Centre for Internet and Society

UNESCO Global Report: Opening New Avenues for Empowerment

nirmita — 2013-09-04T07:21:56Z

We prepared a report on higher education for persons with disabilities in the Asia-Pacific region for UNESCO some time back. The report has been compiled into a global report. Nirmita Narasimhan was the project coordinator from the Centre for Internet and Society.

Preface

(by Irina Bokova, Director General of UNESCO)

Over one billion people – approximately 15 percent of the world’s population – live with some form of disability. Facing a wide range of barriers, including access to information, education, health care and a lack of job opportunities, persons living with disabilities struggle every day to be integrated into society.

This is unacceptable, and UNESCO is taking a stand. To tackle these challenges, UNESCO has led a number of initiatives, including the 2013 Global Report, to empower persons with disabilities thanks to information and communication technologies. Our position is clear – information and communication technologies, along with associative technologies, can widen access to information and knowledge, so they must accessible to all.

Building on the United Nations Convention on the Rights of Persons with Disabilities, the Global Report addresses strong recommendations to all stakeholders – from decision-makers to educators, civil society and industry – on how concretely to advance the rights of people living with disabilities. These recommendations draw on extensive research and consultations. Studies launched in five regions have allowed UNESCO to understand more clearly the conditions and challenges faced by persons with disabilities around the world.

To empower persons with disabilities is to empower societies as a whole – but this calls for the right policies and legislation to make information and knowledge more accessible through information and communication technologies. It calls also for applying accessibility standards to the development of content, product and services. The successful application of such technologies can make classrooms more inclusive, physical environments more accessible, teaching and learning content and techniques more in tune with learners’ needs. We need the commitment of all Government and stakeholders to make this a reality for all persons living with disabilities. To build the inclusive knowledge societies we need for the century ahead, we cannot leave anyone aside. We must do everything to replace exclusion and discrimination with inclusion and empowerment – for this, we must harness the full power of information and communication technologies. This is our shared commitment, and this Global Report will help us move forward.

Forward

(by HE Mr. Miguel Angel Estrella, UNESCO Goodwill Ambassador)

Communication and information are essential for the development of people and societies. It is thanks to the networks of connections which are established freely between individuals that a society is able to advance, as well as the personal development of individuals which makes it possible to increase the collective benefit of all those who form a society. In light of this, special attention should be paid and necessary products and services should be created for persons with disabilities. The more totalitarian and repressive societies are, the more restricted access to information and knowledge is, as well as the application of rights to self-expression and opinion. In addition, special services and attention for the common good of society are limited. However, when a society is free and respectful of human rights, individuals have more solidarity, are open to work together and share information. As a consequence of this free exchange of information and knowledge, it should be possible to build a more inclusive society which can fully participate in the social, cultural and economic life, intellectually and culturally rich, and where people with different
abilities, can take full advantage of Information and Communication Technologies.

Access to information and knowledge allows humans to contribute to social development where he or she can make better choices, and to share the richness with those around them. The conditions, special capacities and abilities of each individual to learn should never be an obstacle or an impediment to their individual development. On the contrary, it is the duty of all authorities to establish an enabling environment and provide special services to those who require them, keeping people with disabilities in mind. Such an inclusive society ensures that each person is valued as an equal human being.

I, therefore, warmly welcome UNESCO’s publication titled “Opening New Avenues for Empowerment: ICTs to Access Information and Knowledge for Persons with Disabilities” which not only makes a major contribution to our understanding of disability, but also highlights technological advancement and shares good practices that have already changed the lives of people with disabilities. The publication also makes concrete recommendations for action at the local, national and international levels, targeting policy and decision makers, educators, IT&T industry, civil society and certainly persons with disabilities, which, I hope, will receive your deserved attention!

Acknowledgements

This Global Report, Opening New Avenues for Empowerment: ICTs to Access Information and Knowledge for Persons with Disabilities, has been commissioned by the UNESCO Communication and Information Sector. It is a result of collaborative action among many researchers, public and private organizations, governmental bodies and civil society, and appreciation is extended to each of them.

The Report is based on the findings of five UNESCO regional studies carried out with the help of the following institutions and coordinating authors:

Africa: Mr Raymond Lang, Dr., the Leonard Cheshire Disability and Inclusive Development Centre, University College, London (UK);

Arab Region and North Africa: Mr Mohamed Jemni, Professor of ICT and Educational Technologies, Head of Research Laboratory UTIC, University of Tunis (Tunisia);

Asia Pacific: Ms Nirmita Narasimhan, Project Coordinator, Centre for Internet and Society (India);

Eastern Europe and Central Asia: International Consulting Agency- Mezhvuzkonsalt (Russian Federation);

South America, Central America and Mexico and the Caribbean: Ms Pilar Samaniego (South America);
Ms Sanna-Mari Laitamo and Ms Estela Valerio (Central America and Mexico); and Ms Cristina Francisco (The Caribbean).

The principal author of this global report is Mr Michael Blakemore, Emeritus Professor of Geography at the University of Durham (UK), who is a UK’s Bologna Expert (Higher Education Reform and Innovation) with the European Commission.

The overall preparation of the world report, regional studies and coordination of the project were ensured by Ms Irmgarda Kasinskaite-Buddeberg and Mr Davide Storti from UNESCO’s Communication and Information Sector.

UNESCO thanks the GAATES Foundation for its contributions and advice to the preparation of this report, particularly Ms Cynthia Waddell and Ms Betty Dion. Thanks also to Mr Jonathan Avila from SSB Bart Group

UNESCO wishes to acknowledge the many individual contributors, experts, and advocates, who assisted in the gathering of survey data and in the preparation of the regional studies.

All those contributing their expertise and time to the peer review also deserve recognition. They include: Axel Leblois (G3ict), Luis Gallegos (Ambassador of Ecuador to the United Nations in Geneva, Switzerland), David Andrés Rojas M. and Vanessa Ramirez (The Trust of America, TRUST ), Shadi Abou-Zahra (W3C/WAI), Bernhard Heinser (DAISY Consortium), Jan A. Monsbakken and Uma Tuli (Rehabilitation International, RI), Karsten Gerloff (Free Software Foundation Europe), Brian Nitz (Oracle), Kiran Kaja (Adobe), Katim S. Touray (Free Software Foundation for Africa), Sophie Gautier and Charles-H. Schulz (LibreOffice), Luiz M. Alves dos Santos (European Commission, EC), Arnoud van Wijk (Real-Time Task Force), Reinhard Weissinger (International Organization for Standardization, ISO), Kenneth Eklindh (UNESCO), Simon Ball (JISC TechDis).

The global summary report was edited by Ms Alison McKelvey.

Click to read the full report here.

For more details visit https://cis-india.org/accessibility/blog/opening-new-avenues-for-empowerment

Banking and Accessibility in India: A Report by CIS

nirmita — 2013-08-13T04:00:19Z

The report gives an analysis of banking accessibility for persons with disabilities in India. Besides a detailed look at the legal provisions and guidelines on banking and technology, the report also provides a view on different disabilities in relation to banking and accessibility in India and contains case studies and guidelines from countries such as New Zealand, Australia, the United States of America, Canada and the Netherlands. The report sums up the analysis with suggestions and recommendations to improve banking accessibility for persons with disabilities in India.

Executive Summary

India is a signatory to the United Nations Convention on the Rights of Persons with Disabilities (CRPD), and has an obligation to provide equal opportunities and facilities to everyone, irrespective of any disabilities they might suffer from. This is guaranteed in the right to equality and the right to life, which are enshrined in the fundamental rights in the Constitution of India. There are specific Reserve Bank of India (RBI) notifications that mandate banks to offer banking facilities in a non-discriminatory manner to all customers. Nevertheless, there are many problems faced by people with disabilities while accessing banking and financial services in India. For instance, many banks and Automated Teller Machines (ATMs) are not physically accessible, staff has no training or expertise in dealing with customers who have special needs, and despite the existence of technology, and ATMs are not equipped to be used by people with disabilities.

There are several international guidelines which can be referred to while formulating policy on banking accessibility, such as guidelines on ATM construction and modification (USA) and guidelines on making websites accessible for people with disabilities (the Web Content Accessibility Guidelines), as well as voluntary standards that have been taken up by banking associations in countries like Australia and New Zealand in order to make banking more accessible to people with disabilities and the elderly population.

The adoption of accessibility features and technologies in Indian banks today is very low, despite there being a legislative as well as executive push for the same. Banks which do not follow these guidelines are not meeting their legal requirements, and it is important for them to understand not just their obligations, but also the benefits that will accrue to them if they follow the suggested guidelines. To that end, this report looks at the current notifications and guidelines that govern this area, the problems faced by people with disabilities, and looks at guidelines from other countries to suggest solutions that can be incorporated by different banks in India.

Introduction

As per the 2001 Census, there are around 2.19 crore persons with disabilities in India. They constitute 2.13 per cent of the total population of the country.[1] This includes persons with visual, hearing, speech, locomotor and mental disabilities. Despite these numbers, there is a lack of understanding of their needs, and people with disabilities face a number of obstacles when it comes to living a normal life, and availing banking facilities is a big part of the problem. Consider the fact that only 50 out of the 1.04 lakh Automated Teller Machines (ATMs) in India are accessible to people with disabilities.[2] There is a general lack of infrastructure and awareness in India that permits people with disabilities to use banking services. This translates to problems not just in accessing a physical bank and seeking help from a bank official, but also extends to accessing services such as ATM machines and online banking options. The problem is exacerbated by the fact that around 75 per cent of persons with disabilities live in rural areas, and only around 49 per cent of the disabled population is literate and only 34 per cent is employed.[3] Although one may find some rare cases of disabled-friendly banking options in the metros, in the rural areas, there are neither facilities nor is there any sensitisation towards meeting the needs of the disabled.

India is a signatory to both the United Nations Convention on the Rights of Persons with Disabilities, 2006[4] (hereinafter, “UNCRPD”) and Biwako Millennium Framework towards an Inclusive, Barrier-free and Rights-based Society for PWDs in Asia and the Pacific, 2002[5] and thus has an international obligation to ensure equal access to all members of the population. This obligation extends to giving people with disabilities the right to conduct banking services. This has been recognised by several Reserve Bank of India (RBI) directives as well, although these guidelines have not been fully implemented so far.

Currently, it is very difficult for people with disabilities to use banking services in India. If a person who has a hearing disability walks into a branch for a home loan, the branch does not have a person who can understand or interpret sign language. More usually, the branch does not even have the resources or knowledge about whom to contact to facilitate the interaction by interpreting. These obstacles mean that a person with disability/ies always has to latch on to someone who is fully capable to help them. Without such help in the form of guarantors or co-borrowers who are fully capable, the chances of obtaining finance from the banks are low because bank's probably give a person with disability/ies a much lower credit rating based on their own internal criteria. These determinations automatically put the disabled at a disadvantage. A person with a learning disability, for example, dyslexia, will face severe difficulty filling out an application form (or any document for that matter) and banks are not disabled friendly in terms of the attitude of the staff towards such difficulties.

Making banking accessible for people with disabilities is both a best practice that should be followed, as well as a sound commercial decision. There are a large number of people in India with differing levels of disability, who would benefit from using banking services. Additionally, the number of people will only increase with time as India’s young population grows old, since incidence of disability increases with age.[6] The Internet, above all, is a tool for people with disabilities to bridge the differences between them and others, and all efforts must be made to ensure that they are not at a disadvantage when it comes to using services such as net banking. There is also the consideration that improving accessibility improves access for all users, and makes it possible for them to make use of more services. A lot of accessibility issues (such as the physical accessibility to branches and ATMs, signature mismatches due to hand tremors or strokes) are common to the disabled, the elderly and those with neurological conditions. Taken together, this constitutes a significant percentage of the customer base — so these issues should be addressed by banks for that reason alone.

This report will look at the legal imperatives that govern accessibility in banking services in India, and look at the various problems being faced by people with disabilities when trying to use banks. It will also look at sample guidelines from other countries and suggest best practices for banking institutions, as well as take a look at the various costs that could be incurred in trying to make their banks more accessible.

The scope of this report is restricted to covering only basic banking services in India, and other financial services, such as insurance and loans, have not been dealt with.

Legal Imperatives

The rights of persons with disabilities have been recognised under various legal instruments, and it has been established that they are to be given the same services and privileges as other members of society.

Constitutional Provisions

Part III of the Constitution of India, which deals with the fundamental rights of citizens, recognizes the principle of equality of all people. Article 14 states that the government must accord equal protection of the law to any person within the territory of India.[7] This recognition of the importance of non-discrimination means that the state must ensure that people with disabilities do not suffer disadvantages when it comes to accessing public services.

Article 15, which deals with prohibition of discrimination on various grounds states that no citizen is to be subject to any disability, liability or restriction with regard to access to shops, public restaurants, and other public places.[8]

It is evident that this important constitutional protection extends to people with disabilities, and it is their right to gain equal and accessible access to all manner of services, including banking.

Legislation dealing with Disability

There are several national laws that deal with the rights of people with disabilities, though not all of these laws have a direct bearing with banking.

The Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995

The Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995 (“the PWD Act”) was enacted to give effect to the proclamation on the full participation and equality of people with disabilities on both central and state governments. The PWD Act has been enacted under Article 253 of the Constitution.[9] It has several provisions for people with disabilities, including education, employment, creation of barrier free environment, social security and similar overlooked areas. It provides for a three tier arrangement:

For evolution of policy for the benefit of persons with disabilities Implementation of the provisions of the Act and laws, policies, etc., and monitoring implementation and redressing grievances.

The implementation of the Act relies on collaboration between the appropriate governments, which includes various central ministries and departments, state and union territories, and local bodies.[10]

Chapter VIII of the Act deals with non-discrimination, and one of the measures it recommends is making buildings accessible by simple measures such as curb cuts and slopes in the pavements for wheelchair users.

There are several problems with the enactment.[11] The terms "accessibility" and "disability" are not clearly defined. They are also not provided as a matter of right but are based on the economic capacity of the service provider. It also fails to consider the access to services and information. However, public banks need to be conscious, since they will usually be considered to have sufficient economic capacity, and might be bound to deliver their services to people with disabilities. This has often become an issue in other jurisdictions as well. In 2009, the Royal Bank of Scotland, for example, was forced to pay extensive damages to a disabled student who was unable to access the bank due to a lack of wheelchair lifts.[12]

The National Trust for the Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities Act, 1999

The trust is intended to give complete care to people with mental retardation and cerebral palsy, and also manage the properties bequeathed to the trust. The trust supports programmes that promotes independence and address the concerns of these special persons, especially the ones who do not have family support. The trust is also empowered to receive grants, donations, benefactions, requests and transfers.[13]

The Mental Health Act, 1987

The Act consolidates and amends the law relating to the treatment and care of mentally ill persons, in order to make better provisions with respect to their property and affairs, and other incidental matters.[14]

The Rehabilitation Council of India Act, 1992

The Act was created to provide for the constitution of the Rehabilitation Council of India for regulating training of the rehabilitation professionals and maintaining of a central rehabilitation register. It also regulates the recognized rehabilitation qualifications, and prescribes minimum standards of education.[15]

RBI Notifications

The most important resource when it comes to banking guidelines is the RBI, which comes out with regular notifications. The RBI has been conferred wide powers under the Banking Regulation Act, 1949 (BRA),[16] under which it can supervise and control the various banking companies, and they are bound to follow its directions. Section 35A of the Act specifies that in public interest or in the interest of banking policy, the RBI can issue such directions as it deems fit, and the banking companies or the banking company, as the case may be, shall be bound to comply with such directions.[17]

RBI has released several notifications dealing with the rights of the disabled.

Circular on grant of banking facilities to the visually challenged

In its Circular DBOD. No. Leg BC. 91 /09.07.005/2007-08 dated June 4, 2008,[18] the RBI mandated that banking facilities (including cheque book facility, operation of ATM, locker, etc.) cannot be denied to the visually challenged as they are legally competent to contract.

In the notification, the RBI recalled the order of the Chief Commissioner for Persons with Disabilities, which had earlier been passed by the Indian Banks’ Association (“IBA”) to its member banks. The Order instructed that banks should offer all the banking facilities including cheque book facility, ATM facility and locker facility to the visually challenged and also assist them in withdrawal of cash. This order has reiterated that there can be no denial of services just because there is an apprehension of risk in operating or using the facility; it said that a similar security threat exists for all members of the population.

As per the RBI notification, the banks are therefore bound to:
Ensure that all the banking facilities such as cheque books are offered to the visually impaired without any discrimination. These facilities should include third party cheques, ATM, net banking, locker, retail loan and credit card facilities.

Advise their branches to render all possible assistance to the visually impaired for availing the various banking facilities.

Circular on making ATMs accessible

The RBI had been receiving several suggestions to make branches and ATMs easily accessible to people with disabilities by providing ramps so that wheel chair users can access them and the height of the machine is also appropriate for them. It had also been receiving suggestions for installing speaking software and key pads with letters in Braille to facilitate use by persons with visual impairment. After considering these suggestions, the RBI passed a notification, directing the banks to implement such measures.

As per its Circular DBOD. No. Leg BC. 91 /09.07.005/2007-08 dated June 4, 2008, RBI has directed all banks to provide:

Ramps to ATMs: Banks have to take necessary steps to provide all existing ATMs or future ATMs with ramps so that wheelchair users or persons with disabilities can easily access them and also make arrangements in such a way that the height of the ATM does not create an impediment in its use by a wheelchair user.
Ramps at bank entrances: Banks may also take appropriate steps including providing ramps at the entrance of the bank branches so that the persons with disabilities or wheelchair users can enter the bank branches and conduct business without much difficulty.
Accessible ATMs: Banks should make at least one third of new ATMs installed as talking ATMs with Braille keypads and place them strategically in consultation with other banks to ensure that at least one talking ATM with Braille keypad is generally available in each locality for catering to needs of visually impaired persons.
Information about the ATMs: Banks should also bring the locations of such talking ATMs to the notice of their disabled customers.

Circular on implementation of the guidelines

These guidelines were strongly reiterated as recently as September 5, 2012, where the RBI by its notification numbered DBOD.No. Leg.BC. 38/09.07.005/2012-13[20] highlighted the abovementioned circulars. It said that it had been brought to their notice by the Office of the Chief Commissioner for Persons with Disabilities that visually challenged persons are facing problems in availing banking facilities like internet banking.

Banks were advised under this notification to strictly adhere to instructions contained in the above circulars and extend all banking facilities to persons with blindness, low-vision and other disabilities.

Circular on guardianship certificates

The RBI, by its Master Circular DBOD.No.Leg.BC.9/ 09.07.006/ 2009-10[21]dated July 1, 2009 on Customer Service, directed banks to accept guardianship certificates issued by local level committees set up under the National Trust Act, enabling persons with disabilities like autism and cerebral palsy to open and operate accounts. Banks were advised to rely on the guardianship certificate issued either by the district court under the Mental Health Act or by the local level committees under the National Trust Act for the purposes of opening and operating bank accounts[22] by the legal guardians for people with disabilities that is covered under the Act. Banks were also advised to ensure that their branches give proper guidance so that the parents or relatives of the person with disability/ies do not face any difficulties in this regard. It has also directed that information about the opening of such bank accounts be displayed conspicuously, in both English as well as the regional language, in its circular RBI /2009-10/142.[23] This notification was in response to a Delhi High Court decision that directed banks to put up such information.

Banks are therefore directed to:

Accept guardianship certificates: Banks can accept certificates issued by local level committees set up under the National Trust Act or district court under the Mental Health Act, so that persons with disabilities like autism and cerebral palsy can open and operate accounts.
Provide assistance: Banks should ensure that their branches give proper guidance so that the parents or relatives of the person with disability/ies do not face any difficulties.
Display information: Banks should ensure that information about the opening of such bank accounts be displayed conspicuously, in both English as well as the regional language.

National Policy on Disability

The National Policy for Persons with Disabilities, which was published in 2006, recognizes the extent of problems faced by the disabled in India. The report also discusses the number of citizens who are affected by disability: “According to the Census 2001, there are 2.19 crore persons with disabilities in India who constitute 2.13 per cent of the total population. This includes persons with visual, hearing, speech, locomotor and mental disabilities. Seventy five per cent of persons with disabilities live in rural areas, 49 per cent of disabled population is literate and only 34 per cent are employed. The earlier emphasis on medical rehabilitation has now been replaced by an emphasis on social rehabilitation. There has been an increasing recognition of the abilities of persons with disabilities and emphasis on mainstreaming them in the society based on their capabilities.”[24] The policy endorses accessibility and says that a barrier-free environment enables people with disabilities to move about safely and freely, and use the facilities within the built environment. In the principle areas of intervention identified by the policy, it ensures that banking services are made barrier free and accessible.[25]

The National Policy is intended to inform the disability plan to be incorporated in the 11th Five Year plan,[26] which will have a timeline and funds for programmes which can be allotted through the Finance Commission.

Explaining Disabilities

There are many problems faced by people with disabilities when they consider banking and financial services. From the very beginning, banks are a complicated route to charter for people with disabilities. Banks often resort to complex schemes and pricing systems, which can be difficult to understand for people with cognitive disabilities.[27] Finding bank branches and ATMs in their neighbourhood which are disabled-friendly and can be accessible to them is another difficulty, especially in a place like India where finding information is often a problem. There might be problems with physical accessibility — lack of ramp which makes it impossible for a wheelchair-bound person to use a bank or uncomfortable height of an ATM which makes it unwieldy for a wheelchair-bound person to access it — which can extend to the virtual realm as well: if a bank’s website is not complying with the standards for web-accessibility (discussed below) and is difficult to use by people with disabilities, they will be unable to take recourse to internet banking, as well.

In many countries such as Australia[28] there is great reliance on phone banking, which can be especially helpful to blind customers, or on audio-based telephone devices, which can be used by deaf-blind or the deaf customers. However, neither technology is at present available in India; text-based alternatives or spoken prompts (TTY based telephone banking) are not used by any banks. It is therefore essential that if a customer is using the interactive voice response (“IVR”) system of a bank and speaking to a bank representative on the phone to get a transaction done that the communication be clear, precise and easy to follow — as anyone who has attempted phone banking in India would testify, that is certainly not the case.

Let us take a look at some specific disabilities and what banks can do to ensure accessibility to their customers:

Problems faced by the hearing impaired while banking

When a person who cannot hear goes to a bank, the first problem they face is the fact that unless they are proficient at lip reading, they will find it difficult to communicate with the bank officials or tellers even when undertaking simple tasks like withdrawing money or depositing cheques. An important point to remember is that most hearing impaired people are more familiar with sign language than with English, and so can get confused by the complicated language used by the banks in their brochures and information booklets. If a deaf customer is communicating with the bank official by writing out instructions, it could take a longer time than other customers and they might face problems with other customers.

Another problem that might occur is that error messages or other audio cues might not be picked up by customers who are using multimedia based banking services or ATM machines.[29] This problem is exacerbated when using customer care services for banks, which are usually available only on the phone. With a lack of technological options for the hearing impaired, they are unable to access the IVR systems, or interact with customer care executives, which make it difficult for them to avail of all banking service facilities.

What can banks do?

Training: Ensure that the bank staff is sensitised to the needs of the disabled and deaf customers, and know of a sign language translator who can be called if a customer requires it.
Ease of understanding: Make the instructions — both in the physical banks as well as in ATMs and websites — simple and precise, so they are easily understood. This will help all customers, not just those with disabilities.
Technical solutions: One solution available in some countries is using a phone-to-text machine or software that enables hearing impaired customers to use the phone banking and customer care services of a bank. For example, the Royal Bank of Scotland users can use a Typetalk or BT Textdirect service which will enable them to speak to an operator and so convey their messages.[30] If a bank feels that sufficient customers will benefit from such a technology, it should invest in it.
Sign language interpretation: A more low-tech solution is to offer interpretative services, where customers who need it can be assisted by someone who is proficient in sign language to help relay their point across to the bank.

Problems faced by the visually impaired while banking

Visually impaired customers can find it difficult to navigate and even reach their banks, if the path is not clear and if the building is not provided with enough ramps and clear entrances. Even understanding the terms and conditions of banks and their services are difficult to comprehend, because the language used to describe services and procedures is confusing and complicated. Often, a booklet with the terms and conditions is simply handed over with no concern for how the person is supposed to read them. Visually impaired people might also face problems in distinguishing details on cheques and other financial instruments which, unlike currency, do not have physically distinguishable marks on them.

Visually impaired customers often face a lot of problems while using ATMs, because the keys are not marked with recognisable lettering in Braille. Even when there is a token raised symbol on the middle key or Braille markings on the keypad for tactile recognition, there is still the problem that what is being displayed on the touchscreen, as well as the instructions on how to proceed with a transaction, are not capable of being communicated. Most ATMs in India are not equipped with an audio jack, and so can’t be used by blind customers who want to connect headphones and hear the display on the screen.

There is also the problem of signature mismatches, especially when it comes to opening accounts and signing cheques. Currently the bank’s solution is to not have the person with disability/ies sign the cheque, which is not a solution that works consistently, especially when a person with disabilities is running a company. There should be a separate process in place to facilitate issuance of cheques by the visually impaired.[31]

The first and most obvious problem with the visually impaired using net banking and other services on the internet is that they won’t be able to see the screen. Similarly, when they attempt to use the ATM machines, the screen cannot be read and the keyboard functions are often unclear. The problem is often accentuated for people with low vision, because the improper lighting, low contrast print and other glares make it difficult to make out what the screen says.[32] Some sites have a security requirement where users have to input CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) codes in order to validate their payment or to register for a particular service; using such security codes can be particularly problematic for blind customers.[33] Banks websites might have pop ups or automatic music playing, which makes it difficult for the visually impaired to use their screen readers. Another problem arises in the mobile applications (“apps”) that are used by various banks; the format is not supported by screen readers on smartphones, and so customers with disabilities can’t use the facility made available to others.

What can banks do?

Training: Sensitise the staff to the needs of blind customers, and ensure that there is a customer care executive who is present when a visually impaired customer needs assistance with a particular service.
Accessible formats: Printing out bank documents or statements in large size fonts, Braille or in audio script format if required is the first thing that banks can do to assist their visually impaired customers. Banks can also try to migrate towards accessible e-text or DAISY formats for their disabled customers.
Banking Guide: Coming out with a bank note guide to help identify the different bank notes and counterfeits, if any, is also important for visually impaired people who rely on their sense of touch. Similarly, an accessible format guide that takes you through the various steps that are involved in withdrawing cash or using an ATM would greatly assist blind customers who are using a new format or type of bank machine for the first time. At the same time, increasing the screen size and resolution of ATM screens would go a long way in improving access to the customers.
Templates: Banks can also be encouraged to come out with cheque book templates, so that blind users can familiarise themselves with using such bank documents and the process of writing cheques becomes easier for them.[34] Banks should also develop a better solution to the problem of visually impaired customer’s inability to sign cheques.
Open format statements: Banks should also ensure that when they provide customers with statements, they are made available in open formats, such as HTML or RTF, so that they can easily be read by screen readers.
Technical solutions: There are some alternatives to the CAPTCHA codes available, such as audio codes or maths questions. Some sites have the option of hearing the codes, instead of just seeing them. There are also human aided accessible CAPTCHA services (such as Solona), where the customer can send a screenshot of the screen to an aide. However, this has several security and privacy implications, and so is not an ideal solution. Multimedia on the websites of banks should be made optional, with a clear possibility of turning the music or animation off, so that users can use the screen reader without any problems.
Mobile apps: Banks should work with their technology partners to ensure that their mobile apps are accessible on all devices and can be used by customers using assistive technology.
Improved ATMs: Several banks around the world are switching to ATMs which give output in multiple formats, such as audio and large-font print,[35] making them more user friendly. There are several guidelines in effect in various jurisdictions which describe better design for ATMs, which takes into account the physical needs of disabled customers; newer ATMs which are set up should be asked to conform to such standards. While this is slowly starting to take place, more banks need to expand and improve their building structures keeping such guidelines and needs in mind. This has been discussed in the next section on ATM Guidelines.
Sensitisation: Special care should be taken to explain terms and conditions to visually impaired persons — there should be an effort to ensure that the person who is opening an account has understood the various terms and conditions and not just heard them.

Problems faced by those with physical disabilities while banking

In India, a major problem is the physical accessibility of banks, with hardly any buildings being equipped with ramps and elevators; even if the bank itself is made accessible via these architectural modifications, the area surrounding the bank, for example, the market place, might be difficult to reach for people in wheelchairs, ultimately making it very difficult for them to use banks.

People with physical disabilities might find controlling their limbs for prolonged periods to be a problem, and so would find it difficult to use not just the physical banking services, but also internet services which necessitate controlling a mouse for a long period of time.

What can banks do?

Build ramps: The most important step that needs to be taken by different banking institutions is ensuring that their ATMs and branches are accessible through a ramp, so that it is physically possible to reach from the road or other public area.
Elevators: Where possible, elevators should also be provided.
Special measures: Within the bank, there should be special provisions for people in wheelchairs or crutches, such as a designated queue and teller, so that they do not have to wait in queue for a long period of time.

Problems faced by those with cognitive disabilities while banking

People with cognitive disabilities might have lower attention spans and might have problems with understanding complicated bank procedures and requirements. If the steps involved in using an ATM or other physical transactions are not logical and simple, people with cognitive disabilities will be unable to handle them. As a lot of Indian banks are rather chaotic and the transactions lack a certain consistency, people with cognitive disabilities could face a lot of problems adjusting. People who have cognitive disabilities might also be relying on their guardians or parents to assist in operating their bank accounts, and legal and bureaucratic hurdles to doing so can be a big hassle.

The front staff at banks are often improperly trained and do not have a holistic understanding of how to deal with people with disabilities. It has also been observed that while banks can be helpful while opening accounts, they are not open-minded about granting loans to people with disabilities.[36]

Customers who are autistic have hand function issues which can cause their signatures not to match the ones on record, which again causes problems when it comes to opening accounts or signing cheques which ultimately bounce.

What can banks do?

Sensitisation: Sensitise the staff to the special needs of customers with cognitive disabilities.
Display of information: Information for guardians of such customers, on the requirements for opening bank accounts, should be prominently displayed in the branches of the bank (Refer to Section 4.3.4).
Uniformity in procedures: Banks should make uniform guidelines or procedures to be followed for each transaction, so that there is a certainty and regularity that eases the way for people with cognitive disabilities.
Clear language: Banks should also ensure that they use extremely simple and clear language in all their transactions as well as literature in order to mitigate confusion.[37]
Identity establishment: There need to be rules put in place to allow those who are unable to sign properly to establish identity in some other manner.

Guidelines on Banking Services and Technology

The previous section has looked at some of the problems being faced by people with disabilities when they access banking services in India. This section will look at some guidelines and best practices which are aimed at increasing the accessibility of services.

Mobile banking

There is the possibility of accessing a variety of financial services through mobile devices, which are termed as mobile banking or “m-banking”. This accessibility means that a lot of people with disabilities who live in rural areas, who have earlier not been able to access banks, can now do so using their mobile phones. Mobile banking also makes it much easier for customers with bank accounts to access their details and do transactions — for people with disabilities, this is a big step forward, as it means they do not have to endure the hassle and inconvenience of going to a bank, where they may not find the assistance that they need.

Currently, mobile banking is not that prevalent in India; less than one per cent of current bank customers are covered under the mobile banking services.[38]

However, the growth in mobile banking transactions has shown an increasing trend. For example, in the month of June 2012, 3.43 million transactions amounting to Rs. 3067.10 million were processed, as compared to 1.41 million transactions amounting to Rs. 984.66 million processed in June 2011 — an increase of about 143 per cent in volume and approximately 211 per cent in value terms.[39]

The Reserve Bank of India has passed some operating guidelines for mobile banking transactions.[40] These guidelines specify the technology and security standards, as well as the requirements for interoperability between operators, transaction limits and procedure for grievance redressal. They also tackle customer protection issues.

Banks should leverage the flexibility and utility of mobile banking in increasing access to their customers who have disabilities, as it would mean lesser expenses for both the banks as well as the customers.

Internet banking

Internet banking is increasingly popular with customers, due to its convenience and ease of use; it removes the necessity of physically going to a bank. Since physical banks are often difficult for people with disabilities to navigate, internet banking could provide the best solution (though there are several problems with this medium as well, as have been described in the previous chapter). However, banks can make their websites more accessible and follow the prescribed guidelines to ensure a better banking experience not just for their disabled customers, but for all customers.

The biggest obstacle that comes with developing net banking options which are accessible to all is the wide diversity in the people who are trying to access the banks’ websites, and it is here that universal design comes into play. “The goal of universal design is to have each web page accessible by all people, instead of providing separate web pages for people with disabilities. This requires, for example, for people who are blind, textual equivalents for all images, and reading order and structure compatible with screen reading; for people who are deaf, visual equivalents such as captions for all audio information; and for people with motor disabilities, means to navigate the page without fine motor control.”[41]

There are a set of standards in place for website accessibility. The Web Content Accessibility Guidelines (“WCAG”) 2.0 specify the manner in which the material on any website is to be perceivable, operable, understandable and robust.[42] Under these four stated principles of web content accessibility, twelve guidelines have been given, which give the web content developers a framework and set of objectives to understand the needs of the disabled. There are also levels of conformance that are defined for each guideline, and a list of sufficient and advisory techniques has also been given.[43]

The WCAG 2.0 Guidelines includes some basic steps, such as including text alternatives for all non-text objects, including descriptors or captioning for images, audio and animated sequences, and following a style sheet wherever possible, in order to maintain a consistent design. The guidelines deal with visibility and display (using contrasting colours for background and text; using relative sizing so that the text can be increased to upto 200 per cent), functionality (providing skip links such as “Back to Top”; ensuring that animation can be paused or switched off; ensuring keyboard as well as mouse functionality), and formatting (ensuring the text is not justified; setting the language attribute of each page; providing clear navigation mechanisms; ensuring that all mark up is validated and coded correctly), amongst others.[44]

The National Informatics Centre (NIC) has developed some guidelines for government websites, which contain best practices for accessibility in website design; these guidelines were released in 2009, and are mandated for governmental websites. The guidelines are classified into three categories: mandatory, advisory and voluntary; a compliance matrix has been provided for various departments and organisations to assess their compliance with the guidelines.[45] It is crucial that banks comply with these guidelines to ensure that a certain basic minimum standard at web accessibility is met for the banking customers across all websites.

Another dimension which is unique to India is that of regional language; for banking customers who are not comfortable with English, it is recommended that bank websites be provided in major regional languages as well. The best way to display regional fonts is to use Unicode (UTF-8). Banks should ensure that Unicode is used to display the fonts, as otherwise the fonts can become garbled and a person using a screen reader will not be able to access the written material at all.

A critical guideline to be followed is that visual information should also be coupled with audio information, and that frequency and volume of the audible cues should be capable of being configured and controlled by the user.[46]

Automated Teller Machines (ATMs)

The number of ATMs and their penetration in India is very low: 63 ATMs and 497 points of sale per million population,[47] and a number of regulatory and commercial requirements have led to their relative low (though increasing) use in India. RBI has recently passed guidelines on operating White Label ATMs[48] which effectively open up most of the acquiring part of the process to non-bank independent players.[49] This should ensure that there is a greater increase in the number and penetration of ATMs in India, which will be beneficial for people with disabilities only if the ATM-makers ensure that minimum guidelines for the disabled are met with.

Currently there are no guidelines in India on how to construct ATMs in accordance with the needs of people with disabilities. However, banks can take guidelines from other jurisdictions as their guide and look at how other countries have handled the issue of making ATMs more accessible. It is hoped that this lacuna in the policy will be filled soon.

The American Department of Justice recently notified a final ruling on the standards of accessibility relating to ATMs under the Americans with Disability Act (“ADA”). Such standards range from requirements that signs be in Braille, a voice guidance system, and input controls for blind users.[50] These standards took effect in March 2011, and had a March 2012 compliance date. All ATM owners are to comply with these guidelines when constructing or altering ATMs.

Some salient features of these guidelines are:

Height and reach: It is mandated that the ATM’s reach should be between 15 and 48 inches. Further, the graphic area where the touch commands are input needs to be lowered to the desired height.
The input device should be tactile, and so the surface of the keys should be different from the base and this should be apparent by touch. The keypad should also be arranged in a standard 12-key ascending or descending layout, as seen in telephones or computers.
ATMs must be equipped with both voice guidance systems as well as Braille language signage. This would mean adding a headphone jack to the machine, so the audio is heard only by the user and thus ensuring his privacy.
The display in the ATM needs to be clear; from an observation point 40 inches above the floor in front of the machine, the letters should appear in a sans serif font, with a minimum height of 3/16 inches, in a colour contrasting to the background.
There is also a requirement of equal services, which means that all services offered at any location through a bank’s ATM must also be provided by an “accessible” ATM in the same location. For this purpose, each installation is to be considered as a separate location.

The Indian Banks’ Association (IBA) has issued a Standards document on Accessible ATMs for customers with disabilities, and has also released a work flow document to be followed by various banks. The IBA Standards documents states that:

“The fundamental principle of an Accessible ATM for development, testing and implementation purposes is to ensure a machine which enable the user to complete all transactions successfully with a blank screen simply through voice guidance for totally blind users, permit independent use through clear screen data for low vision / partially sighted users and effective physical access for wheel chair users.”

The document specifies different accessibility measures to be taken for each level of accessibility (for example: completely blind users and users with partial sight), with details about the size and measurement of various features that need to be incorporated. It also includes a workflow to be incorporated into the Speaking ATMs for the effective use by people with disabilities.

Currency

For currency to be most effective as a means of payment, all users should have barrier-free access. The ability to conduct financial transactions using bank notes is crucial to independent living.[52] Yet this can pose significant challenges for individuals who are blind or partially sighted.

Physical currency (both notes and coins) are confusing and often cannot be distinguished from each other by merely feeling them. There is a great similarity between the hundred, five hundred and thousand rupee notes, as well as in the coins which are now completely confusing. Notes should also be discernible to the colour blind, which in their current form is not always possible. Various representations have been made to the Government of India on this regard and the change required is only a small one, though no changes have so far been forthcoming.

India can learn from the example of other countries which have experimented in the past with introducing currency which is friendlier to people with disabilities. Whether it is the printing of differently coloured notes, or the development of “raised-texture tactile features,”[53] there are several alterations that can be made to the currency. In India, the bank notes come with raised texture shapes to help the visually impaired to identify the different notes, and also come in different colours, though further improvements can be made. This problem is exacerbated in the coins — earlier, there was a differentiation in shape between them, but the newly minted coins of denominations Rs. 1, Rs. 2 and Rs. 5 are all very similar, and differentiating between them is a big problem.

In countries such as Canada, development of bank notes is based on a “continuous process that relies on scientific and empirical research, together with direct feedback from bank note user groups and experts. The bank consults Canadians living with blindness and low vision, as well as their representative organizations and vision experts, to identify the needs of this community and to explore potential solutions.”[54] It is this sort of consultative process that needs to be incorporated in India as well.

Telephone Banking

Telephone banking is in its nascence in India and not all banks provide it. Furthermore, there are no guidelines in place to govern how telephone banking would take place. For people with disabilities, telephone banking could be very useful, if the proper tools are made available to them. Banks can look at the draft guidelines of other countries (refer to section 8 of the Report) which have provisions for phone banking to see what kind of procedure they should follow.

Converting to Accessibility in India

Making banking accessible is not just in the commercial interest of the bank but is also in line with its commitments under various legislation and international conventions. In India, this has even been acknowledged by the RBI, which has issued a notification[55] suggesting that at least one-third of the new ATMs of all banks must be accessible.[56] Dinesh Kaushal has studied[57] some examples, such as the Punjab National Bank, which has set up some talking ATMs in Jaipur, or the State Bank of India which in 2010 announced plans of installing 7000 talking ATMs, but there is no news on the status of this goal. Currently the bare minimum target set by RBI is also not being met.

Subsequent to the RBI notifications, some positive developments have started taking place. The Union Bank of India has indicated that it will deploy over 100 Voice Guided ATMs — which not only allows access to visually impaired people but also people with physical disabilities through ramps for wheel chair access.[58]

Half of these ATMs are to be put up in the banks, and the other half in passport offices. The ‘Talking ATM’ is designed as per Access for All (AFA) standards and comprise of accessible key pads, voice-guidance technology, Braille stickers and multi-lingual capability. When a visually challenged person attaches his headphone set to this ATM, he can hear the instruction which enables him to fill-in the required data using the numeric keypad. Apart from reading aloud screen messages, the machine provides complete orientation making it easy for the customer to use the machine. An important security feature of this ATM is that it provides the person an option to blank out the screen as a safety mechanism to avoid shoulder surfing by any bystander trying to access customer data during the transaction.[59] The bank recently completed setting up the 100th such ATM in the building of the National Association for the Blind.

The NCR Corporation India, which has a 47.5 per cent share in the country’s ATM business, has stated that it will install 50 ‘talking’ ATMs in various passport offices.[60] The company set up India’s first talking ATM in Ahmedabad for the visually impaired under the Union Bank of India initiative described above. Importantly, the managing director of the ATM company stated that while the hardware of the ATMs remains the same, the software customisations depend on the specific needs. Banks do not need to change their entire fleet of ATMs for installation of new solutions.[61]

One concern that arises when we consider questions of accessibility is: what would be the cost of altering the present technology and infrastructure? If the cost of making banking accessible is too prohibitive, it would not be in the interests of the banks to do so.

“A talking ATM is the regular ATM with an additional module that allows a blind person to get the information in audio format. A talking ATM could be configured so that when a user plugs in a headphone in the audio jack, the ATM would start talking to the person with audio messages…Installing talking ATM technology is not very expensive. It might range anywhere between Rs. 25,000 and Rs. 50,000.”[62]

There needs to be an evaluation of the present ATMs to see if merely upgrading the software would suffice in converting them to speaking ATMs — if this is the case, it can be done so with the help of the manufacturer at a low cost. The evaluation would also help the banks identify those machines which can be upgraded by the addition of some simple technology and hardware, while the others could be marked for eventual replacement. At the same time, the new machines that are set up by the banks should be audio-enabled; this should not be difficult as “all new ATM installations are audio enabled, as all major ATM manufacturers now produce talking ATMs including Triton, NCR, Wincor-Nixdorf, Diebold, and Fujitsu.”[63]

Under the Americans with Disability Act, the determination of when an undue burden is placed on an establishment which has to make its services accessible is to be determined on a case by case basis, and would be considered keeping in mind factors such as the nature and cost of the upgrades, the availability of alternatives and the resources present with the financial institution in question.[64] Such a system should be incorporated in India as well, where the ability of the bank is considered when seeing the efforts it needs to make when converting its services to make them more accessible.

Union Bank of India’s Accessible and Talking ATM has brought in many initiatives for the first time, like the use of bilingual Indian accent text-to-speech (TTS) voices in English and Hindi, accessible infrastructure for the physically disabled and complete voice guidance support for ATM operation.[65] These should set the benchmark for other banks who want to improve the accessibility of their services as per the guidelines set forth by RBI.

Case studies and Guidelines in Other Countries

Looking at the guidelines that are present in other countries can be helpful in determining how banks in India should go about improving their services. The following countries have specific provisions in place which regulate or instruct how banks should handle their disabled customers.

New Zealand

The New Zealand Banker’s Association published a set of Voluntary Guidelines to meet the needs of older and disabled customers, which aim to improve access to banking services for such customers.[66] The guidelines recognise the increasing importance of older and disabled customers to banks as well as the importance of meeting their needs and demands. The guidelines direct the member banks to give training to the staff in order to better help the disabled customers, as well as to have specific procedures in place in case financial irregularities or abuse occur in bank accounts of people with disabilities. There are directions on improving physical accessibility (such as providing for low tables, ramps in ATMs, queuing aisles wide enough for wheelchairs and so on), as well as giving specific customer care help to those who need it, such as consulting the needs of the disabled when developing new services, having a provision for a reduction in fee if some customers are unable to use certain features, and having a provision for personal banking in special cases at no additional cost.

There are also specific provisions in the Guidelines for things such as ATM construction. Section 5.9 of the Guidelines specifies the factors to be kept in mind while designing ATMs: large screens, audible output, tactile differentiation in the keys, easy prompts in clear language and so on.[67] Section 5.10 talks about improving the accessibility of online banking and how bank websites should be designed, and recommends the use of international W3C web accessibility best practice standard, the accessibility-related New Zealand e-government web standards.[68] Finally, the Guidelines also talk about basics, such as clear and large font prints in their literature, and providing information in several formats (including Braille, DVD, and audio) wherever possible, to facilitate bank use by people with disabilities.[69]

Australia

The Disability Discrimination Act, 1992 (“DDA”) makes it unlawful to discriminate against a person on the grounds of a disability.[70] The objects of the DDA include eliminating, as far as possible, discrimination against people with disabilities and promoting recognition and acceptance within the community that people with disabilities have the same fundamental rights as the rest of the community. The law is administered by the Human Rights and Equal Opportunity Commission and sets out specific areas in which it is unlawful to discriminate. These areas include accommodation, employment, access to premises, and the provision of goods, services[71] and facilities. The HREOC administers the legislation, which includes complaints handling, public inquiries, policy development and education and training. The Commission has supported the development of several voluntary guidelines that determine accessibility in the sphere of banking.

The Australian Bankers’ Association (“ABA”) has worked with the community to produce voluntary Industry Standards in 2002 which aim to improve the accessibility of electronic banking. These standards cover a range of areas: ATMs, Electronic Funds Transfer at the Point of Sale, Automated Phone Banking and Internet banking.[72]

The voluntary standards for ATMs[73] cover a broad range of topics, including their access and location, their operation, the method of swiping and removing the cards, the display, the keypad, the output, security and privacy for the users, and finally, installation and operating instructions. There is a checklist provided with the recommended detailed standards for each of the above areas.

Electronic Funds Transfer at Point of Sale[74] occurs when funds are directly transferred from a cardholder's bank account to the retailer, when the cardholder's magnetic stripe card is swiped in an EFTPOS terminal. Cardholder authentication occurs by signature or Personal Identification Number (PIN). These standards cover areas such as access and location of the EFTPOS terminals, process of swiping, inserting or removing the card, operating instructions, display, keypad and output options, amongst others. A helpful checklist has been provided for EFTPOS deployers to assess whether their machines are disabled-friendly.

The guidelines on phone banking[75]

deal with financial services which are available to the customer via the telephone, that can be used by the customer without having to converse with an employee of the financial institution. The guidelines look at certain design principles, best practices for input and navigation, output, documentation, the role of TTY Communications and Relay Operators, and dealing with timeouts and errors. Like with the other standards, a checklist with the best practices as per the guidelines has been provided.

The standards on internet banking[76]

looks at various aspects of financial transactions taking place on the internet, and prescribe guidelines for design and implementation (for example: compliance with the WCAG1.0 standards), feedback and testing of accessibility, compatibility, enhanced usability (in areas such as navigation, registration, login, information redundancy and so on), consistency and user support. A specification checklist is also provided, so that owners can comfortably see whether their site is compliant with the guidelines or not.

There is an action plan for the above four set of guidelines, to check their implementation and to identify problems and barriers that may arise in the future.[77] Though these guidelines are voluntary, it is worthwhile to consider the example of such a detailed action plan, as implementation of any sort of guidelines will only become more efficient if something like this is followed.

The Australian Banker’s Association has also come up with a set of Guiding Principles for Accessible Authentication, which recognizes that “accessibility issues need to be considered in the deployment of authentication technologies, to ensure that people with disabilities and older people are not disadvantaged… The purpose of the Guiding Principles is to provide a framework for financial institutions to help reach a workable balance between security requirements, commercial strategies and equitable access to banking products and services.”[78] The Principles aim to follow certain universal design principles, of equitable and flexible use, minimal effort, simple and intuitive design, amongst others. They are as follows:[79]

Accessibility of authentication technologies: Financial institutions should ensure that authentication technologies are accessible to all customers, or where this is not possible, a human-based alternative authentication system needs to provide equivalent amenity and convenience.
Customer convenience: All customers should be able to undertake their personal and business financial activities conveniently and safely.
Authentication planning: Financial institutions should consider the accessibility needs of customers with disabilities and older customers as part of authentication technology planning.
Authentication testing: Financial institutions should consult customers with disabilities and older customers as part of planning and testing accessibility of authentication technologies.
Registration, login and transaction procedures: Financial institutions should ensure that registration; login and transaction procedures are as accessible as possible to all customers.
Messages and error recovery: Financial institutions should ensure that online messages are unambiguous and written in “plain English” and that error recovery processes are efficient and accessible.
Staff and customer training: Financial institutions should provide relevant customer support staff with appropriate disability awareness training so they are aware of the needs of customers with disabilities and older customers. In addition, financial institutions should provide customers with information and training in the use of available authentication technologies.
Raising staff, business and customer awareness: Financial institutions should develop a strategy for enabling relevant management and staff awareness of these Guiding Principles. In addition, financial institutions should promote the availability of alternative accessible authentication technologies with their customers.
Confidentiality of customer information: Financial institutions must ensure the confidentiality of information of customers with disabilities and older customers.

United States of America

The 2010 Standards under the ADA have set out detailed requirements to make ATMs accessible, as was discussed in the previous section of the paper. These elements are considered by the Department of Justice to be Auxiliary Aids and Services (and not structural elements) and the safe harbour provision does not apply to them.[80]

Though American ATMs have been equipped with text to speech functions and have been subject to height and space requirements for many years, the new rules provide for additional security and instructional features for disabled customers.[81]

All the ATMs which come under the scope of the ruling will have to be speech enabled; further, there are specifications as to the height requirement (the machine should be between 15 and 48 inches in height). There is a requirement that the input area be not just touchscreen, and it should be tactilely discernible from the surrounding surface; the keypad should be arranged in a manner that is common and easy to remember. Instructions about the use of the ATMs should be given in Braille and equal services should be offered to all customers, irrespective of their disabilities.

Subsequent to the passing of the ruling, the American Bankers’ Association recommended that banks be aware of the legal requirements under the Americans with Disabilities Act; ABA advocated that banks make a careful audit of their existing machines, and compare them to the standards to which they need to conform. In case the machines need to be upgraded, the machine manufacturers would have to be contacted in order to make alterations, if necessary.

Canada

Canada has issued standards for “self-service interactive devices”,[82] the umbrella term under which ATMs would fall, the purpose of which is to specify minimum accessibility and usability requirements for self-service interactive devices intended for public use. The standard specifies accessibility requirements for automated banking machines (ABMs) — both stand-alone and wall mounted — and ABM sites. There are specifications which give the various minimum dimensions that must be conformed to when constructing such self-service interactive devices. However, the standards do not look at the technological aspect, specifically excluding it from their purview and giving that responsibility to the relevant authority.[83] It is interesting to note that the steering committee that ultimately led to the adoption of the standards was pulled together by the Canadian Banker’s Association, and the committee included representatives from the major Canadian banks.[84] The committee recommended that there be a mandatory requirement for audible instructions and the provision for attaching headphones to an automated banking machine; it would be the duty of the financial institution to provide the headsets to the disabled customers, along with a list of machines where they could be used. The committee also looked into the issue of the cost of making the machines and other areas more accessible, and though they were waiting for more conclusive research, they were hesitant about the prohibitive cost of major redesigns.[85]

Netherlands

In 2007, the Dutch National Forum on the Payment System produced a document in English on "Guidelines for user-friendly payment terminals". These guidelines include advice on making payment terminals accessible and easy to use for people with disabilities and older people.[86] The guidelines describe certain standardised elements of the PIN payment procedure, the user interface and advocates practical values for the same.[87] The document then goes on to specify important design principles which must be kept in mind while considering the accessibility of payment gateways and banks; the guideline is designed in such a way that if the design principles are to be kept in mind, the subsequent ergonomic principles which have been described will be easy to meet.[88]

Suggestions and Recommendations

The report illustrates that though banks are mandated to ensure that there is accessibility in banking services in India, there is still a lot that needs to be done. There are several measures that can be taken up by banks, which will not be costly and which will be especially rewarding for customers with disabilities:

Compliance with RBI Guidelines: Banks should ensure a basic minimum compliance with the guidelines set forth by RBI for increasing access to banking services as described in Section 4.3 of the Report.
Compliance with International norms: Banks also need to ensure a basic minimum compliance with international norms, such as the WCAG 2.0 standards for websites, so that people with disabilities can access the bank websites with ease.
Physical Accessibility: Banks need to ensure that as far as possible, there is at least physical accessibility to their branches — which would include building ramps, having wider lifts, and so on. Branches should, even if they cannot be located on the ground floor, at least make reasonable accommodations for the disabled, such as having a person who can assist them up to the branch or come down to meet them. Branches should be organised in an easily navigable manner and there should always be a plan for assistance in place — interpreters, special staff to assist with filling out of forms, physical assistance, and easily available information in the form of maps, diagrams, bold text explanations, etc. Banks should also focus more on creating avenues for disabled customers to use their services. This would include building usable and user-friendly voice systems, which is currently needed.[89]
Technical Solutions: Today there are many technological solutions to overcome some of the barriers faced by the visually challenged in the area of banking. Finger print identification technology[90] can be effectively explored to allow the use of thumb impressions while operating bank accounts.[91] For example, the XRCVC is in the process of developing a 'thumb print recognition software named as "e-Signs" with the help of CMC Ltd. (a TATA Enterprise) which can be applied across the banking system in partnership with the RBI to process cheques.[92] Most manufacturers now have accessible ATM models and banks must ensure that new ATMs have these models installed, and that old ATMs are retrofitted to become accessible. Banks should also work with their technology departments to ensure that their mobile apps are accessible on screen reader and other assistive technology software.

Promote the growth of banking services for people with disabilities: State and national governments should encourage opening of bank accounts by the disabled so that any funds or scholarships can be directly transferred into their account as opposed to being given to organisations which may not transfer it to the beneficiaries — this would help curb malpractices. Information on how people with disabilities can open an account — whether joint or single — and the formalities they need to fulfil should be made easily and readily available. This will encourage more people to open accounts for/with the disabled.
Adopt accessible formats for disabled customers: Banks should publish instruction manuals for ATMs as well as banking procedures in accessible formats such as Braille and DAISY. The banks can then take help of various volunteer organisations in producing and distributing the books to the relevant segments of the population. Such materials should also be made available for download, free of cost, on the bank’s website.
Training and sensitisation: Banks should not simply train and sensitise their employees and increase awareness of the various kinds of disability and the services to be provided to the disabled, but actively solicit those with special needs and make it clear that they "understand their needs" and welcome their business. Banks need to consider whether it makes sense to have separate or specially prepared paperwork for the disabled to fill out if the regular forms are difficult to read or understand.
Preferential Treatment: The Ministry of Finance should push for preferential treatment of all persons with disabilities along the same lines as the special rates of interest provided to the elderly. Public sector banks like the State Bank of India have a massive network and such visible and actively advertised preferential treatment will spread awareness not only at the bank level but in society as well. This will really encourage family members of the disabled to help them set up bank accounts and will foster independence.
“Know Your Customer” (KYC) procedures undertaken by banks should be clarified and made simpler — a one-time verification should take place rather than repeated calls, visits, questions, clarifications and summons to the office or branch.
Bank managers and staff should be proactive and watchful enough to monitor and check for abuse of power by those who are 'assisting' or administering the property and money of the disabled, who are even more susceptible to fraud than the average account holder, and therefore should be provided with stronger anti-fraud/theft services, such as more frequent SMS or email alerts for transactions.

The most important aspect[93] that financial service providers need to understand is that accessibility— goes much beyond merely providing ramps and the financial service providers do not currently understand the variety of disabilities and the issues which are tied to each kind of disability. Consider ATMs — the way they are currently designed, the machines are too high for users who are in a wheelchair and the doors themselves are inaccessible to the orthopedically challenged; ATMs have neither voice support nor compatible software for the visually challenged. Thus, a basic and fundamental change in the way banks are catering to customers’ needs to take place.

Financial service providers should be more encouraging and should engage in outreach to make it easier and more attractive for those with less capability to open and operate accounts with their parents or guardians. Financial independence and control should be offered and facilitated to the maximum extent possible.

Accessibility should not be treated as a corporate social responsibility measure by the large banks and financial corporations, but as a responsibility to be fulfilled regardless of anything else. Further, public sector banks have the biggest responsibility to implement these measures — while they employ people with disabilities because they have a reservation [94] for them, their services are not accessible to their own employees! There needs to be an effort made to ensure that the internal banking software which is used is accessible for people with disabilities and can be accessed by them using the appropriate assistive technology like screen readers.

Financial service providers should tailor accessibility solutions to address each kind of disability and the range of problems faced by the persons affected by them; they should look at best practices from around the world and implement solutions on their own steam instead of minimum compliance with the government or RBI requirements. Ultimately, making financial services more accessible will only mean that their customer base will grow. Change needs to be top-down — rules and regulations first, then training, sensitisation, and then infrastructure. Schemes and offers should be put in place to attract the disabled as customers, assure them of good and competent service without discrimination, and incentives to invest or save (by offering special schemes such as those which currently exist for women and the elderly).

Building such systems would involve learning more about the customers and their particular situations and needs, and banks can take the help of various organisations that work with the disabled in order to get a better understanding of what they need to deliver. While there are some voluntary standards that can be used as a guide,[95] the most important aspect is to keep the basics in mind: simple and clear language, audible scripts, easy and non-confusing navigation and instructions and the ability to speak to someone in case of an error; these are all elements that will go a long way in ensuring that disabled customers are more equipped to use the financial services offered by a bank.

It would be helpful if there was a monitoring or evaluating mechanism to see how far banks are complying with the standards or guidelines that have been set forth before them. There needs to be a comparative study about how far, for example, the bank websites are compliant with the WCAG Guidelines on Web Accessibility or how easy it is for people with disabilities to access the bank counters and ATMs in different branches. Such a study would give good empirical evidence and serve as the starting point for improvement on the current scenario.[96]

In the light of the above, some specific suggestions/ recommendations are made to the Department of Banking Operations in order to make banking more inclusive for persons with disabilities and senior citizens as under:

The department may consider coming out with a policy/ Code requiring all banks to make their services accessible to persons with disabilities. The Policy/ Code may also identify good practices to be followed by banks with respect to areas such as websites, ATMs, mobile and phone banking services, website accessibility and customer care.
The Department may require RBI to stringently enforce its notification regarding accessibility of ATMs
The Department may ensure that accessibility be incorporated as a key strategy in all future policies and programmes planned by the Department and is also incorporated in any existing policy which is executed by the department.
The Department may involve persons with disabilities in executing its accessibility strategy and identify goals/ targets to be achieved over the next 5 years in terms of making banking services accessible in India.

Bibliography

“Barriers to Using Automatic Teller Machines”, Tim Noonan, available at http://www.hreoc.gov.au/disability_rights/inquiries/ecom/atmpaper.htm.
“Guidelines for Accessible and Usable Web Sites: Observing Users Who Work with Screen Readers”, Mary Theofranos and Janice Redish, available at http://redish.net/content/papers/interactions.html.
“The Banking Experience: How to Make Financial Services Accessible for Blind and Partially Sighted People”, RNIB’s Handbook of Good Practices and Standards, at http://www.rnib.org.uk/aboutus/Research/reports/2012/Banking_Experience_CP.pdf.
“Website Accessibility”, available at http://www.tiresias.org/research/guidelines/web.htm.
ABA Guiding Principles for Accessible Authentication, available at http://www.bankers.asn.au/ArticleDocuments/177/ABA-Guiding_Principles_for_Accessible_Authentication.doc.aspx
John Gill, “The Markets for the Adaptation of Self Service Terminals to be Accessible by People with Disabilities”, available at http://europa.eu/information_society/activities/einclusion/docs/worshop_atm/atm_markets_report.doc
Carolyn Samuel, “Making Bank Notes Accessible for Canadians Living with Blindness or Low Vision”, available at http://www.bankofcanada.ca/wp-content/uploads/2011/08/samuel.pdf.

Glossary of Terms

ABA - Australian Bankers’ Association
ABM - Automated Banking Machines
ADA - Americans with Disability Act
AFA - Access for All
BRA - Banking Regulation Act
BT - British Telecom
CAPTCHA - Completely Automated Public Turing test to tell Computers and Humans Apart
DDA - The Disability Discrimination Act (Australia)
EFTPOS - Electronic Funds Transfer at Point of Sale
HREOC - Human Rights and Equal Opportunity Commission
HTML - Hyper Text Markup Language
IBA - Indian Banks’ Association
IVR - Interactive Voice Response
NIC - National Informatics Centre
PIN - Personal Identification Number
PWD - People with Disabilities
PWDA - The People with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995
RBI - Reserve Bank of India
RTF - Rich Text Format
TTS - Text to Speech
UNCRPD - United Nations Convention on Persons with Disabilities
WCAG - Web Content Accessibility Guidelines
XRCVC - Xavier’s Resource Centre for the Visually Challenged

Annexure 1 – Disability and Accommodations

Disability	Branch Banking	Phone Banking	Internet Banking	Payment Terminals and Kiosks	Mobile Banking
Physical Disability	Bank branches are inaccessible to people using wheelchairs, as they are not provided with ramps, and often have steps at the entrance The queuing and counter system in place is not friendly for customers with disabilities; desks are not always at a height that can be accessed by someone in a wheelchair The staff is not sensitised to the needs of customers with physical disabilities Suggested Solution: Conduct sensitisation and training programmes for the staff train them about the needs of customers with disabilities Construct ramps and walkways so that buildings are accessible by wheelchairs Ensure that the bank layout is accessible and as uniform as possible, ensuring ease of access for customers with disabilities		Using websites which are not accessible could be a problem for a person who doesn’t have full use of their limbs Suggested Solution: Ensure websites are compatible with assistive technologies, such as alternate input devices. Standards such as the WCAG should be followed	ATM entrances are not accessible for people with wheelchairs as they are not provided with ramps ATMs are often too high, and cannot be accessed by someone who is sitting in a wheelchair Using keypads could be a problem for a person who doesn’t have full use of their limbs Suggested Solution: ATMs should be provided with ramps (with the appropriate slope) that can be accessed by customers in a wheelchair ATMs should be at the appropriate height and should be designed keeping in mind the needs of people in wheelchairs	Using phone apps could be a problem for a person who doesn’t have full use of their limbs Suggested Solution: Mobile apps should have a clean interface, which is not problematic to use and which can be controlled by voice commands
Visual Disability	Branches are not laid out in a uniform manner, and are difficult to navigate for someone who can’t see The signage is not done in raised texture maps, and so can’t be accessed by someone who can’t see Coinage in India is not disabled-friendly, with the coin sizes being very similar to each other and difficult to demarcate Bank literature is not available in large print or Braille formats and so can’t be read by people with low or no vision Suggested Solution: Conduct sensitisation and training programmes for the staff train them about the needs of customers with disabilities Textured maps and signage should be made readily available at branch locations The branch layout should be simplified so that someone with a visual disability is not at a disadvantage In case the customer desires, bank literature, statements and other documents should be made available in alternate formats (eg: large print, Braille, PDF)		Websites are often not accessible using assistive technologies like screen readers, and are not navigable using non-traditional input devices Suggested Solution: Websites need to be made accessible and should comply with the Web Content Accessibility Guidelines (WCAG) which clearly specify how best to make the web interface usable for people with disabilities	There aren’t many speaking ATMs with audio jacks which can be used by people who can’t use the touchscreen The number pad display is not uniform amongst various banks, and so can be problematic for people relying on tactile memory Suggested Solution: Banks should introduce more speaking ATMs, which have an audio jack that can be plugged into a listening device, which helps a customer with visual disability use an ATM	Mobile banking apps are not accessible using phone screen reading software Suggested Solution: Phone apps need to be made accessible and should comply with the W3C Guidelines which specify how best to make the mobile interface usable for people with disabilities
Hearing Disability	Branch officials have not been sensitised to the requirements of someone who is hearing impaired, who might require them to write down their statements Sign language interpreters are not on call to help translate in case a person with disability needs them Alert and announcements in banks are usually based on sound notifications, and so can often be missed by customers with hearing disabilities Suggested Solution: Conduct sensitisation and training programmes for the staff train them about the needs of customers with disabilities Designated branches should have a sign language interpreter on call for assistance of customers with hearing disabilities Notifications and announcements, such as at a teller, should be accompanied by a visual alert as well (eg: a blinking light, or a number flashing on a screen)	There is great reliance on spoken directions and no option for a deaf customer to have a conversation about phone banking with their bank No provision for options such as text relay that can be used by deaf customers to do banking transactions The options on an automated VRS system at a bank’s call centre are often not clear and are incomprehensible Suggested Solution: Banks should attempt to introduce text relay services, which can be used by deaf customers to communicate with bank officials via the phone The VRS system should be in clear, understandable and audible tones for the ease of customers		Alerts and notifications in an ATM are usually in the form of a loud noise or a beep, which will be missed by a person with hearing disability Suggested Solution: ATMs should have a light which flashes in case of a notification, which will come to the attention of the user
Cognitive Disability	Bank literature and documents are complicated and the language is not easy to comprehend; this could be a problem for someone with a learning disability Banks have a bias against someone with a learning disability and despite rules against this, are reluctant to open account for customers with cognitive disabilities Suggested Solution: Conduct sensitisation and training programmes for the staff train them about the needs of customers with disabilities Bank documents, scheme information and so on should be in clear, easy to understand language	The options on an automated VRS system at a bank’s call centre are often not clear and are incomprehensible Suggested Solution: The VRS system should be in clear, understandable and audible tones for the ease of customers

Annexure 2 – Banking and Accessibility Guidelines

Area of Banking	Guidelines/Recommendations
Mobile banking	Web Accessibility Initiatives international guidelines on mobile accessibility: http://www.w3.org/WAI/mobile/
Internet banking	The Web Content Accessibility Guidelines lay down the principles for making websites more accessible for people with disabilities: http://www.w3.org/TR/WCAG/ Australian Industry Standards for Electronic Banking: http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking- Royal National Institute for the Blind’s Good Practices and Standards for Electronic Banking: www.rnib.org.uk/aboutus/Research/reports/2012/Banking_Experience_CP.pdf
ATMs and payment kiosks	Americans with Disabilities Act ATM Standards, 2010: www.firstdata.com/downloads/thought-leadership/atm_ada_accessibility.pdf Australian Industry Standards for ATMs: www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/ATM-Standard Canadian Guidelines on Self Service Interactive Devices: A summary is available at “Standard B651.1-09”, sourced from http://hub.eaccessplus.eu/wiki/Canadian_standard_for_accessible_design_for_automated_banking_machines Dutch Guidelines on Payment Terminals: http://hub.eaccessplus.eu/uploads/a/a1/Dutch_Guidelines_on_payment_systems.pdf
Phone Banking	Australian Industry Standards for Automated Phone Banking: http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/Automated-Telephone-Banking-Standard
Branch Banking	New Zealand Banker’s Association Voluntary Guidelines on Meeting Needs of Older and Disabled Customers: http://www.nzba.org.nz/banking-standards/code-of-banking-practice/voluntary-guidelines-to-assist-banks-to-meet-the-needs-of-older-and-disabled-customers/

[1]. Data taken from http://www.disabilityindia.com/html/facts.html.

[2]. “NCR Corp to set up 50 Talking ATMs in Post Offices”, available at http://lflegal.com/2012/09/ncr-india/.

[3]. More data on disability can be seen at the World Bank Country Profile on Disability for India, available at http://siteresources.worldbank.org/DISABILITY/Resources/Regions/South%20Asia/JICA_India.pdf.

[4]. Full text available at http://www.un.org/disabilities/default.asp?id=259.

[5]. Full text available at http://www8.cao.go.jp/shougai/english/biwako/contents.html.

[6]. See generally: “Guidelines for Accessible and Usable Web Sites: Observing Users Who Work with Screen Readers”, Mary Theofranos and Janice Redish, available at http://redish.net/content/papers/interactions.html, last viewed on July 26.

[7]. Article 14: Equality before law - The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India (Prohibition of discrimination on grounds of religion, race, caste, sex or place of birth).

[8]. Article 15. Prohibition of discrimination on grounds of religion, race, caste, sex or place of birth
(1) The State shall not discriminate against any citizen on grounds only of religion, race, caste, sex, place of birth or any of them
(2) No citizen shall, on grounds only of religion, race, caste, sex, place of birth or any of them, be subject to any disability, liability, restriction or condition with regard to
(a) access to shops, public restaurants, hotels and palaces of public entertainment; or
(b) the use of wells, tanks, bathing ghats, roads and places of public resort maintained wholly or partly out of State funds or dedicated to the use of the general public

[9]. Article 253: Legislation for giving effect to international agreements - Notwithstanding anything in the foregoing provisions of this Chapter, Parliament has power to make any law for the whole or any part of the territory of India for implementing any treaty, agreement or convention with any other country or countries or any decision made at any international conference, association or other body.

[10]. For more details on the legislation, along with the full text, refer to http://socialjustice.nic.in/policiesacts3.php.

[11]. See generally: www.accessability.co.in/access/files/Accessibility-in-India-Issues-Status-Way-Forward.pps.

[12]. “Bank loses accessibility case”, available at http://www.fm-world.co.uk/news/fm-industry-news/bank-loses-accessibility-case/.

[13]. Singh, A. & Nizamie, S.H. (2004) Disability: the concept and related Indian legislations. Mental Health Reviews, accessed from http://www.psyplexus.com/mhr/disability_india.html on September 11, 2012.

[14]. Id.

[15]. Id.

[16]. Full text of the legislation is available at The Banking Regulation Act, 1949, http://indiankanoon.org/doc/1129081/

[17]. Section 35A: Power of the Reserve Bank to give directions-
(1) Where the Reserve Bank is satisfied that-
(a) in the public interest; or
(aa)in the interest of banking policy; or
(b) to prevent the affairs of any banking company being conducted in a manner detrimental to the interests of the depositors or in a manner prejudicial to the interests of the banking company; or
(c) to secure the proper management of any banking company generally; it is necessary to issue directions to banking companies generally or to any banking company in particular, it may, from time to time, issue such directions as it deems fit, and the banking companies or the banking company, as the case may be, shall be bound to comply with such directions.
(2) The Reserve Bank may, on representation made to it or on its own motion, modify or cancel any direction issued under sub- section (1), and in so modifying or cancelling any direction may impose such conditions as it thinks fit, subject to which the modification or cancellation shall have effect.

[18]. Available at http://rbi.org.in/scripts/NotificationUser.aspx?Id=4226&Mode=0

[19]. Available at http://rbi.org.in/scripts/NotificationUser.aspx?Id=4923&Mode=0

[20]. Available at http://www.rbi.org.in/scripts/BS_CircularIndexDisplay.aspx?Id=7548

[21]. Available at http://rbi.org.in/scripts/BS_CircularIndexDisplay.aspx?Id=5071.

[22]. “Banking Made Easier for People with Disabilities”, available at http://www.autism-india.org/india_legal.html.

[23]. Available at http://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=5248.

[24]. National Policy for Persons with Disability, available at http://www.socialjustice.nic.in/nppde.php?format=print.

[25]. Principle Areas of Intervention VI (x): “Banking system will be encouraged to meet the needs to the persons with disabilities”, Id.

[26]. See generally: Discussion on disability in the Mid Term Appraisal of the Eleventh Five Year Plan, Page 185, available at http://planningcommission.nic.in/plans/mta/11th_mta/chapterwise/Comp_mta11th.pdf.

[27]. Tim Noonan, “Acceptable E-commerce in Australia: A Discussion Paper about the Effects of Electronic Commerce Developments on People With Disabilities”, available at http://www.timnoonan.com.au/ecrep10.htm

[28]. Id.

[29]. “Barriers to Using Automatic Teller Machines”, Tim Noonan, available at http://www.hreoc.gov.au/disability_rights/inquiries/ecom/atmpaper.htm, last viewed on July 26, 2012.

[30]. See generally: Accessibility at the RBS, available at http://www.bankofscotland.co.uk/accessibility/hearing-impaired/, last viewed on July 20.

[31]. In conversation with Mr. George Abraham, CEO, SCORE Foundation. Ms. Radhika Alkazi, Managing Trustee of Aarth-Aastha also pointed out that in many instances, banks often ask persons with disabilities to bring someone else to sign for them (or operate the account on their behalf) even when the person is fully capable of signing and operating the account themselves. There is no fixed basis for the procedure, which varies from bank to bank.

[32]. “Barriers to Using Automatic Teller Machines”, Tim Noonan, available at http://www.hreoc.gov.au/disability_rights/inquiries/ecom/atmpaper.htm, last viewed on July 26, 2012.

[33]. “The Challenges of Blind Internet Users”, available at http://www.evengrounds.com/blog/challenges-of-blind-internet-users, last viewed on July 15.

[34]. See generally: Accessibility at the RBS, available at http://www.bankofscotland.co.uk/accessibility/visually-impaired/, last viewed on July 20.

[35]. Consider the development of such ATMs by Wells Fargo bank in the USA; more details are available at https://www.wellsfargo.com/about/diversity/accessibility/.

[36]. In conversation with Mr. Anil Joshi, the Programme Director of Human Ability and Accessibility at IBM, who works with parents of children with Down’s Syndrome and other mental disabilities. He also pointed out that given that only a miniscule portion of people with disabilities are able to understand banking concepts, the few who do so invariably use banking facilities with the help of their parents or guardians.

[37]. “Barriers to Using Automatic Teller Machines”, Tim Noonan, available at http://www.hreoc.gov.au/disability_rights/inquiries/ecom/atmpaper.htm, last viewed on July 26, 2012.

[38]. “Customising mobile banking in India: issues and challenges”, Address delivered by Shri Harun R. Khan, Deputy Governor, Reserve Bank of India, at the FICCI-IBA (FIBAC) 2012 Conference on-“Sustainable excellence through customer engagement, employee engagement and right use of technology” on September 5, 2012 at Mumbai, available at http://www.rbi.org.in/scripts/BS_SpeechesView.aspx?id=726.

[39]. Id.

[40]. Available at http://www.rbi.org.in/Scripts/bs_viewcontent.aspx?Id=1660.

[41]. Leonard R. Kasday, "A Tool to Evaluate Universal Web Accessibility" Posters, Proceedings of the 2000 International Conference on Intelligent User Interfaces 2000, pp. 161-162.

[42]. See generally: “WCAG 2 at a Glance”, available at http://www.w3.org/WAI/WCAG20/glance/

[43]. See generally: “Website Accessibility”, available at http://www.tiresias.org/research/guidelines/web.htm

[44]. For more details, see generally: “Website Accessibility”, available at http://www.tiresias.org/research/guidelines/web.htm

[45]. The Compliance Matrix can be accessed at http://web.guidelines.gov.in/compliance.php.

[46]. “Deaf and Hearing Impaired”, Woei-Jyh Lee, Handbook of Universal Usability in Practice, available at http://otal.umd.edu/UUPractice/hearing/, last viewed on 23 July, 2012.

[47]. “ATM Usage very low in India, says RBI”, available at http://www.firstpost.com/economy/atm-usage-very-low-in-india-says-rbi-404198.html.

[48]. Available at http://rbi.org.in/scripts/NotificationUser.aspx?Id=7286&Mode=0.

[49]. Harsh Vardhan, “White Label ATMs”, available at http://ajayshahblog.blogspot.in/2012/08/white-label-atms.html.

[50]. “Department of Justice finalises New ATM Accessibility Standards”, available at http://www.diebold.com/solutions/atms/opteva/html/Diebold_AccessibilityStandards.pdf, last viewed on July 12.

[51]. “Department of Justice Finalises New ATM Accessibility Standards”, available at http://www.diebold.com/solutions/atms/opteva/html/Diebold_AccessibilityStandards.pdf, last viewed on July 12.

[52]. “Making Bank Notes Accessible for Canadians Living with Blindness or Low Vision”, Carolyn Samuel, available at http://www.bankofcanada.ca/wp-content/uploads/2011/08/samuel.pdf.

[53]. Id.

[54]. Carolyn Samuel, “Making Bank Notes Accessible for Canadians Living With Blindness or Low Vision”, available at http://www.bankofcanada.ca/wp-content/uploads/2011/08/samuel.pdf.

[55]. (DBOD.No.Leg.BC.123 /09.07.005/2008-09).

[56]. Refer to Section 4.3 of the Report.

[57]. Dinesh Kaushal, “The Case for Accessible Banking”, available at http://cis-india.org/accessibility/accessible-banking.

[58]. NR Indran, “UBI to deploy Mumbai’s first Talking ATM for the visually challenged”, available at http://apnnews.com/2012/07/09/ubi-to-deploy-mumbai%E2%80%99s-first%E2%80%98talking-atm%E2%80%99-for-the-visually-challenged-powered-by-ncr/

[59]. Id.

[60]. “NCR Corp to set up 50 Talking ATMs in passport offices”, available at http://lflegal.com/2012/09/ncr-india/.

[61]. “NCR Corp to set up 50 Talking ATMs in passport offices”, available at http://lflegal.com/2012/09/ncr-india/.

[62]. Dinesh Kaushal, “The Case for Accessible Banking”, available at http://cis-india.org/accessibility/accessible-banking.

[63]. Id.

[64]. “Department of Justice Finalises New ATM Accessibility Standards”, available at http://www.diebold.com/solutions/atms/opteva/html/Diebold_AccessibilityStandards.pdf, last viewed on July 12.

[65]. See more details at http://www.unionbankofindia.co.in/personal_TalkingATMs.aspx

[66]. These guidelines are available at http://www.nzba.org.nz/banking-standards/code-of-banking-practice/voluntary-guidelines-to-assist-banks-to-meet-the-needs-of-older-and-disabled-customers/

[67]. Id.

[68]. Id.

[69]. Id.

[70]. Section 4 of the DDA defines disability in relation to a person as:
a. total or partial loss of the person's bodily or mental functions; or
b. total or partial loss of a part of the body; or
c. the presence in the body of organisms causing disease or illness; or
d. the presence in the body of organisms capable of causing disease or illness; or
e. the malfunction, malformation or disfigurement of a part of the person's body; or
f. a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
g. a disorder, illness or disease that affects a person's thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour; and includes a disability that:
a. presently exists; or
b. previously existed but no longer exists; or
c. may exist in the future; or is imputed to a person.

[71]. Section 4 of the DDA defines a service as relating to, amongst other things, banking, insurance, superannuation and the provision of grants, loans, credit or finance, and including financial and information services provided, for example, through websites, telephones, ATMs and EFTPOS.

[72]. For a full list, please refer to: http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/Industry-Standards---Accessibility, last accessed on 12^th August, 2012.

[73]. Refer to http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/ATM-Standard

[74]. Refer to http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/EFTPOS-Standard

[75]. Refer to http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/Automated-Telephone-Banking-Standard

[76]. ABA Industry Standard on Electronic Banking, available at http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/Internet-Banking-Standard

[77]. Refer to http://www.bankers.asn.au/Industry-Standards/ABAs-Accessibility-of-Electronic-Banking-/Australian-Banking-Industry-E-Commerce-Industry-Action-Plan

[78]. “Background to the Guiding Principles”, Section 1.1 of the ABA Guiding Principles for Accessible Authentication, available at http://www.bankers.asn.au/ArticleDocuments/177/ABA-Guiding_Principles_for_Accessible_Authentication.doc.aspx

[79]. Id.

[80]. “Department of Justice Finalises New ATM Accessibility Standards”, available at http://www.diebold.com/solutions/atms/opteva/html/Diebold_AccessibilityStandards.pdf, last viewed on July 12

[81]. See generally: “Department of Justice finalizes new ATM accessibility standards”, available at www.diebold.com/solutions/atms/opteva/html/Diebold_AccessibilityStandards.pdf

[82]. A summary is available at “Standard B651.1-09”, sourced from http://hub.eaccessplus.eu/wiki/Canadian_standard_for_accessible_design_for_automated_banking_machines, and a full text can be purchased from the Canadian Standards Association website.

[83]. “The extent to which technical requirements are applied is the responsibility of others, such as the authority having jurisdiction.”

[84]. “Barrier Free Banking”, available at http://www.abilities.ca/agc/article/article.php?pid=&cid=&subid=&aid=429

[85]. Id.

[86]. “Dutch Guidelines for User Friendly payment terminals”, available at http://hub.eaccessplus.eu/wiki/Dutch_Guidelines_for_user-friendly_payment_terminals

[87]. “Dutch Guidelines for Payment Systems”, available at http://hub.eaccessplus.eu/uploads/a/a1/Dutch_Guidelines_on_payment_systems.pdf

[88]. Id.

[89]. Building User Friendly Voice Systems, Tim Noonan, available at http://www.timnoonan.com.au/ivrpap98.htm

[90]. See generally, “What are the possibilities”, the webpage for the Xavier’s Resource Centre for the Visually Challenged, available at http://www.xrcvc.org/fs_alternatives.php

[91]. In countries like Japan, even sighted people use what are known as signature stamps, Hanko and Inkan, instead of actual signatures, for signing of official documents. This is a practice that can also be incorporated by banks.

[92]. See generally, “What are the possibilities”, the webpage for the Xavier’s Resource Centre for the Visually Challenged, available at http://www.xrcvc.org/fs_alternatives.php.

[93]. In conversation with Ms. Anubhuti Mittal, who works for HR Solutions for the Differently Abled, and runs a consultancy which works with people with disabilities, providing recruitment services to the disabled, doing access audits, job mapping, sensitization and training of employees at organisations.

[94]. Pursuant to Section 33 of the PWD Act, which states: Every appropriate government shall appoint in every establishment such percentage of vacancies not less than three per cent for persons or class of persons with disability of which one per cent? each shall be reserved for persons suffering from:

Blindness or low vision;
Bearing impairment;
Loco motor disability or cerebral palsy, in the posts identified for each disability:

Provided that the appropriate Government may, having regard to the type of work carried on in any department or establishment, by notification subject to such conditions, if any, as may be specified in such notification, exempt any establishment from the provisions of this section.

[95]. For example, the Australian and New Zealand Standards (AS/NZS 4263).

[96]. A good reference point would be “A Look at Internet Banking Accessibility in Australia”, Sofia Celic, Steven Faulkner, and Andrew Arch, available at http://ausweb.scu.edu.au/aw04/papers/refereed/celic/paper.html, where the authors have studied the websites of different Australian banks to see how far they are complying with the WCAG1.0 guidelines and have rated them on different criteria. Unfortunately, the team found that “the overall status of the accessibility of Australian banking web sites, using the accessibility of their home pages as an indicator, is less than desirable. None of the banks assessed has met the ABA recommended timetable of addressing all applicable WCAG 1.0 Priority 1 and Priority 2 checkpoints within 18 months of the Standard being released (April 2002).”

Contributors:

Nirmita Narasimhan, Policy Director
Vrinda Maheshwari, Consultant

Click to download the entire report (PDF) 802 Kb

For more details visit https://cis-india.org/accessibility/blog/banking-and-accessibility-in-india-report

CIS Gets ITU-D Sector Membership

nirmita — 2013-07-11T10:11:54Z

The Centre for Internet and Society (CIS) has become a sector member of ITU-D, the development sector of the International Telecommunication Union, the specialized UN Agency dealing with telecommunications and information communications (ICTs).

Over the past years, CIS has had the opportunity to work with ITU on specific accessibility related projects. With this membership, CIS will be able to participate more regularly in ITU activities and contribute to key policy and regulatory debates surrounding telecommunications and ICTs at the global level. CIS is one of six civil society organizations registered as ITU members from the Asia-Pacific region.

CIS profile on ITU membership can be viewed here. Click to view the ITU Membership Certificate

For more details visit https://cis-india.org/accessibility/blog/cis-itu-d-sector-membership

Government of Madhya Pradesh initiates ICT Accessibility in Public Communication

nirmita — 2013-01-31T10:17:13Z

The Centre for Internet and Society, 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.

Specifically, it was requested that the government ensure that all websites are WCAG 2.0 compliant, that Unicode font is used for all regional language content and that content should be in accessible formats such as Daisy and E-pub. The submission can be found by clicking here.

In January 2013, the Government of Madhya Pradesh issued a notification in Hindi (scanned PDF version of the notification here) requesting all departments to comply with WCAG 2.0 and use Unicode font. The five page notification goes into detail regarding the need for these standards. We welcome this move by the Government of Madhya Pradesh and appreciate the efforts of Arushi in taking up this issue. We are happy to be associated with this initiative.

Click to read the original notification received from the Government of Madhya Pradesh (Image files in Zip folder, size 5.3 MB).

For more details visit https://cis-india.org/accessibility/blog/govt-of-mp-initiates-ict-accessibility-in-public

Accessibility of Government Websites in India

nirmita — 2012-09-25T05:54:58Z

This report summarises the key findings of a test conducted to measure the accessibility of 7800 websites of the Government of India and its affiliated agencies against the Web Content Accessibility Guidelines (WCAG) 2.0, which is the universally accepted standard for web accessibility.

For more details visit https://cis-india.org/accessibility/accessibility-of-govt-websites.pdf

Mobile technologies and enlightened service packages help persons with disabilities connect to new opportunities

nirmita — 2012-09-13T13:38:32Z

Innovative approaches from mobile hardware and applications developers as well as operators are helping connect the estimated 15% of the global population that lives with some form of disability to the power of information and communication technology.

The press release was published by the International Telecommunication Union (ITU) on September 12, 2012

A new report released jointly by ITU and civil society partner The Global Initiative for Inclusive ICTs (G3ict) on the occasion of the United Nations Conference on States Parties to the Convention on the Rights of Persons with Disabilities, (New York, 12-14 September), reveals a surge of interest in an as-yet untapped market, with new accessibility applications now being launched almost daily, offering unprecedented ways to empower persons with disabilities to communicate, access information and control their environment.

Senior citizens, people living with disabilities and the illiterate are often marginalized from the ‘mobile miracle’ however, because devices are not equipped with the right kind of accessibility features, or because the price of accessible mobile phones and services is out of reach. That’s now changing, with a host of exciting options coming onto the market.

New screen readers can make mobile phones easily usable for the blind, those with low vision and the illiterate. Visual or vibrating alerts, relay services and hearing aid compatibility devices are making mobile phones accessible for the deaf and hard of hearing, while features such as voice recognition and auto text are proving a boon to those with physical disabilities.

Examples of pioneering solutions highlighted in the report include special text-only billing plans for the deaf and hard-of hearing so that subscribers pay only for messaging and data; a new SMS-to-Avatar translation system being developed by the University of Tunis which converts typed text into real-time, online interpretation in sign language with the help of a dictionary of words and signs; and new GPS-based devices and services that help blind and partially sighted people navigate streets using an interface that announces the nearest points of interest and the user’s current location, with links to Braille readers over Bluetooth.

‘Digital accessibility’ is a relatively untapped market segment that offers potentially lucrative commercial opportunities for mobile service providers, manufacturers and smart phone application developers while ensuring the digital inclusion of persons with disabilities. A handful of leading mobile operators from around the world are already successfully addressing the needs of seniors and persons with disabilities, demonstrating the business case for promoting mobile accessibility.

Unfortunately, not all mobile operators and manufacturers are following suit, and affordability remains a major issue, especially for smart phone solutions and for subscribers in developing markets. “ITU encourages all Member States to implement regulatory and policy measures to promote access and ensure the accessibility needs of all people are met,” said Dr Hamadoun I. Touré, ITU Secretary-General. “This is especially timely given the widespread adoption of the Convention on the Rights of Persons with Disabilities which requires ICT accessibility of all its signatories, most of which are also ITU Member States.”

There are already six billion mobile cellular telephone subscriptions globally. By 2013, ITU estimates that there will be more mobile cellular telephone subscriptions than human beings on the planet. But while some people are hyper-connected, others are yet to be reached.

“This report will help guide all stakeholders as they implement business practices and policies to promote accessible mobile phones and services at home. We want to see affordable, accessible mobile phones and services used to ‘m-power’ persons with disabilities and other users around the globe,” said Brahima Sanou, Director of ITU’s Telecommunication Development Bureau, which led the preparation of the report.

The report also includes a checklist for policy makers which includes steps such as developing a roadmap with operators, supported by organizations of persons with disabilities, to identify and address mobile phone accessibility gaps; facilitating or holding capacity building programmes with mobile operators on disability awareness and ways to reach out and serve persons with disabilities; and identifying areas for which Universal Service/Access Funds may intervene to equalize access for users with disabilities.

The report, Making Mobile Phones and Services Accessible for Persons with Disabilities, is available for free download from the ITU website at: http://www.itu.int/ITU-D/sis/PwDs/Documents/Mobile Report.pdf

For more details visit https://cis-india.org/accessibility/www-itu-press-release-mobile-technologies-and-enlightened-service-packages-help-persons-with-disabilities-connect-to-new-opportunities

Making Mobile Phones and Services Accessible for Persons with Disabilities

nirmita — 2013-04-26T05:00:19Z

This report is published by the International Telecommunication Union in cooperation with G3ict – The Global Initiative for Inclusive Information and Communication Technologies. Nirmita Narasimhan and Axel Leblois are the lead authors. The contributors include Deepti Bharthur, Lakshmi Haridas, Pranav Lal, Peter Looms, Roopakshi Pathania, Deva Prasad, Susan Schorr, and Mukesh Sharma.

For more details visit https://cis-india.org/accessibility/making-mobile-phone-and-services-accessible-for-persons-with-disabilities.pdf

Accessibility of Government Websites in India — Test Results

nirmita — 2012-08-02T12:56:45Z

The Centre for Internet & Society conducted a survey of the accessibility of the government websites in India. A total of 7800 websites listed on the Government of India directory were researched upon.

Two data sets were considered to evaluate the websites. The first data set comprises the errors identified by the automated tool AChecker. These errors are (known errors, likely errors, probable errors, HTML validation errors and CSS validation errors). The second data set was arrived at through manual evaluation. This includes (alternate text for non-text objects, colour change option, navigation markup and form accessibility).

To view the test details, click here (Excel File, 1618 Kb)

For more details visit https://cis-india.org/accessibility/accessibility-audit-of-govt-websites

Web Accessibility Policy Making: An International Perspective

nirmita — 2012-09-25T05:33:25Z

G3ict and CIS are pleased to announce the publication of a new, improved edition of the Web Accessibility Policy Making: An International Perspective. The report published in cooperation with the Hans Foundation provides an updated synopsis of the many policies that governments have implemented around the world to ensure that the Internet and websites are accessible to persons with disabilities.

The report contains a Foreword by Axel Leblois, Founder and Executive Director of G3ict, an introduction and studies from countries like Australia, Canada, Germany, Ireland, Italy, Japan, South Korea, New Zealand, Philippines, Portugal, Sweden, Thailand, United Kingdom, United States, and the European Union. The report contains contributions from Prashanth Ramadas, Asma Tajuddin, G Aravind, Katie Reisner, Sucharita Narasimhan, Bama Balakrishnan and Nirmita Narasimhan. Axel Leblois, Donal Rice, Immaculada Placienca Porrero, Kevin Carey, Licia Sbattella and Sunil Abraham are the expert reviewers.

Foreword by Axel Leblois

This third edition of our joint report with CIS “WEB ACCESSIBILITY POLICY MAKING: AN INTERNATIONAL PERSPECTIVE” provides an updated synopsis of the many policies that governments have implemented around the world to ensure that the Internet and web sites are accessible to persons with disabilities. With 153 countries parties to the Convention on the Rights of Persons with Disabilities as of December 2011, an increasing number of governments are now in the midst of developing policies and programs to ensure that web sites and services under their jurisdictions are accessible.

Indeed, the Preamble of the Convention on the Rights of Persons with Disabilities recognizes “the importance of accessibility to the physical, social, economic and cultural environment, to health and education and to information and communication, in enabling persons with disabilities to fully enjoy all human rights and fundamental freedoms”. Its article 9 stipulates that: “To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems” (1). It further specifies that “State Parties shall also take appropriate measures to … Promote access for persons with disabilities to new information and communications technologies and systems, including the Internet” (2.g).

There is therefore no doubt that all State Parties have an obligation to act upon those commitments. However, as this report demonstrates it clearly, web accessibility policies and their levels of enforcement vary considerably among countries with some common denominators such as the compliance with the W3C – WAI guidelines on web accessibility.

G3ict and CIS hope that this new, improved edition, which will now be available in print as well as in electronic format, will help accelerate the development of web accessibility policies and programs around the world. We want to express our sincere appreciation to Nirmita Narasimhan, programme manager at CIS and editor of the G3ict Publications and Reports for her dedication to this report which would not have been made possible without her incredible work and motivation as Disability Advocate.

Download a PDF of the Web Accessibility Policy Making here [335 KB]

Download the Daisy File [23412 KB]

For more details visit https://cis-india.org/accessibility/web-accessibility-policy-making-an-international-perspective

Technology for Accessibility in Higher Education

nirmita — 2012-01-31T06:29:03Z

Education for students with disabilities has long been a serious cause of concern in India, as also in other countries around the world. A person with a disability studying in mainstream educational institutions in India experiences many difficulties in navigating through the obstacle course of the Indian educational system, writes Nirmita Narasimhan in this IIMB Journal brought out on the occasion of the conference 'never-the-less - Enabling Access for Persons with Disabilities to Higher Education and Workplace - Role of ICT and Assistive Technologies.

Problems exist in many areas – course content, staff, facilities, resources as well as the educational and examination process. The relative physical inaccessibility of educational institutions, unavailability of accessible content in different languages, lack of trained and sensitive teachers, and the lack of awareness about developments in enabling technologies have hitherto rendered the educational environment itself rather difficult to access. In addition to the long waiting periods in getting the course materials digitized into accessible formats, as well as the assignment of scribes unfamiliar with subject topics for students to write the examinations put students with print disabilities at additional disadvantage – as if there weren’t enough problems already! Thus the educational experience often becomes a nightmare for a student who is disabled. However, compared with the situation from a decade earlier, the education scenario for persons with disabilities has, thanks to the sustained advocacy and interventions of disability organizations, gradually improved and promises to get better in the years to come.

Today, technology has made it possible for persons with disabilities to read and work independently. Some institutions for higher learning around the country, like St Xavier’s College, Mumbai, Delhi University and Loyola College in Chennai have already set up ICT centres which facilitate reading and working students who are print impaired. They offer support through digitization, training, and facilities. Organisations like National Association for the Blind and other Daisy organizations convert study materials for blind students and make them available in formats and media of the students’ choice. Students themselves, through peer to peer networks and mailing lists are able to collaboratively produce and share accessible study materials on a variety of subjects ranging from graduation to competitive exams. Another really big boon is the advent of the mobile phone as a suitable platform for listening to books. Today, two international mobile screen reader software - Nuance Talks and Mobile Speak - are available in the Indian market at competitive prices and this has led to an increase in the incidence of mobile adoption amongst persons with print disabilities, at least in the metropolitan cities.

There are many areas of improvement, which institutions of higher education can adopt for enhancing the education experience for students. For instance, the provision of digitized reading materials, access to computers with assistive devices, choice of examination methods, maintaining accessible web sites, promoting open access and open educational resources will go a long way in furthering education amongst students who have disabilities. Institutions could explore new models of imparting education which are proving successful in other parts of the world. Furthermore, existing sources of information and knowledge, such as information in the public domain and knowledge imparted through distance education should be made accessible to a wider audience.

Click here for the conference details held in IIM, Bangalore on 20 and 21 January 2012.
Download the original published in the Journal: Enabling Access for Persons with Disabilities to Higher Education and Workplace [PDF, 1422 KB]

Nirmita Narasimhan is a Programme Manager with the Centre for Internet and Society and works on policy research and advocacy related to IP reform and technology access for persons with disabilities. She received a National Award from the President of India in 2010 recognizing her contribution to the Empowerment of Persons with Disabilities.

For more details visit https://cis-india.org/accessibility/accessibility-in-higher-education

Universal Service for Persons with Disabilities: A Global Survey of Policy Interventions and Good Practices

nirmita — 2012-10-08T05:43:46Z

The Global Initiative for Inclusive Information and Communication Technologies and the Centre for Internet and Societies in cooperation with the Hans Foundation have published the Universal Service for Persons with Disabilities: A Global Survey of Policy Interventions and Good Practices. The book consists of a Foreword by Axel Leblois, an Introduction and four chapters. Deepti Bharthur, Axel Leblois and Nirmita Narasimhan have contributed to the chapters.

Foreword

Universal Service definitions have been developed by 125 countries and are the foundation for policies and programs ensuring that telecommunications are available to all categories of population. Universal service funds are the main vehicle used to fund those programs, primarily addressing imbalances such as lack of availability of services in rural areas. While geographic coverage has vastly improved over the past decade with wireless infrastructure, the scope of Universal Service has expanded to include other categories of underserved populations.

Among those, persons with disabilities and senior citizens, who represent 15% of the world population[1] are an increasing concern for legislators and regulators. Basic accessibility features for public telephone booths, fixed line or wireless handsets, customer services in alternate formats such as Braille, or assistive services such as relay services for hard of hearing or deaf persons are in fact not implemented in a majority countries.[2]

To address those issues, several countries have expanded the scope of their national definition of Universal Service Obligation to include persons with disabilities allowing programs promoting the accessibility of information and communication technologies to be covered by Universal Service Funds.

The adoption of the Convention on the Rights of Persons with Disabilities by over 150 countries since March 31st, 2007 will likely accelerate this trend: States Parties have an obligation to ensure that Information and Communication Technologies and Services are made accessible to persons with disabilities. This can be done by aligning the definition of Universal Service Obligation with article 9 of the Convention and expanding the charter of Universal Service Funds to cover programs promoting accessibility for persons with disabilities. This report is the first attempt to document how Universal Service definitions and related policies and programs have been implemented by various countries to ensure that persons with disabilities have full access, on an equal basis with others,to telecommunication services.G3ict would like to express its sincere appreciation to the Center for Internet and Society for its support of this project, to Nirmita Narasimhan for researching and editing this report;to the International Telecommunication Union for providing references and helping identify countries to be surveyed, and to the Hans Foundation for funding the print version of the report. Promoting universal service for persons with disabilities can affect positively the lives of millions of users around the world. We hope that this report may serve as a useful reference for policy makers, operators, organizations of persons with disabilities, and as a framework for good practice sharing among countries currently implementing the Convention on the Rights of Persons with Disabilities.

Axel Leblois
Executive Director
G3ict – Global Initiative for Inclusive ICTs

Introduction

The advent of the Internet and accessible information and communication technologies (ICT) has opened up exciting possibilities and opportunities for persons with disabilities.The United Nations Convention on the Rights of Persons with Disabilities (the ‘UNCRPD’)3 has explicitly recognized the right of persons with disabilities to seek, receive and impart information on an equal basis with others4 and has placed specific obligations on member states to ensure that all ICT based facilities and services (which include telecommunications services) must be made available and accessible to all. To this end, member states are required to formulate and implement appropriate laws and policies at national, regional and global levels. In an age where almost all spheres of life are inextricably woven with and dependent on ICT, Article 9 of the UNCRPD on Accessibility is possibly one of the most powerful and critical tools in the hands of policy makers to ensure that persons with disabilities are assured of basic human rights such as education, health, employment and access to information and participation.While the lack of awareness amongst governments is undeniably a serious impediment to implementing accessible ICT in any country, an equally serious and perhaps more realistic problem is the lack of resources which is plaguing many countries, especially developing nations. The fact that governments are already struggling to ensure basic human rights for all citizens by judiciously dividing their limited resources for the whole gamut of needs makes it difficult for them to outlay separate and substantial budgets which may be required for implementing ICT accessibility. In such a scenario it becomes very important to look around and identify sources of funding, new or existing, which can be leveraged by governments to fulfill their obligation towards making all ICT based applications and services accessible and promoting assistive technologies for persons with disabilities.

This report aims to highlight the extreme suitability of leveraging the Universal Service Fund (USF) to implement accessibility and assistive technologies in telecommunications. It examines the evolution of the concept of USF, its minimum mandate and scope, funding sources, as well as project implementation mechanisms and showcases countries which are using the USF to fund accessibility projects through policies and programmes.

[1].WHO Global Report on Disability, June 2011 - http://www.who.int/disabilities/world_report/2011/en/index.html

[2].CRPD Progress Report on ICT Accessibility – 2010 by G3ict - http://g3ict.org/resource_center/publications_and_reports

Click here for the Braille format
Download the Daisy version here
Download the book here PDF [302 KB]

For more details visit https://cis-india.org/universal-service-for-persons-with-disabilities

The Business Case for Web Accessibility

nirmita — 2011-12-07T09:56:47Z

NASSCOM Foundation has published a handbook on web accessibility titled "Understanding WebAccessibility — A Guide to create Accessible Work Environments". Nirmita Narasimhan authored a chapter "The Business Case for Web Accessibility".

The Internet is perhaps one of the most revolutionary things that happened for persons with disabilities. It has transformed their lives from one of ignorance and dependence to one of inclusion and participation. Using assistive technologies, blind persons can now read newspapers and information on websites, deaf persons can understand video content through captioning and persons with different disabilities can access computers in a variety of ways. However, despite these exciting developments in assistive technologies, the relative inaccessi-bility of websites remains a severe impediment to disability access to the internet.

There may be several reasons for complying with web accessibility. These may be:

Social (i.e. acknowledging the right of persons with disabilities to have equal access to information and opportunities offered by the internet);
Legal reasons (i.e. complying with national guidelines, policies or laws);
Technical (i.e. ensuring increased interoperability, reducing server load, time taken in website maintenance and better quality websites); and
Business (i.e. realizing that having an accessible website makes good business sense).

This article focuses on the last reason, i.e. business drivers for web accessibility.

Web accessibility means that a website can be accessed completely by all users, regardless of disability or any disabling factor such as illiteracy, old age or limited bandwidth. Compliance with the Web Content Access Guidelines (WCAG) will ensure that a website will be equally accessible to all disabled users, irrespective of the type of disability (visual, motor, auditory, cognitive or persons who are prone to seizures). Contrary to common belief, an accessible website is not necessarily a boring one. In fact, often times, the difference between an accessible and an inaccessible website may not be evident visually, but only upon use.

It is important for business houses to bear in mind that making websites accessible not only benefits persons with disabilities, but is helpful to every user. For instance, captioning of videos for the deaf will also benefit illiterate persons and persons having limited bandwidth, who constitute a sizeable percentage of the Indian population. Furthermore, nearly everyone benefits from clearly structured content, easy navigation and illustrated graphics. There are over a billion persons with disabilities living around the world, over 70 million in India alone and some surveys also estimate that one fifth of internet users have some form of disability or disabling condition. Hence companies which ensure that their web sites are accessible will be assured of a much wider reach than companies whose websites are not accessible.

An important aspect of creating an accessible website is that if a website is designed and developed in an accessible manner from the very beginning, its cost would exceed the cost of creating an inaccessible web site by perhaps merely 2%. However, on the other hand, if one were to have to retrofit accessibility features into a website, the cost and effort would be the same as that of creating an entirely new site. Furthermore, while the website would become accessible, the maintenance and day to day activities on it would also need to continue to be accessible. An accessible web site enhances ease of maintenance and scalability. Companies must also ensure that the developers maintaining the website must have a good understanding of WCAG.

Perhaps one of the biggest advantages of having an accessible web site is that it also increases its chances of ranking and visibility amongst search engines. There is a significant overlap between guidelines for accessibility and SEO. For instance, both of them require alternative text for graphics, clearly defined heading structures, identification of language of pages and page content, descriptive links etc. Having an accessible website will ensure that it can be accessed on new browsing technologies and platforms, like mobile phones and PDAs. Not only is navigation and usability enhanced, but the separation of content from presentation drastically reduces the download time of accessible web sites, rendering it a pleasurable experience for users to visit the web site.

There is a clear business case in creating products and web sites which are accessible. This is evident in the fact that some of the largest and most successful companies in the world have incorporated accessibility and universal design in their products and services. For instance,

Apple has been committed to accessibility since 1985 and its accessibility website3 features all its accessibility technologies for persons with disabilities as well as other third party products. Apple has integrated universal access into its operating system so that they are usable with Apple and other products.

The accessibility statement on the web site of General Electric4 gives details of its ongoing work on the accessibility of its website and a disabled user can track the company's progress by reading this page. It also provides a help facility for persons who are unable to use the site due to access problems.

A stunning example of a company which has made huge business profits through application of universal design principles in its products is that of NTT DoCoMo which came out with its accessible line of mobile phones called the “Raku-Raku” phone and rapidly captured the majority market share of mobile phones in Japan. The company has sold up to 20 million5 handsets as of July 2011 since its inception and released 18 models.

Some further examples of companies which are committed to accessibility are Cisco Systems Inc.6, AT&T Services Inc.7, France Telecom8, Google9, Hewlett-Packard10, IBM11, Microsoft Corporation12, Nokia13 and Vodafone14. The web sites of these companies have detailed information on the key areas of their accessibility work.

It is therefore clear that companies are increasingly recognizing the wisdom of unlocking their content to a larger audience. Not only do they increase their customer base, but also are able to garner loyalty from their customers as well as bolster their image by showing consideration towards customers with different needs.

The publicity that can be leveraged by business houses on account of their commitment to accessibility and inclusion will go a long way in building a good and lasting relationship with their customers. Hence, companies are strongly urged to make a concerted effort to promote web accessibility through awareness, internal policies and providing requisite training and support. In a world where policy makers are also increasingly becoming aware of the need for web accessibility and mandating it through policies, it will become inevitable for both public and private organizations to have websites which are universally accessible.

Read the original published by NASSCOM Foundation here

Download the entire book here (PDF, 1570 kb)

For more details visit https://cis-india.org/accessibility/business-case-for-web-accessibility

Barriers to Access in a Connected World

nirmita — 2011-11-08T05:30:24Z

Accessibility is an imperative to achieve a truly inclusive and participatory society writes and every individual, corporation, organization and government has a crucial role to play in nurturing it, writes Nirmita Narasimhan in this article which was published by Hans Foundation in their Annual Review 2011.

Imagine a world in which there are phones but you cannot communicate; there are televisions but you cannot watch or hear any of the programmes; there are millions of books, but you cannot read even one of them. Imagine that you were to go into a supermarket but couldn’t buy anything because you couldn’t find what you wanted, or find out the price; that you went to an ATM machine, but couldn’t withdraw money; that you went to a website of an airline, but couldn’t buy your tickets because you couldn’t view the options on the menu bar; a world where you alone are denied access to all information and entertainment like watching movies, going to museums and other places of public interest. It shouldn’t be very difficult to imagine this, because this is exactly the world we live in today. This is the reality faced by over a million persons living with disabilities around the world.

Today the number of persons with disabilities is increasing, compounded by the decrease in mortality rates and the increase in the number of diseases. Over 90 per cent of persons with disabilities live in developing countries and have little or in many cases, no access to basic human rights of education, food and shelter, employment, independent living and access to information.

It is to address this situation that the United Nations Convention on the Rights of Persons with Disabilities (‘Convention’) came into force in May 2008, marking a watershed in the disability rights movement. One of the unique features of the Convention is that for the first time equal importance was accorded to the right to access information and Information and Communication Technologies (ICT) bringing it on par with transportation and physical environment. It placed a clear obligation on the states parties to ensure that all websites and ICT services as well as information both in the public domain and with respect to cultural materials such as books, movies, etc should be made available to persons with disabilities in accessible formats, at the same time and no extra cost. The convention requires that countries should amend their laws to incorporate flexibilities which will enable persons with disabilities to enjoy their human rights and fundamental freedoms.

Technology – A Fundamental Enabler for Accessibility

The Information Society has opened up several avenues for persons with disabilities to participate and live independently. Through the use of assistive technologies, persons with disabilities can access computers, study, work, book tickets and travel, pay taxes, shop, transact business, use social media and work. For instance, blind persons can access computers using a screen reader[1] on computers or mobile phones, enabling them to send messages, make calls, listen to books, navigate the route and use the internet like other people; deaf persons can carry on a conversation through relay or text messaging and listen to audio using hearing aids; autistic persons can use symbols or pictures on their mobile phones to communicate their needs to persons around them. Hence, the range of platforms and media available today, offer tremendous opportunities for participation and inclusion.

Challenges to Inclusion

The general lack of awareness amongst policy makers and the public, resulting in widespread social stigma and insensitive attitudinal barriers associated with disability, often negates the advantages provided by technology. Attitudinal change is fundamental to making the world a more inclusive place.

In addition to social attitudes and awareness, several other challenges which hamper the ability of persons with disabilities to harness the power of assistive technology, are discussed briefly below.

One major challenge is inaccessible technology. Technology may be inaccessible due to a multiplicity of reasons, such as the unavailability of suitable software in a given region [2] or prohibitive pricing. In the absence of equally appropriate open source solutions, persons with disabilities cannot afford assistive technology. For instance, a screen reader which costs upwards of $1000 for a single user license is unaffordable for a person with disability in most countries.

Another barrier is the inaccessibility of web sites. The failure to adhere to universally accepted Web Content Access Guidelines (WCAG) formulated by the World Wide Web Consortium (W3C) renders web sites unfit for use by persons using assistive technology. The guidelines lay down very simple instructions such as ensuring that images are accompanied by alternative text attributes which enable screen readers to read out the description of the image to the listener and providing alternate formats where anything on a web site is inaccessible. Many countries today such as USA, UK and Canada have made it mandatory for all public web sites to conform to these guidelines. However, there are still several countries which do not have any such policies in place.

The lack of accessible content also poses a significant challenge. There is a severe shortage of content in formats such as electronic text, Braille, audio, etc which can be accessed by assistive technology. This may occur either due to technological (content created in inaccessible format) [3] or legal reasons (copyright laws prevent content from being rendered in accessible formats). The latter issue is the subject matter of treaty deliberations at the World Intellectual Property Organization. Today barely 5 per cent of all published materials in developed countries and 0.5 per cent in developing countries are available to persons with disabilities who are not able to read printed materials in accessible formats such as electronic text, Braille, audio, etc. Organizations serving the blind have to constantly obtain permission from copyright holders for each book that they want to convert, which is not always forthcoming. In some countries, this is simplified by the inclusion of a fair use provision (exception) in their copyright laws, which essentially does away with the requirement of having to obtain permission in cases of conversion and distribution for the disabled. However, while such a provision exists in approximately 53 countries, it is not available in over 127 countries where even the countries with exceptions cannot exchange books. Developing countries are the most severely hit since they neither have the legal provisions permitting conversion in their country nor the resources and funding to undertake conversion, and are unable to borrow books from libraries for the blind in other countries. This has resulted in a huge book famine for persons with blindness and other print disabilities around the world, preventing them from exercising their human rights of education, access to information, social and cultural participation and independent living.

Training is a very crucial aspect of ensuring effective and rapid adoption of technology by persons with disabilities, since they need to orient and familiarize themselves with the technology in order to be able to use it effectively. It is imperative that adequate resources are channelled towards capacity building and training activities and that governments, DPOs [4]and industry work together to identify appropriate implementation strategies.

The Road Ahead

To surmount all the challenges to accessibility and achieve universal inclusion, we need to achieve a solution through a mix of policy formulations and practical interventions in which all stakeholders participate i.e., by following both a top down and bottoms up approach. Incorporating accessibility and universal design principles uniformly across all services and products will ensure accessibility not only to the disabled, but also to the other categories of users who are unable to access such as elderly and illiterate persons, linguistic minorities and those with limited bandwidth. It will also reduce the long term cost and effort associated with retrofitting things to make them more accessible at a future date.

DPOs [4] around the world are also trying to work with industry to leverage the business case in making products which are universally inclusive and develop solutions which are more widely available in the market, rather than created exclusively for a niche community. Considering that persons requiring accessible products constitute nearly half of the world’s population (including seniors, illiterate persons and other categories), there are clearly huge market opportunities for business houses to follow. For persons with disabilities, an increase in the number of manufacturers creating accessible goods would help drive down prices and increase variety. A good case in point is that of NTT Docomo in Japan which increased its market to over 70 per cent after it surveyed the demographics of elderly and disabled persons and brought out a new line called Raku Raku phones. Within three years, this line sold over 15 million handsets since even persons without disabilities found accessibility features like high colour contrast, large icons and digits etc more comfortable to use.

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. Any effort, whether it is making one’s website accessible and ensuring that all information published is accessible to persons using assistive technologies or participating in awareness raising, capacity building, creating employment opportunities for the disabled, supporting advocacy activities or on ground projects of DPOs such as conversion of books, is significant and brings us nearer to achieving our vision ― an inclusive world.

Download a scanned version of the article published in the Hans Foundation's Annual Review 2011 here [PDF, 4.09 MB]

[1].A software which will read out what appears on the screen.

[2].For example, in India text to speech software is not available for all the 25 official Indian languages but is only available for English and a few other languages, which results in the exclusion of a large proportion of the population.

[3].For instance,instead of creating a proper pdf document, if one converts a scanned image of a document (instead of text) to pdf, it will not be readable by a screen reader.

[4]Disabled Persons Organizations.

For more details visit https://cis-india.org/accessibility/barriers-to-access-connected-world

Right to Knowledge for Persons with Print Impairment: A Proposal to Amend the Indian Copyright Regime

praskrishna — 2011-08-22T13:17:33Z

This research paper argues the need for amending the Indian Copyright provisions for enabling the print impaired to gain access to published works. The paper was submitted to the Ministry of Human Resource and Development in November to appraise it of the needs of the print disabled community. The paper is up for public comments and we welcome your feedback for this ongoing campaign.

For more details visit https://cis-india.org/accessibility/publications/Case%20for%20Amendment%20of%20Copyright%20Regime%20in%20India%20November%2022-%202009.pdf

Right to Knowledge for Persons with Print Impairment: A Proposal to Amend the Indian Copyright Regime

praskrishna — 2009-12-04T10:18:45Z

This research paper details the need for an amendment of the present provisions of Copyright laws and help enable the print impaired gain access to published works. The paper was submitted to the Ministry of Human Resource and Development in November to appraise it of the needs of the print disabled community. The paper is up for public comments and we welcome your feedback for this ongoing campaign.

For more details visit https://cis-india.org/accessibility/publications/uploads/Case%20for%20Amendment%20of%20Copyright%20Regime%20in%20India%20November%2022-%202009.pdf