, Shalini Subramaniam of PayPal, Balachandra Shetty of Intuit, Sandeep Sabat of ZingUp Life, Kameshwari from Wipro, Mahabala Shetty from NIC, and Srinivasu from Informatica. The panel was moderated by Giri Prakash of Hindu Business Line. They discussed issues including how to promote a stronger government response to accessibility issues, initiatives that can be taken from the private or civil society sector in order to address accessibility issues, the lack of awareness around accessibility in the Indian context, and the responsibilities that developers have to make accessible apps and products. Shalini from PayPal talked about the potential for government initiatives such as Make in India could be used to further the availability of accessible consumer products and services in India.

The second speaker, Kameshwari Visarapu from Wipro, talked about how persons with disabilities need to make their voices heard in society. She stressed that, while the laws are already in place, people do not demand their rights. Without this, the government and any community, even those with the necessary power, would not be able to make the changes. Mahabala Shetty from NIC pointed out that NIC is responsible for developing and updating various government websites. He said he understood that the inaccessibility of government websites and services is a serious problem, and pledged to make sure that all websites would be made accessible in the coming months.

The fifth speaker was Sandeep Sabat of ZingUp Life, also a health tech company, which seeks to help people with issues not just around physical health, but also emotional, mental and spiritual health. He drew a comparison with the beginning of the mobile revolution, when people would say that web on mobile is a small, niche space, which eventually gave way to the idea of mobile-first design. Extending this analogy, he said that design must now be accessibility-first, in order to ensure that it becomes part of the culture of product development.

The sixth speaker at the event was Balachandra Shetty from Intuit. He pointed out that design principles needed to make a product accessible and making that product easy to use for the general public are the same, and that improving the user experience for 20% of the population effectively improves it for everyone.

The seventh speaker was Pranay Gadodia from Deutsche Bank HR, who argued that accessibility was important not just for persons with disabilities, but for everyone. He gave the example of ramps on public entrances, which make access easier for everyone. He demonstrated the use of a screen reader and tried to order food through Swiggy. When he found that the app was inaccessible, he pointed out that they had just lost a customer.

The eighth speaker, Srinivasu from Informatica, talked about his work in the accessibility space for various NGOs and companies. He argued that inaccessibility was never built into a product by design, and that any problems were the result of ignorance. He also said that accessibility work was the only career with two major benefits – that of creating an immediate impact among the community and being the kind of work that not only takes advantage of a business opportunity but also directly benefits consumers.

The ninth speaker, Abhik Biswas, said that he believes that accessibility is a nonissue, because if everyone wrote good code and followed best practices, all products would be accessible anyway. He said this was not always the case with software tools. He gave the example of work that Prakat did with a provider of legal software. In large corporate lawsuits, parties would usually share terabytes of data with each other, and legal e-discovery software is used to discover patterns for evidence. An inaccessible document would be useless to such software so, of course accessibility isn’t an issue only for a certain set of people. If you’re in the innovation space and trying to solve problems, he stressed, then accessibility is an issue.

The moderator then raised the issue of the lack of progress for persons with disabilities in the past five years. He asked what progress has been made in the legal area, and whether there are any solutions that users can come up with themselves rather than waiting for government action. Shalini pointed out the inaccessibility of the Swiggy app, and added that there are automated accessibility checkers for apps, both Apple and Android. She demonstrated this for the audience.

Kameshwari said that part of the problem is that a single person may not be able or willing to make much noise. There are a lot of communities that have been formed on a corporate/state/national level, but collectively making noise is important for major changes. One process that her own company tried was creating a repository of pre-tested accessible components, which has two advantages; the developer can pick the component from a standardized repository, and the component would have been pre-tested for accessibility and responsiveness. This is another possible solution – which people collectively come up with standardized repositories of accessible components.

She then gave the example of an accessible garden in Kerala, where persons with disabilities could visit and touch different types of plants in a guided experience to help them identify and understand them. When talking about inclusivity, she asked, why create a separate garden? Integrate these features into all gardens instead, she suggested.

The third speaker said that the government drains enthusiasm from people, and insisted that it could only play the role of a facilitator. The need is to inspire the necessary passion in people to carry forward the issues themselves.

Sandeep said that the intent is already there, but the government was not capable of doing it alone. The social fabric of the country needs to change, along with the attitude of the society. To that end, they suggested making accessibility a non-issue, and looking for opportunities to integrate it into society at large. Instead of thinking of it through a usability standpoint, consider how to improve the overall user experience of a product through the lens of a user with disabilities.

Balachandra pointed out that while love is a strong emotion, fear too is very powerful. The laws in the Commonwealth are much stricter than those in the US, he pointed out, and yet apps built in those countries are far more accessible than those in Indonesia, India etc. So, he suggested that if a product proved to be inaccessible to a certain segment of the population, the employees responsible could face down the CEO, and fear would drive them to make their products accessible. In addition, he called for stricter laws and a possible amendment of the IT Act, drawing upon laws in the Commonwealth and France. Disability discrimination in the US carries a high penalty, and suggested that similar laws would enforce accessibility in local products.

The moderator asked Pranay: is it possible for app developers or mobile platform providers to make accessibility mandatory for apps that are publicly released? He answered that as a tech developer he might not be the right person to answer that, however, he know that the iOS framework is much more stringent than Android in this regard. He called on users with disabilities to call out inaccessible design wherever they saw it, in order to inform developers and to create a healthy competition to make companies disability-inclusive. He also pointed out that many corporations hold events or draft policy for persons with disabilities without involving them in the decision-making process, and that this needed to change.

Srinivasu stressed that the job of making government services accessible fell on the developers within the government, who are in-house, or the vendors, who work for NIC. There are two things the government can do, he said; when asking for a vendor, they could refuse those who make inaccessible products, thus making accessibility a requirement for procurement.

The second is to raise accessibility issues at the level of education. He gave the example of several apps like TaxiForSure and Cleartrip, all of which responded to accessibility issues raised by their users. He stressed that any user could give feedback, and not just those with disabilities, and that raising awareness is a duty for everyone. He asked the audience to share the event on WhatsApp, and to type with their non-dominant hand, as a simple way of understanding disability. The other exercise he called on the audience to do is to write a post about the event on Facebook or their blogs using only the keyboard, without touching their mouse. In this way, he drew attention to thinking about accessibility whenever one uses a website or software.

Abhik took the opportunity to add one more dimension, an area of concern for app developers in India in particular – that of linguistic accessibility. Most apps, he pointed out, are being developed in English only, and most government apps have the additional burden of considering vernacular languages, while NVDA only supports 10-12. The government can’t solve this problem by making multilingual websites, as developers also need to contribute to projects like NVDA in order to build support for other languages. Accessibility, he stressed, wasn’t anyone’s problem, but everyone’s problem.

After this, Shekhar Naik, former captain of the Indian blind cricket team, talked about his life story. He mentioned that there are over 5c0k blind cricketers in the country. He talked about his passion for cricket, how it brought him to where he was today, and thanked the government for its increased recognition and felicitation of persons with disabilities.

After that, the owner of Pothole Raja, Pratap Bhimasena Rao, spoke about the importance of the accessibility of built environments such as roads. He pointed out that 25% of vehicular accidents cause a disability, and stressed the need to address these issues to promote not just accessibility, but prevent disability.

After this, Amit Balakrishna Joshi from the state government gave a brief overview of the Karnataka government’s accessibility and e-governance initiatives. He spoke about the Karnataka Mobile One app, an initiative to consolidate and digitize several state government services. As the world’s largest Mobile One platform, it would integrate about 40 departments, with the objective of bringing equality in service delivery across socioeconomic, linguistic and literacy divides.

At 7:00, Sean Murphy from Cisco gave a talk on universal design principles. He discussed how universal design is important to maximize market access, ensuring that a company reaches 100% of its market. In Cisco, accessibility is integrated into the product lifecycle right from the design phase to testing to rollout.

He also discussed regulatory standards such as Section 508 in the US, which he stressed were critical to securing industry-wide accessibility. The event ended at 7:30 p.m.

Images:

Participants light the lamp to commemorate the start of GAAD 2017.

Prakat Solutions co-founder Abhik Biswas speaks at GAAD 2017.

Panelists discuss accessibility challenges in India.

For more details visit https://cis-india.org/accessibility/blog/report-gaad-2017

Comments on the draft Policy on IT Accessibility for People with Disabilities

nirmita — 2017-05-19T15:33:41Z

The Centre for Internet & Society gave inputs on a document on implementing digital accessibility to Ministry of Electronics and Information Technology on May 2, 2017.

We welcome the initiative of the MEITY to formulate a policy/ set of guidelines to implement electronic accessibility for persons with disabilities within the government and provide our comments to the draft document below:

Accessibility of the document:

The present document is not completely accessible. The first two Annexures cannot be read at all using a screen reader and there is also scope for improving accessibility in the rest of the document. Given the government’s policy requiring electronic accessibility and the nature of this document itself, this error may be rectified immediately. A good resource for creating accessible electronic documents is available at https://help.rnib.org.uk/help/daily-living/technology/accessible-documents

Title and content presentation:

The present title reads- ‘Policy for IT Accessibility for people with disabilities”. This may be rephrased to - Policy for Implementing IT accessibility for persons with disabilities so that its purpose is clear and differentiated from the National Policy on Universal Electronics Accessibility. The policy may be broadly divided into four main aspects- Content and communication, technology, training and procurement, since these are the four areas where specific interventions are required and have different needs and associated standards.

Preliminary sections:

The policy would benefit from clearly articulated vision, objectives, scope, applicability and statement.

Content and communication:

All communication, including documents and publications, whether print or electronic, should be universally accessible. This could include documents, mails, invoices, leaflets etc. We recommend use of Unicode, EPUB 3, EPUB 3 Accessibility Guidelines and WCAG 2.0 (level AA) as the standards to be followed while creating and publishing electronic documents and information. The need to use Unicode for regional languages is especially emphasised, as also the need to provide alternatives in case of scanned notifications and documents. We would also like to stress the need to use alternate modes of communication for transactions such as Alternative mode of authentication other than visual captcha (IE: One time password (OTP), logical reasoning (2+2) etc.)

Accessibility of technologies:

ICT accessibility interventions for different disabilities- This section should be circulated to experts of different disabilities to get their inputs. Attention may be given to also providing technology options such as the screen reader NVDA which are open source, efficient and work with indian languages. Overall, it is recommended that this section, recognises that persons with disabilities be provided with suitable assistive technologies and accessible technologies to enable them to work efficiently. The illustrative list of disabilitywise technologies may be provided as annexures to the policy/ guidelines and not be part of the main document.

Click to read the full submission here; and see the Policy and Guidelines here

For more details visit https://cis-india.org/accessibility/blog/comments-on-the-draft-policy-on-it-accessibility-for-people-with-disabilities

Mobile Accessibility Practices

nirmita — 2017-04-12T13:48:13Z

Over the past few months the Centre for Internet & Society along with some like minded organizations had been working on framing a feasible accessibility guidelines for mobile apps which they could recommend to the Government of India, since there is no single standard in existence at the moment.

Problem Statement

The shift to digital governance and availability of assistive technologies have been both empowering as well as frustrating for persons with disabilities, who comprise approximately 150 million of the Indian population. Government initiatives such as the Digital India campaign are increasingly delivering basic functions of governance through information technologies. In the past year, the government, private sector and the world at large have embraced mobile applications as a preferred medium for user interactions and transactions.

The Mobile Seva App Store hosts 790 government apps, which provide services including voter information, agricultural assistance, welfare scheme signups, and educational content provision. In addition, the overall app market in India has also grown rapidly, with almost 5 times as many apps downloaded in 2015 compared to the previous year. These include apps which let users access everyday services like transportation, communication and entertainment.

However, for persons with disabilities, many of these apps, and consequently the services they provide, are inaccessible and often impossible to use. Research in the past year that looked at several apps, both government and private, found that a majority of the apps are inaccessible and unusable, especially for persons with low vision and blindness.

Read the full submission

For more details visit https://cis-india.org/accessibility/blog/mobile-accessibility-practices

Comments on the draft Rights of Persons with Disabilities Rules

nirmita — 2017-03-29T03:41:25Z

The Centre for Internet & Society (CIS) submitted comments on the draft Rights of Persons with Disabilities Rules for the consideration of the Department of Empowerment of Persons with Disabilities, Government of India.

The comments were submitted to the Department of Empowerment of Persons with Disabilities on March 23, 2017. Click to download the submission here.

Introduction

We thank the Department of Empowerment of Persons with Disabilities (DEPD) for inviting comments on its draft rules. We provide brief comments on the Rules below. We would particularly like to draw the department’s attention to the need to have rules concerning measures relating to standards compliance, training and monitoring which we feel would help strengthen the Rules to address the issue of accessibility in a timely and effective manner.

Accessibility of the draft rules document

At the outset, we would like to draw attention to the fact that the Rules when first published in PDF form were only partially accessible and not easily readable for persons using screen readers. We appreciate that at a later date, an accessible Word version was provided, however we feel that even the original PDF needs to conform to the PDF/UA standards.

Policy/Guidelines on accessible communication

Following from the above point, we would like to propose that the DEPD publish at the earliest a set of guidelines for publishing accessible information and communication. The guidelines may define what constitutes information, explain how to create and disseminate accessible information and identify relevant accessibility standards. They may be applicable to all cases where printed or electronic information such as books, leaflets/ handbooks, mails, invoices, forms, data, policies and acts are created and communicated to diverse stakeholders. This guidelines may be mandatory across the Central and State Governments.

Reasonable Accommodation

Rule 3(1) requires that every establishment take steps to provide reasonable accommodation. It may further be added that said measures towards reasonable accommodation be taken within a reasonable time frame, such that persons with disabilities are provided access to resources at the same time as others and not significantly later.

Standards and Guidelines

Standards are critical to implement accessibility, and it is important that we adopt the most updated globally recognised standards. To aid this endeavour, we recommend that the DEPD may appoint two experts who will primarily be responsible for implementing accessibility. Their tasks will involve identifying standards and policy requirements in different domains and coordinating with the relevant ministries to notify and implement the same. One expert may be responsible for environmental accessibility, while the other may be responsible for overseeing ICT accessibility. The experts may carry out the tasks of formulating strategies to implement accessibility compliance, as well as researching advances in international policies and standards and making recommendations to relevant Ministries.

Regarding the Rules relating to the notification of standards for ICT accessibility (Rule 17.c.), we recommend that these may be expanded and made more comprehensive. To our understanding, some of the standards mentioned in relation to ICT accessibility such as telecasting and broadcasting do not as yet address the issue of accessibility. We recommend that the relevant ministries notify standards and guidelines to be followed in their regard at the earliest. There are also critical domains such as procurement, telecommunications and mobile devices, services and applications and emergency and disaster response for which standards and guidelines need to be notified.

We propose that the deadline for notification of standards be set within 6 months of the Rules coming into force and that the standards to be adopted are those which are globally followed, such as EN 301-549 for procurement.

Past efforts have proven that the notification of guidelines alone does not necessarily result in the implementation of accessibility, and often times a web site or platform which has been made accessible, reverts to being inaccessible as time elapses and persons who are involved in updating it and maintaining are unaware of accessibility principles to be followed. Hence, each and every person developing, maintaining and updating a website should be familiar with accessibility core principles. Outsourcing accessibility compliance is a temporary solution, it will be rendered pointless as people continue to update the website and post new content that is inaccessible. Therefore, some level of training is an absolute necessity, although the specific level and nature of these trainings may vary based on the individual’s role in relation to the website. For example, a web developer would need more in depth training as compared to a communications or administrative officer whose role may be to upload documents to the web site. Creating accessible documents and communicating in an accessible manner is something which every government official should be able to do, while the needs of developers are more advanced and technical and may require two rounds of training. Each ministry and department at the Centre and state may allocate a certain portion of their budget towards this.

An Accessibility specialisation unit may also be constituted within the NIC or any other appropriate agency whose task will be especially to provide on-going practical support to government agencies on how to implement accessibility across their web sites and publications. This team may work closely with the DEPD and other government agencies to audit, trouble shoot and guide continuous progress in implementing web site accessibility across the government.

All Ministries and government agencies may be required to include a section on accessibility compliance and initiatives as part of their annual reporting. This report may also include their performance on expenditure relating to implementing accessibility, hiring employees with disabilities, trainings undertaken and affirmative action required to be taken by them as given in the RPWD Act 2016, such as steps towards incentivising affirmative action by the private sector and activities undertaken relating to Chapter VI, Chapter VII and Chapter VIII of the RPWD Act.

Training and Support

Monitoring and reporting

Regarding website accessibility, the DEPD may also consider taking up auditing web sites of government agencies at random from time to time and publish the reports periodically as a measure towards gauging progress. A comprehensive audit of all government web sites of both the Central and state government and applications may be undertaken every 3 years.

National fund

Rule 43, relating to the Utilization of the National Fund is not clear on how much money is spent on accessibility initiatives each year. It is proposed that this rule specify the percentage of funds which have to be required to be utilised each year. In the absence of this, there is a concern that the fund will be under utilised, despite there being a large need for spending on accessibility. Details of projects and spending may be published from time to time.

Office of the Chief Commissioner

The DEPD may require that at least one person of senior rank within the Office of the Chief Commissioner for Persons with Disabilities be a person with disability. This will ensure that the interests of the concerned group are directly represented at the highest level dedicated to ensuring their welfare and participation.

Transparency

Finally we recommend that the rules emphasise the need for transparency in implementing the provisions of the Act and that all initiatives, programmes and expenditure may be published in a timely and accessible manner.

For more details visit https://cis-india.org/accessibility/blog/comments-on-the-draft-rights-of-persons-with-disabilities-rules

Comments on Department of Empowerment of Persons with Disabilities 'Vision Document 2030'

nirmita — 2017-02-28T15:58:55Z

The Centre for Internet & Society (CIS) submitted comments for the consideration of the Department of Empowerment of Persons with Disabilities (DEPD) on the Vision Document 2030 brought out earlier this month.

We appreciate the efforts by the Department of Empowerment of Persons with Disabilities (DEPD) to put together a vision and strategy document to inform and direct the implementation of the new Rights of Persons with Disabilities Act, 2016 (RPWD), and give effect to the rights of persons with disabilities as enshrined in various international treaties.

Overall, we recommend that the vision articulate more clearly in terms of quantifiable targets what it seeks to achieve at different points of time and that these targets, while taking into account the realistic situation in our country, are not so minimally set as to undermine the aims of the Act and the national commitments outlined therein.

We submit that it be kept in mind that this is not the first time that a national conversation has taken place around accessibility and standards, and that many previous attempts such as the Guidelines on Indian Government Websites (GIGW) have been in existence for nearly 8 years.

Therefore, we submit that the steps taken towards implementing this act should be more ambitious, and should seek to resolve the issue within the next 2-3 years. Accordingly please find our brief comments below:

Background

Section 2(i) is as follows: Vision: ‘To build an inclusive society in which equal opportunities are provided for the growth and development of Persons with Disabilities so that they can lead productive, safe and dignified lives.’ We propose the addition of the word ‘integration/inclusion/assimilation’ as in the phrase ‘growth, integration and development’, since that implies social acceptance, which is crucial. We also propose the addition of one more sentence as follows: ‘To enable access to technology and technology enabled resources for every person with a disability to facilitate effective communication and integration in society, as well as to ensure that accessibility considerations and standards are included across the board in all government programmes and initiatives.’
We propose in 3(a) - the inclusion of the word technologies in the phrase ‘providing appropriate aids and appliances.’ This is important since aids and appliances are not always technology-based and often times a new technology may be suitable, efficient and contemporary to address a specific need.
We propose in 3(b) - the inclusion of the word accessibility in the phrase ‘developing rehabilitation professionals/personnel.’

Long Term Vision by 2030

Inclusion of curriculum related to e-accessibility such as knowledge of the Web Content Accessibility Guidelines (WCAG) and universal design principles in all institutes and institutions teaching courses in engineering, computer science, IT etc.
Inclusion of disability-related issues in the curriculum of university courses in other fields as well, such as law, sociology, economics, and architecture.
Creation of a mechanism to gather more comprehensive and accurate data on persons with disabilities, such as their levels of access to technologies, information and basic resources and amenities.
Provision of training to use computers for students and children with disabilities in rural areas and provide training to students receiving aids and appliances as part of schemes. In addition, the Government should also focus on providing appropriate training and access to appropriate content in order to make full use of these technologies.

Seven Years' Strategy

The point about making documents, buildings, websites, documents etc. accessible under the Accessible India campaign [1] is appreciated; however, it should be accompanied with a mechanism for transparency and accountability. This should include periodic reports giving updates on the details of websites, documents, etc. taken up for retrofitting. At the moment, this information is not available on any of the public domain web sites such as the Accessible India campaign URLs, and repeated RTIs have failed to make this information available. Hence, there is no clarity on what the exact number of URLs and documents which have been made accessible so far is. Without accountability built into this procedure moving forward, there is very little to ensure that it happens.

Three Years Strategy

Review of legislations for persons with disabilities : we propose that a time line be set for this, say within 6 months and a list of existing and new policy/ legislation requiring interventions/ formulation be drawn up for action. Priority tasks could be to take up accessible procurement, accessibility of mobile applications, web sites and electronic documents.
One of the foremost tasks should be to identify and notify appropriate standards for different domains of accessibility such as procurement, electronic documents, television and so on, as well as reaffirm/ update any existing standards already recognized by the Government so that the process of retrofitting existing resources, as well as building new accessible ones commences at the earliest.
It is recommended that the Government of India put together an advisory committee of subject matter experts from NGOs and other civil society bodies who can advise on initiatives to be taken for environmental and information accessibility.
Regarding the plan for making 50% of all government web sites and documents accessible[2] , this target needs to be revised. The Accessible India campaign, which lists the same target in its strategy document,[3] has already been underway for the past one and a half years, and we hope that this target would have already been achieved under those efforts. Hence, if the Government sets a target of 50% over the next three years, this implies either that work has not been taking place thus far, or that very little will be done over that period of time. Furthermore, the RPWD Act requires all service providers to make their services accessible within 2 years of notification of regulation by the Central Government[4], hence the time stipulated under the Act is much lesser than the vision is providing for and should be amended to making all web sites and documents accessible within 2 years. It may further be noted that the GIGW had been notified since 2009 and despite being in place for eight years, there is currently no official information on how many websites been made fully compliant with these standards. Therefore, we submit that a strict approach with regard to any deadlines and regulatory measures are necessary.
It is respectfully submitted that the number of 500 language interpreters[5] is simply not enough. This would work out to approximately 15 interpreters per state in 3 years, a number that we consider far too low for the time allotted. We submit instead that it is urgent that an attempt be made to train at least 30 people per state/UT per year, which would work out to 90 interpreters per state/UT over the 3-year period.
It is crucial the DEPD try to work with the Digital India campaign and the Smart Cities Mission to ensure that upcoming smart cities are born accessible. To this end, there needs to be specific measures to ensure that accessibility standards are part of the Terms of Reference and contracts for smart cities and that there is sufficient guidance and accountability for this.

[1]. Section C.6

[2]. Section D.6

[3]. http://www.disabilityaffairs.gov.in/upload/uploadfiles/files/Accessible%20India%20Campaign_Brochure.pdf

[4]. Chapter VIII, Section 46

[5]. Section D.7

For more details visit https://cis-india.org/accessibility/blog/comments-on-depds-vision-document-2030

The Quest for Education – Persons with Disabilities, Severely Challenged

nirmita — 2016-11-30T15:38:55Z

Education is the fundamental building block of development; it leads to an improved quality of life, employment, social acceptance and inclusion, national development and intellectual growth.

Published in Your Story on November 24, 2016

The right to education and the current census figures

Over the past decade, multiple efforts and initiatives associated with policy and programme towards achieving the goal of education have taken place. However, there are still millions of children with disabilities and students who are struggling to access basic and higher education and for whom economic independence appears to be an elusive dream.

The 2011 census figures show that the literacy rates for persons with disabilities are much lower than that of the non-disabled population of the country and even within that, certain disabilities and women across disabilities have a lower percentage. The overall literacy rate for persons with disabilities is 59 percent compared to 74 percent for the general population. The literacy level of women with disabilities in urban areas is 61 percent, which is 9 percent lower than their male counterparts. While women with disabilities in rural areas are worse with a literacy rate of 38 percent, 20 percent lower than disabled males. And people with multiple disabilities fare the worst, with a 35.8 percent literacy rate. Their education needs in terms of content, technology, training and support remain unfulfilled.

Challenges faced by the disabled

The issues faced by children with different disabilities vary. For instance, in the case of children with print impairment, there is need for aggressive implementation of schemes to provide assistive technology since most disabled students do not have access to technologies in most states. Students who are blind are dependent upon Braille materials, which often do not reach them before half the school term is over. And this only supports the bare minimum need in terms of reading and not any extra knowledge building requirements. In some states, laptops are being distributed; however, these are unaccompanied by any training requirements, so it is unclear how many students are really able to use their devices. In places where these devices are available, they are mostly provided to students from the ninth standard.

Thus, in some states, laptops are being distributed; however, these are unaccompanied by any training requirements, so it is unclear how many students are really able to use their devices. In places where these devices are available, they are mostly provided to students from the ninth standard. Thus, transition becomes difficult and they find it hard to write their own exams. So while their sighted counterparts are experimenting with technology from a much earlier age, they are introduced to it at a much later stage, by which time their colleagues are far ahead of them.

Children with hearing impairments also face many challenges. They are isolated from mainstream communication as well; there are only around 250 sign language interpreters in India and sometimes one person has to cater to the requirements of an entire state. Hence, they grow and are educated in isolation without proper means of integration in inclusive schools. The physical environments in most schools also tend to be inaccessible for those with mobility impairments.

It is a rather dismal scenario content wise too. The course content put out by different boards is not in accessible formats, so organisations serving the blind have to convert them into an accessible format. There is a strain on resources. In the case of regional language content, the expense of typing out Telugu or Tamil is high and often increases the cost of the book 10-fold. Just converting the basic course syllabus for any one subject for a BA course can run into lakhs. Hence, there is very limited access to books.

The third challenge is the lack of trained manpower and resources to provide an enriching reading experience for a child with a disability. Children not only have to deal with restrictive resource conditions, but also difficult social conditions and stigma at school. Attitudinal changes need to occur and a lot of this begins at home and school. Consider this, in a rural setting; students in a class have access to a teacher full time during school hours. But there may be only one special needs teacher catering to students with multiple disabilities across several schools. So instead of having more support, a student with disability has to actually deal with severely limited support.

Often these teachers are ironically paid much lesser than other teachers, considering that they actually need more skills and patience to teach children with disabilities. Only in the field of disability does one encounter a situation where a specialisation is undervalued and under paid, whereas in all other genre of professions like medicines, one has to do a generalisation before a specialisation. What sort of prospects then do we offer children with disabilities? What we need is resource centres at each college and school, or if that is not possible, then at least resource centres at district level coordinating support in an appropriate manner with adequately paid and skilled teachers.

Promoting technology

Promoting use of technology and open source software and imparting training at an early age will go a long way in making students with disabilities self-sufficient and independent. And of course, the issue of content is of primary importance. All boards must embrace accessible standards such as EPUB 3.0 for publications and WCAG 2.0 for their websites and make course content available in accessible formats. Exemption of certain topics should be replaced by facilitating learning using innovative methods and tools. Importantly, there also needs to be focus on providing education targeted towards profession and gainful employment.

Clearly, there is a long way to go before we can talk of inclusive education for children with disabilities; there is a severe shortage of even exclusive or special education. To improve the situation, individual piecemeal efforts alone will not make a difference. It is essential to have a systemic approach to inclusive education, with sufficient implementation and infrastructural support, if we are to progress to a point where every child with disability is encouraged to learn and be prepared for a world of employment, independence and dignity.

For more details visit https://cis-india.org/accessibility/blog/your-story-nirmita-narasimhan-november-24-2016-quest-for-education-persons-with-disabilities-severely-challenged

Where Are There So Few Books For The Print-Impaired?

nirmita — 2016-11-04T01:20:57Z

India publishes approximately 90,000 books each year in 24 different languages. We have over 16,000 publishers, and are one of the top nations for English book publishing in the world. Clearly we are a nation which values and fosters a culture of reading and passing on knowledge in different domains ranging from literature, to yoga, language, education, science, fiction and many others.

This article was published in the Huffington Post on November 3, 2016.

We are also the world's second most populous nation with an extremely large population with disabilities, including persons with print impairments. However, the total number of books accessible to the print impaired in India is only 19,000, a fraction of what is available yearly to the general public. How is it that despite our prowess in publishing and technology, persons with print impairments in India remain deprived of access to books and other forms of information which are key to an inclusive and fulfilling life?

There are presently approximately 19,000 books converted till date, a pathetic contrast to the 90,000 books published just in India every year.

Before going further into this question, let us understand the term "print disability". Very broadly, print-impaired persons are those who cannot access printed material due to some form of disability, such as blindness or low vision, dyslexia, autism etc. For these persons to be able to read, the material needs to be converted into some other format such as Braille or accessible electronic formats which can be read using some assistive device like a screen reader or e-book reader, fitted in a laptop, mobile or stand alone device. For assistive technology to be able to read the content, it needs to conform to universal standards such as Unicode for Indic font or EPUB 3.0.

The challenges

Until 2012, one of the biggest hurdles to access printed content for the print-disabled was the fact that they had to obtain permission from the copyright holder of the work, every time they wanted to convert a book into audio/ Braille/ other formats. This was often unsuccessful, time consuming and required resources beyond the means of most blindness organizations, who could convert only a bare minimum of books, mostly excerpts from school text books for their readers. After over a decade of sustained advocacy, the Government included section 52 (1)(zb) in the Indian Copyright Act, a fair use exception which permitted conversion of copyrighted works into any accessible format for the benefit of a person with a disability on a non-profit basis. For profit, conversion is permitted on certain terms. This considerably opened up the world of books for persons with print impairments in India. In September 2016, the Marrakesh Treaty for the Visually Impaired also came into force, which means that cross-border sharing of accessible books can happen between countries which have ratified the Treaty.

However, despite these measures, the availability of books remains abysmal. While the legal issues have been sorted out to a large extent, the practical situation is harder to deal with and there are significant hurdles in creation and dissemination as well as equipping users to read accessible books.

Firstly, organizations serving the print-impaired do not have the bandwidth to undertake large scale conversions of each and every book that gets published. At present, organizations have to spend considerable time and resources converting content into an accessible electronic format before they can make it available to end users. Consider this, the cost of typing out one page of a regional language like Telugu is approximately ₹30 So it would cost ₹3000 to type out a 100-page Telugu book, in addition to the price already paid to purchase the book. Apart from the unaffordability, the lack of equipment and personnel necessitates conversion being carried out in a very limited manner and mostly for books which are critical for studies and in high demand, since state boards do not provide accessible versions of school text books.

The simplest way to address accessible book creation would be for publishers to adopt EPUB 3.0 and ensure that books are "born accessible"...

While the Daisy Forum of India, along with the Government of India recently opened an online accessible digital library called the Sugamya Pustakalaya, it needs to be populated with accessible content. There are presently approximately 19,000 books converted till date, a pathetic contrast to the 90,000 books published just in India every year. Even international organizations such as Bookshare which have been expending millions to convert books in different countries have only succeeded in making 500,000 accessible books available in all, and these too are not equally available to persons in every country due to copyright issues.

The other challenge is to equip each and every print-impaired person with a device such as a laptop or mobile phone on which he/ she can read and work with the book. Of course, merely providing devices is pointless—appropriate training in how to use them is essential.

There are also issues of inadequate distribution networks to reach out to print impaired persons in urban and remote parts of India, which still need to be addressed.

Apart from the challenges specific to creating and disseminating accessible books, other digitization activities can also add to the problem. For instance, the Digital Library of India project, a spectacular effort to digitize books of all genres, is said to have a library of 550,603 books including several really old manuscripts and historical books. However, all of these are scanned and saved as inaccessible image files, rendering them of no use to the print-impaired.

Another problem is in the case of Indian language content which is often created in a nonUnicode font, making it unreadable for persons using screen readers.

How can we improve the situation?

The simplest way to address accessible book creation would be for publishers to adopt EPUB 3.0 and ensure that books are "born accessible" since they anyway produce a digital file of a book before bringing it out in print. This would obviate the entire cost, time and effort spent on conversion. Also, selling accessible e-versions to the print impaired could be a huge business opportunity for publishers, considering the large market for such books in India and globally. More information on this can be obtained from Accessible Book Consortium or by writing to BookShare.

We also need to ensure all digitization activities consider accessibility requirements and create resources that conform to accessibility standards.

We have the law, the technology, the books and the people, but need a concerted effort from multiple stakeholders... to bring all of these together.

On the technology front, an NGO-driven project over the past four years has now made text to speech available for several Indian languages using the open source text to speech engine e-Speak, which works with both laptops and Android phones. The government, with institutions like the IIT, is also driving initiatives to develop text to speech and optical character recognition (OCR) software for Indian languages. However, there is some way to go before these become available to end users.

To sum up, we have the law, we have the technology, the books and the people, but need a concerted effort from multiple stakeholders—the government, publishers, educational institutions and NGOs—to bring all of these together, so that every print-impaired person in India can enjoy the right to read.

For more details visit https://cis-india.org/accessibility/blog/huffington-post-november-3-2016-nirmita-narasimhan-where-are-there-so-few-books-for-print-impaired

Mobile Apps Are Excluding Millions Of Indians Who Want To Use Them

nirmita — 2016-09-24T16:01:45Z

If someone were to ask you how many apps you use in a day, you might need to stop and count. You use apps to book cabs, to order groceries, make payments online, buy diapers, connect with friends... the list goes on. In fact apps, are becoming so intrinsic to daily life that without one handy you may have to think twice about how to complete a transaction.

The article was published in the Huffington Post on September 22, 2016.

Apps are uncomplicated, easy to use, at your finger tips and quick. So logically, everyone who has a smartphone should be using them, right? Unfortunately, that is not the case. Much as they would like to, millions of persons living with disabilities are unable to use apps to fulfil their daily living needs. This is because most apps are not accessible to users with a visual disability.

With about 30% of the blind population of the world living in India, it's imperative for service providers to give more thought to universal design and accessibility standards.

In order for an app to be accessible for a blind user, it should be readable by a screen reader -- software which reads out whatever appears on the screen. For it to function effectively, elements on web pages and applications should be properly labelled, otherwise the software will be unable to decipher what it is, not having any cognitive abilities like human beings. It will merely read out the element out as "button" or "graphic".

Here I will look at five very popular apps relating to food, groceries, transportation and mobile bill payment and banking to see how accessible they are for people with disabilities. These apps were tested using Talk Back, an open source Android screen reader.

1. Swiggy

The first app we looked at was Swiggy, which is used to order food from nearby restaurants. Here, the first screen, which shows the discounts/offers available, uses a graphics banner without alternative text, which cannot be deciphered by a screen reader. Another issue is inaccessible navigation. For instance, though we can select a food category like "soup", choosing a particular type of soup is not possible as the focus simply stays on the main category. This means a screen reader cannot read the rest of the information, making it impossible for a visually challenged person to order food.

2. Big Basket

Then we tried Big Basket to order some groceries. One of the issues we found included unlabelled banners; also, the continuous scrolling of the banner, which makes the screen reader try to constantly read the next unlabelled graphic, renders the app practically unusable. When we navigated to the list of products available, only their names were readable and the focus could not be shifted to information like price and quantity. This means the user can add items to the basket, but has no way of knowing the price or deciding the quantity, which obviously makes the app a no-go.

3. Ola

The taxi-hailing app Ola is fairly accessible, with some scope for improvement. The button to pinpoint the location is not labelled, and while trying to select a cab category the focus moves away automatically if there is no action in a few seconds. Hence, a person with vision impairments may need some assistance to use the app.

4. MyAirTel

This app for Airtel customers was found to have limited usability, with several accessibility issues. Many buttons, including Settings and Information are not labelled and hence are not readable by screen readers. The offers and discounts banner is also not labelled and keeps on moving, sending the screen reader into a loop saying "graphic". However, viewing unbilled/billed amounts and paying bills is easy, as those screens are well labelled and use minimal graphic controls.

5. ICICI - Pockets

This digital wallet app from ICICI bank was tested using an ICICI bank internet banking login and unfortunately found to be completely inaccessible for a person using a screen reader. There is no screen reader support and consequently no auditory feedback when using slides or touching the screen. One can tap and access the menus/options but they are not focusable and are not announced by the screen reader.

Over the past few years we have seen how corporates have embraced technological innovations and helped better the lives of common Indians. However, a more inclusive approach will help people with disabilities to enjoy the best technology has to offer, and lead a more independent life. It would be pertinent to mention at this point that the inaccessibility of apps is not a phenomenon which is particular to the ones reviewed above, but a common feature across stakeholder groups, including private and government agencies. With about 30% of the blind population of the world living in India, it's imperative for service providers engaging consumers through information and communication technologies to give more thought to universal design and accessibility standards. It would truly make a difference in the lives of many Indians.

For more details visit https://cis-india.org/accessibility/blog/huffington-post-september-22-2016-nirmita-narasimhan-mobile-apps-are-excluding-millions-of-indians-who-want-to-use-them

An Overview of Accessibility Work (2008 - 2016)

nirmita — 2016-09-24T16:09:53Z

India has an estimated 70 million disabled persons who are unable to read printed materials due to some form of physical, sensory, cognitive or other disability. The disabled need accessible content, devices and interfaces facilitated via copyright law and accessibility policies. CIS campaigns for change in this area.

The progress made over the years can be accessed below:

Publications

E-Accessibility Policy Handbook for Persons with Disabilities (Nirmita Narasimhan, G3ict and ITU; November 23, 2010): The handbook was compiled and edited by Nirmita Narasimhan. Nirmita also contributed to the original toolkit.
Universal Service for Persons with Disabilities (CIS, G3ict and Hans Foundation; December 27, 2011). Nirmita Narasimhan was a co-author.
Web Accessibility Policy Making (CIS, G3ict and Hans Foundation; February 28, 2012). Nirmita Narasimhan was a contributor.
Making Mobile Phones and Services Accessible for Persons with Disabilities (ITU and G3ict; August 2012). Nirmita Narasimhan was a co-author.
Accessibility of Government Websites in India: A Report (CIS and Hans Foundation; September 26, 2012). Nirmita Narasimhan was a co-author.
Opening New Avenues for Empowerment (UNESCO; February 2013). Nirmita Narasimhan was the project coordinator from Asia Pacific.
Inclusive Financial Services for Seniors and Persons with Disabilities: Global Trends in Accessibility Requirements (G3ict and CIS; February 2015). Nirmita Narasimhan was a co-author.
National Compendium of Laws, Policies and Programmes for Persons with Disabilities (CIS and Office of the Chief Commissioner for Persons with Disabilities, Department of Disability Affairs, Ministry of Social Justice and Empowerment, Govt. of India; January 3, 2016). Nirmita Narasimhan was one of the contributors.

Reports

NIVH Annual Report 2011-12 (NIVH; 2012)
Inclusive Disaster and Emergency Management for Persons with Disabilities (Nirmita Narasimhan and Deepti Samant Raja; September 17, 2013). The report was submitted to the National Disaster Management Authority of India for their action.
Banking and Accessibility in India: A Report (Nirmita Narasimhan; August 12, 2013)
Accessibility of Political Parties Websites in India (Nirmita Narasimhan; March 24, 2014).
Enabling Elections (Nirmita Narasimhan and Centre for Law and Policy Research; March 2014).

Policy Submissions and Feedback

CIS worked with the Department of Electronics and Information Technology and civil society and industry partners such as the National Centre for Promotion of Employment for Disabled People (NCPEDP), Microsoft Corporation, National informatics Centre (NIC), etc., to formulate and implement a National Electronic Accessibility Policy to ensure that all Indian information and communication technologies and electronic infrastructure (including the Internet) and research which is publically funded, is accessible to persons with disabilities. Nirmita Narasimhan was part of the policy drafting committee.
Accessibility in the New Telecom Policy 2011: CIS made a submission to the Department of Telecommunications, Ministry of Communications & Information Technology, Government of India on December 9, 2011. CIS was one of the 27 organisations that sent a joint letter requesting that accessibility for persons with disabilities be included specifically within the goals and objectives of the policy.
Pilot Project Scheme - Access to ICTs and ICT Enabled Services for Persons with Disabilities in Rural India: CIS worked with USOF of India to design a scheme to launch projects for persons with disabilities. CIS prepared a background paper for the USOF, compiled a comprehensive global report which was later published in cooperation with G3ict and helped to convene a stakeholders meeting in September 2011 to launch the scheme and invite project applications.
Comments to the Rights of Persons with Disabilities Bill, 2014 (Nirmita Narasimhan and Anandhi Viswanathan; October 30, 2014). The comments were submitted to the Parliamentary Standing Committee in October 2014.
CIS joined hands with Daisy Forum of India member Arushi in Bhopal to submit a request for a notification mandating that all communication by the Government of Madhya Pradesh should be accessible to persons with disabilities. The state government issued a notification in Hindi requesting all departments to comply with WCAG 2.0 and use Unicode font. Nirmita Narasimhan drafted this submission.
Accessible ICT Procurement: CIS along with 20 other organisations petitioned the Ministry of Social Justice & Empowerment, Ministry of Finance and the Ministry of Information Technology, Govt. of India to bring in accessibility considerations within the draft Procurement Bill.
Comments to the GIGW (Nirmita Narasimhan; April 30, 2015): CIS submitted its comments to the National Informatics Centre for making Indian government websites conform to the notified standards of the Guidelines for Indian Government Websites.
Recommendations on Accessible ICT Procurement (Pranesh Prakash; May 9, 2016). CIS along with 20 other organisations petitioned the Ministry of Social Justice & Empowerment, Ministry of Finance and the Ministry of Information Technology to bring in accessibility considerations within the draft Procurement Bill.

WIPO

CIS is accredited as an observer at WIPO and regularly participates in the meetings of the Standing Committee for Copyright and Related Rights (SCCR) held in Geneva. CIS is actively involved in matters being discussed there such as the TVI. As part of its work, CIS provides comments at the SCCR and advises the Indian government on these matters through policy briefs, research and interactive discussions and meetings. CIS has given several statements on Treaty for the Visually Impaired and prepared an analysis of the consensus document on an international instrument on limitations and exceptions for persons with disabilities with the Third World Network which was widely circulated amongst the negotiators at the SCCR. CIS’ statements at the SCCR in June 2013, July 2012, December 2011, June 2011, and November 2010 are available on the CIS website.

CIS took part in the WIPO Diplomatic Conference to Conclude a Treaty to Facilitate Access to Published Works by Visually Impaired Persons and Persons with Print Disabilities in Marrakesh, Morocco, June 17 to 28, 2013. The conference concluded with the adoption of the Marrakesh Treaty to Facilitate Access to Published Works for Persons who are Blind, Visually Impaired, or otherwise Print Disabled. CIS's Closing Statement at Marrakesh on the Treaty for the Blind can be seen here.

At the national level CIS has been campaigning for right to read, attending meetings with ministries such as the Ministry of Human Resource Development, Department of Electronics and Information Technology, and the Ministry of Social Justice and Empowerment, and giving feedback on the Copyright Amendment Bills. Earlier this year, CIS gave a detailed analysis of the Copyright (Amendment) Bill 2012 examining the positive changes and the negative ones.

Events

National Workshop on Web Accessibility (Organized by CIS and Society for Promotion of Alternative Computing and Employment; September 25-26, 2009).
National Conference on ICTs for Differently Abled / Under privileged Communities in Education, Employment & Entrepreneurship — NCIDEEE 2009 (Loyola College, Chennai, December 1 – 3, 2009): The event was co-organised by Dr. A. Albert Muthumalai S. J, Principal, Loyola College, & Prof. J. Jerald Inico, Faculty In-charge, Resource Centre for the Differently Abled (RCDA), Loyola College, in association with NASSCOM, Computer Society of India and CIS.
CIS organized Right to Read campaigns in the 4 metro cities of Chennai Kolkata, Delhi and Mumbai. The campaign has gathered thousands of supporters and has succeeded in bringing the problems of the print disabled to the notice of policy makers and the general public.
EdICT 2010 (New Delhi, October 27 to 30, 2010): CIS in collaboration with G3ict, UNESCO, ITU, WIPO, The Deafway Foundation, DEF and SPACE and with the support from Hans Foundation and the Department of Information Technology, Ministry of Information and Communication Technology organised this event. Twenty-nine experts made presentations on a variety of topics, ranging from discussing challenges and solutions in educational institutions, to technology development and policy formulation and implementation. A total of 77 participants attended this event.
Websites Accessibility Evaluation Methodologies at Twentieth International World Wide Web Conference (Hyderabad, March 30 – 31, 2011): CIS co-organised this with G3ict and W3C. The panel discussed web accessibility evaluation methodologies and their challenges and technical survey methodologies alternatives. The panel was moderated by Nirmita Narasimhan and featured four speakers — Shadi Abou Zahra, Neeta Verma, Srinivasu Chakravartula and Glenda Sims.
ITU Tutorial on Audiovisual Media Accessibility (India International Centre, New Delhi, March 14 – 15, 2012): In cooperation with the ITU-APT Foundation of India, CIS hosted a two-day Tutorial on Audio Visual Media Accessibility from March 14 to 15, 2012 at the India International Centre, New Delhi, India.
Girls in ICT Day (Organized by CIS and Mithra Jyothi; Bangalore; April 25, 2013).

Internet Governance Forum
CIS has been organising workshops and participating regularly at IGF events since 2008 on topics like accessibility, access to knowledge, openness, internet governance, freedom of expression, etc. Details given below: IGF 2008, Hyderabad, India: CIS joined the Dynamic Coalition on Open Standards and also contributed to the authoring of the Agreement on Procurement in Support of Interoperability and Open Standards. CIS is now a part of the DCOS secretariat. IGF 2009, Sharm El Sheikh, Egypt: Nirmita Narasimhan presented on Accessibility Policy Making: An International Perspective at the Global Internet Access for Persons with Disabilities workshop organised by ITU and EBU on November 16. CIS also co-organised the workshop on ‘Content Regulation, Surveillance and Sexuality Rights – Privacy, Agency and Security’, together with the Association for Progressive Communications, Women’s Networking Support Programme and the Alternative Law Forum. IGF2010, Vilnius, Lithuania: At the UNESCO Open Forum, Anja Kovacs presented the research study ‘Exploring ICT-enabled Education Initiatives for Persons with Disabilities in the Asia-Pacific Region’. The study was undertaken by CIS in cooperation with G3ICT and UNESCO. Besides this, CIS co-organised these workshops: Freedom of Expression or Access to Knowledge: Are We Taking the Necessary Steps towards an Open and inclusive Internet? with the Center for Technology and Society, Brazil, ‘Sexual Rights, Openness and Regulatory Systems’, with the Association for Progressive Communications and the Alternative Law Forum, Open Standards: Ensuring Accessibility and Inclusiveness with the World Wide Web Consortium and the workshop on Data in the Cloud: Where Do Open Standards Fit In? IGF 2011, Nairobi, Kenya: Use of Digital Technologies for Civic Engagement and Political Change: Lessons Learned and Way Forward and Open Spectrum for Development in the Context of the Digital Migration. These workshops were organized by CIS.

Awards

Nirmita Narasimhan was awarded the National Award for Empowerment of Persons with Disabilities from the Government of India on December 3, 2010 on the occasion of the World Disability Day. The award was presented by Smt. Pratibha Patil, President of India under the Role Model category. The award function took place at Vigyan Bhavan in New Delhi and was telecast live on Doordarshan.
Nirmita Narasimhan received the NIVH Excellence Award from Justice AS Anand (retd), former chairman of the National Human Rights Commission, on International Day of Persons with Disabilities at the National Institute for the Visually Handicapped in Dehradun on December 3, 2011. The Tribune covered the award ceremony.
Girls in ICT Day 2013 (organized by ITU-APT Foundation of India with support from CMAI - Association of India Communication and Infrastructure, FICCI Auditorium, Tansen Marg, New Delhi, May 7, 2013). Dr. Nirmita Narasimhan got a felicitation for her contribution and achievements in the field of Information and Communication Technology. The honour was conferred during the celebration of this event.
Nirmita Narasimhan won the NCPEDP-Mphasis Universal Design Award in the "Persons with Disabilities" category. The awards aim to raise awareness about accessibility.

Articles and Interviews

Technology for Accessibility in Higher Education: Nirmita Narasimhan wrote an article in Enabling Access for Persons with Disabilities to Higher Education and Workplace - Role of ICT and Assistive Technologies. The IIMB Journal was brought out on the occasion of the conference ‘never-the-less’.
The Business Case for Web Accessibility: NASSCOM Foundation published "Understanding Web Accessibility — A Guide to create Accessible Work Environments". In this handbook on web accessibility, Nirmita Narasimhan authored a chapter titled “The Business Case for Web Accessibility”.
Barriers to Access in a Connected World: Hans Foundation published its Annual Review of 2011. Nirmita Narasimhan wrote an article in it. She wrote that accessibility is an imperative to achieve a truly inclusive and participatory society and every individual, corporation, organization and government has a crucial role to play in nurturing it.
Girls in ICT Portal (November 28, 2011): ITU interviewed Nirmita and published her profile on their website.
An India Where the Disabled have a Choice (Dataquest, August 5, 2016). Nirmita Narasimhan spoke to Dr. Archana Verma about the problems faced by the disabled while using technology.
We Tested 18 Government Apps, and Most are not Fully Accessible to the Disabled (Nirmita Narasimhan; Factor Daily, August 31, 2016).
Mobile Apps Are Excluding Millions Of Indians Who Want To Use Them (Nirmita Narasimhan; Huffington Post; September 22, 2016).

Media Coverage

Nirmita Narasimhan gave inputs to the following media coverage:

DFI and Cambridge University Press join hands for getting print access to the “print impaired” (The Bookseller; November 27, 2009).
WIPO Proposals Would Open Cross-Border Access To Materials For Print Disabled (IP Watch; May 28, 2010).
Disability groups in India welcome progress on treaty for blind persons (The Times of India; December 20, 2012).
Indian Users’ Perspective On WIPO Negotiations On Treaty For Visually Impaired (IP Watch; February 16, 2013).
How tech brings self-reliance to students with disabilities (The Times of India; May 29, 2016).
How India’s top firms fare in employing women and persons with disabilities (Livemit; August 9, 2016).
Using technology to address issues (The Hindu; August 14, 2016).
India has a long road ahead in becoming a disabled-friendly country (Your Story; August 31, 2016).

NVDA and eSpeak

Hans Foundation is funding CIS to do a project on developing a text-to-speech software in 15 Indian languages over a period of two-and-a-half years. Following are the monthly programmatic reports indicating the progress made in the project:

Monthly Reports

2014

		March	April	May	June	July	August	September	October	November	December

2015

January	February	March	April	May	June	July	August	September	October	November	December

2016

January	February	March	April	May	June	July	August

Training Programmes

Following are the reports of the training programmes that were conducted across several locations in India:

15 days Training in Basic Computing with use of NVDA and eSpeak in Hindi (April 10; 2015).
15 days Training in Basic Computing with use of NVDA and eSpeak in Gujarati (April 16, 2015).

15 days Training in Basic Computing with use of NVDA and eSpeak in Oriya (April 30, 2015).
eSpeak Tamil Computing with NVDA (May 4 – 8, 2015).
Training in Basic Computing with use of NVDA and eSpeak in Assamese (May 9 – 10, 2015).
Training in the Use of eSpeak for Indian Languages during TOT (May 11 – 20, 2015).
Tamil Language (May 25 – 29, 2015).
Training on the Use of eSpeak Hindi on Windows and Android Platforms (May 28, 2015).
Report on 30 Days Summer Course on Basic Computer Competencies and Language Proficiency (May 1 – 30, 2015).
Tamil Computing with NVDA Training Workshop (Organized by NVDA team: Anne Jane Ask with Higher Secondary School for the Visually Impaired, Palayamkottai, Tirunelveli; June 3 – 7, 2015).
Report on eSpeak Tamil Computing with NVDA Training Workshop in Tirunelveli (Organized by NVDA team; Anne Jane Askwith Higher Secondary School for the Visually Impaired, Palayamkottai, Tirunelveli; June 3 - 7, 2015).
Training in eSpeak Marathi (Organized by NVDA team; National Association for the Blind; Nashik; June 22 - 23, 2015).
Training in eSpeak Marathi (Organized by NVDA team; SIES College, Sion, Mumbai; June 28, 2015).
Training in eSpeak Marathi (Organized by CIS; Atmadepam Society; August 22 – 23, 2015).
Training in eSpeak Hindi (Organized by NVDA team; Jeevan Jyoti School for the Blind; Varanasi; August 26 - 28, 2015).
eSpeak Training in Hindi Language (Organized by CIS and National Association for the Blind; Kullu; September 3 – 4, 2015).
Training in use of eSpeak Bengali with NVDA (Organized by CIS; Turnstone Matruchaya, Siligudi, West Bengal; September 7 – 9, 2015).
5 day TOT for Training in Use of eSpeak Kannada with NVDA (Organized by CIS, Mithra Jyoti, Enable India and NFB, Bangalore; September 21 – 25, 2015; Bangalore).
Training in the use of eSpeak Hindi with NVDA (Organized by CIS and Lakshay for the Differently Abled; September 29 – 30, 2015; Ranchi). The event was conducted online by Dr. Homiyar with local support from Mritunjay Kumar and Zainab.
Report on eSpeak with NVDA Screen Reader and Assistive Technology for Visually Challenged (Organized by National Association for the Blind, New Delhi, Centre for Differently Abled Persons, Bharathidasan University, Tiruchirappalli, and CIS; January 21, 2016; Tiruchirappalli).
Report on NVDA with E-Speak and BookShare Online Library (Organized by Karna Vidya Technology Centre, Computer and Internet Society, and CIS; February 27, 2016; Chennai).

For more details visit https://cis-india.org/accessibility/resources/cis-accessibility-work-overview

We Tested 18 Government Apps, and Most are not Fully Accessible to the Disabled

nirmita — 2016-09-03T03:32:06Z

When you wake up in the morning, the odds are one of the first things you look at is your phone. You might check WhatsApp, review the news, look at the day’s schedule, and book a taxi to work.

The article was published in Factor Daily on August 31, 2016.

The government, too, is increasingly engaging with citizens through apps such as MyGov and the Swachh Bharat. At the national and local level, these promise to improve the government’s engagement with citizens and increase their access to information.

From electoral information to agricultural news to welfare schemes, these apps promise to streamline the functions of government and allow millions of people who would otherwise have difficulty accessing these services to use them freely.

But for millions of Indians with disabilities, the convenience offered by these apps is almost negligible.

The government has made electronic accessibility one of its priorities. The 2009 Guidelines for Indian Government Websites (GIGW) laid out a set of standards to which all official government websites were to conform, inheriting the global WCAG standard.

The National Policy on Universal Electronic Accessibility, which came into force in 2013, also mandates equality of access for persons with disabilities in all government electronic infrastructure.

But do these work for people with disabilities?

The Centre for Internet and Society, with the help of an independent researcher, has reviewed 18 most popular government Android apps, and found that almost all of them have inaccessibility and usability issues for people with visual impairment.

The tests were conducted by an Accessibility Evangelist who himself is visually impaired using TalkBack, a screen reading software for Android that gives voice output of the content on the screen. We found that all but a handful of the apps are at least partially inaccessible for visually impaired persons.

We also observed that the government has a directory of websites on its GOIdirectory website. The government offers a similar directory for its apps here.

However, there are no standards or guidelines for app development as in the case of GIGW, and the webpage-based apps often do not conform to GIGW standards.

These are the apps we looked at:

MyGov by Government of India:

What it does: A social media channel of the Indian government to let users access information on government activities and spread educational content to Indian citizens.

How accessible it is: It is a purely web-based app, but the web page it loads isn’t completely accessible. The graphics in particular are poorly labeled.

The animations they use are also inaccessible, and the banner that scrolls the new announcement is completely unusable for visually impaired persons.

2. EPathshala – NCERT

What it does: A platform for accessing eBooks through mobile platforms in multiple formats, and enabling users to download, store, browse and read books.

How accessible it is: The first screen that allows language selection is not labeled properly — only the Hindi and English buttons are correctly announced. Many of the options that are available on the screen are not labeled with text, only graphics.

Even if a visually impaired person managed to download the books, it is not possible to read them, as the screen reader does not support accessing the downloaded content. The books themselves are just PDF or JPEG images, which are completely unusable by any screen reading software. In addition, the reading mode available for the books is itself inaccessible for visually impaired persons.

3. Accessible India Campaign

What it does: A platform to report accessibility issues in public buildings and spaces and an information platform for the Accessible India Campaign.

How accessible it is: Fairly accessible, Good Work!.

4. Narendra Modi

What it does: The Prime Minister’s official app delivers information and messages from the Prime Minister’s Office.

How accessible it is: Completely inaccessible. The very first screen cannot be navigated by someone who is visually impaired. If one manages to get past that somehow the controls on the rest of the app are labeled in all caps, which makes using the screen reader difficult.

If one selects the feed option and follows a topic, the controls on the content screen are all simply labelled “Narendra Modi.”
However the text is presented using standard web controls, which means that once navigated to a page can be accessed using a screen reader.

5. LIC Mobile

What it does: Delivers information about various insurance policy schemes and allows users to submit an application online.

How accessible it is: The app is accessible until the point of login and account creation. The information in the customer policy credentials is not presented in an accessible format. The agent portal needs further testing as well. In addition, the use of graphical captchas is inaccessible for those with visual impairments. A captcha in a different format would have been more logical.

6. MyGov Move

What it does: Allows users to register and volunteer for various government initiatives in government-run elementary schools that lack resources.

How accessible it is: Except for the text heading, none of the controls are labeled. Some controls are accessible to persons with low vision as the text in the button graphics is quite large. However, they are still graphical and not text-based, and so cannot be used by the screen reader. The national symbol is also not labeled.

7. IFFCO Kisan Agriculture App

What it does: Allows farmers to access customized agricultural information and services including weather forecasts, agricultural advisory information, best practices and tips, and a platform for buying and selling goods.

How accessible it is: It is accessible not just in English but also in Hindi. There are some minor errors, such as Delhi not being listed as a state or certain buttons not being correctly labelled, as well as the list of languages lacking support in the native script of that language. However, overall it is one of the more accessible apps reviewed.

8. mPassport Seva

What it does: Allows citizens to access information, schedule appointments, and view updates related to all passport-related services.

How accessible it is: Decently accessible, except for the appointment scheduling function, which uses a captcha. The buttons in the app are also not labelled in an accessible format. Several text fields also use all capitals, which causes the screen reader to spell the word instead of pronouncing it.

9. IRCTC Connect

What it does: Lets users check train schedules, manage ticket booking and plan journeys.

How accessible it is: The very first screen that asks the user to select between various sub-services is completely inaccessible, with no text labeling available. However, once past that screen, most of the other services, such as ticket booking and PNR status checking, are fairly accessible. Many options still use all caps, which makes screen readers spell words rather than pronounce them.

Another issue is that selecting a particular option causes the displayed content to change, but the focus moves to the top of the screen, requiring another round of navigation when using a screen reader.

10. MyGov

What it does: A citizen participation platform that allows users to discuss their views on various issues and make suggestions directly to ministries and other government organisations.

How accessible it is: Some controls are labeled with text and can be used with screen readers, but several other buttons are labeled graphically or are difficult to navigate in accessible ways due to poor focus/tab order.

There are many videos available through the app but no transcripts of these talks are available.
The focus while navigating the app is highly inconsistent and makes its use very inconvenient. The main navigation menu is also inaccessible.

11. Swachh Bharat

What it does: Provides information and lists events relating to cleanliness drives across the country.

How accessible it is: The starting screen of this app is cluttered with controls and information, making it difficult to navigate with a screen reader. A few controls are labelled with text, but the majority are inaccessible.

12. Aadhaar Mobile

What it does: Enables users to download and share their details as they are stored in the UIDAI database.

How accessible it is: The first screen lacks alternate text for any of the controls and graphics. The user could not register their Aadhaar card in order to continue testing the app.

13. India Post Mobile Banking

What it does: Offers financial information and transaction services for India Post banking customers.

How accessible it is: The initial screen controls are accessible. However, the user was unable to successfully login to conduct further tests.

14. Swachh Delhi — Official App

What it does: Allows residents of Delhi to report waste and garbage dumps around the city.

How accessible it is: All major features of the app are accessible. However, the reporting function requires a user to use their phone’s camera app, which may be prohibitive for visually impaired persons. It would have been preferable to allow users to simply report a location without requiring a picture as well.

15. Swachhata: MoUD

What it does: Allows users to register complaints with the local municipal body about trash or waste in their neighbourhoods.

How accessible it is: A permissions error led to the user being unable to access the app.

16. All India Radio Live

What it does: Offers streaming of public service, entertainment and informational content in Hindi, Urdu and other major regional languages.

How accessible it is: The app is completely inaccessible. A user can select a channel, but further controls on the screen lack labels or consistent focus.

17. DD News

What it does: Provides live streaming, video feeds and news updates from DD-News in English and regional Indian languages.

How accessible it is: Minimal use of graphics and clear labelling mean that the app is generally easy to navigate. However, the videos available through the app do not have supplementary text descriptions.

18. AIIMS@Delhi

What it does: Allows patients of AIIMS to view and manage their medical history, book appointments, and contact medical professionals.

How accessible it is: The app is simple and uses standard controls, which are generally large and well labelled, making navigation and reading for visually impaired persons comfortable. User lacked the UHID necessary for further testing.

For more details visit https://cis-india.org/accessibility/blog/factor-daily-august-31-2016-nirmita-narasimhan-we-tested-18-government-apps-most-are-not-fully-accessible-to-disabled