Centre for Internet and Society

Department of Information Technology Meeting on a National Policy on E-Accessibility

nirmita — 2011-09-22T12:32:54Z

On 30 January 2009, the Department of Information Technology hosted a meeting in New Delhi bringing together important stakeholders to discuss the issue of electronic accessibility for the disabled and persons with special needs in India.

Creating a barrier free internet is vital to creating a pluralistic and democratic virtual environment, where all groups irrespective of disability or levels of literacy are able to access culture and knowledge goods and services which are available on the internet today. Since its inception last year, CIS has been campaigning for legislative, administrative and legal interventions in the area of web accessibility for the print disabled and working with different groups towards the common goal of having a National Policy on Electronic Accessibility in India.

On 30 January, the Department of Information Technology (DIT) called a meeting of all stakeholders to discuss the issue of web accessibility for disabled persons and persons with special needs. The meeting was attended by 34 key persons from the Government and private organisations around India. Sunil Abraham (Director--Advocacy, CIS) and Nirmita Narasimhan (Programme Manager, CIS) were amongst the attendees (a complete list of attendees is given below).

The meeting was chaired by N. Ravi Shankar, Joint Secretary, DIT, who in his opening remarks briefed the gathering about the initiatives of the Government in this area. He talked about the Government’s goal of providing Universal Accessibility and Internet for all. He informed the gathering that the DIT had already initiated schemes for ICT empowerment of visually impaired/hearing impaired children; under these schemes, 21 ICT Vocational Centers had already been set up and 100 additional ICT vocational centers would be set up in phase II. Additionally, he explained that the issue of Universal Accessibility had been internationally addressed at the Internet Governance Forum (IGF) 2008 held in December 2008 in Hyderabad. He stressed the need for initiating inclusive developmental activities in the e-governance programme of DIT and language initiatives of TDIL (Technology Development for Indian Languages), in order to increase coverage and diversity, culminating in education for all alongside Internet for all.

Dr. Govind, Senior Director and Head of Department, E-Infrastructure and Internet Governance Division in the Ministry, highlighted the issue of web accessibility for visually impaired and other differently able persons and the need for initiating a concrete action plan for the same.

Javed Abidi, Director, National Center for Promotion of Employment for Disabled People talked at length about the need for web accessibility and proposed that the government should set a time line within which all existing government web sites should be made standards compliant. All new web sites should be created keeping compliance with WCAG 2.0 in mind right from the start and proposed that for existing web sites, we should adopt a staged approach and aim at ensuring complete compliance at least by 2010-2012.

Ms. Neeta Verma, Sr. Technical Director, NIC gave a presentation on the issues related with making web accessibility universal. She said that NIC has formulated guidelines for government websites, in association with DIT and DARPG. Compliance to these guidelines shall make Indian government websites Usable, User Centric and Universally Accessible. She proposed that even the Manual of Procedures (MoP) used in the Govt. should mandate Universal Web Access for Government business and day to day activities. Websites should not only be designed once for accessibility but also need to be sustainable in the long run.

All attendees gave their inputs on the issue of web accessibility. Shri Jaijit from Sun Microsystems stressed the fact that the need for standards was not essential for disabled persons alone, but was necessary for other groups as well, such as illiterate persons. Ms.Shilpi Kapoor from Barrier Break Technologies mentioned that most government web sites had to firstbe be made html compliant in order to be standards compliant and stressed the need for training, resource generation and sensitization. Shri Minocha, Director, NAB felt that a law similar to the one in USA should be implemented which mandates that any web site developed had to be Universally Accessible. He asked the Government. to look at daisy guidelines, digital library and procurement policy for differently abled persons. He strongly urged the Government to take into account not merely standards of website accessibility, but also brouser standards, document standards etc, since an accessible web site was not of much use if the content posted on it was in an inaccessible format. He also appreciated the efforts of NIC and C-DAC towards working for open source and cited the example of the Venezualian Government. He proposed that DIT should initiate a technology development or customization project in this area. Shri Vijaiy Krishnamani from Infosys stressed on the need for creating a common simple usable interface rather than multiple types.

Shri Vijay Kapur from Microsoft proposed for implementation of WCAG1.0 & 2.0 standards to bring out interactivity in web content like Arya and the Clint side document accessibility through the daisy consortium.

Shri Rajesh Aggarwal, CEO, NIXI offered complete support for all initiatives in the area of web accessibility and voiced the opinion that all software produced out of public funds should be made available in the public domain so as to encourage research and innovation. In addition to policy advocacy, he was also supporting a capacity building and awareness workshop on web accessibility for web developers from all over the country which was being organized by CIS in Ghaziabad from Feb 16th-18th. Smt.Jayalakshmi Chittor of CSDMS proposed that an audit process should be evolved to check government web sites for WCAG 2.0 compliance and cited the example of Malta for policy in this area. Some other issues which were stressed time and again by other attendees were the legal mandating of adherence to standards within a fixed time period, adequate representation of Indian language in Unicode format, adherence to WCAG 2.0 and not merely 1.0, supporting voice enabled web sites etc. Sunil Abraham Director Centre for Internet & Society (CIS) lauded the DIT/MCIT for the timely and critical accessibility initiative and strongly endorsed the suggestion to create a national policy document mandating accessibility for all publicly funded electronic infrastructure. CIS offered to provide a comparative analysis of national electronic accessibility policies from developed and developing countries and also prepare a draft policy for DIT/MCIT. Further, he urged DIT/MCIT to advocate for the adoption of the proposed WIPO Treaty for improved access for the blind, visually impaired and other reading disabled put forward by the World Blind Union and knowledge Ecology International.

After the round of discussions the following recommendations were made to the DIT/MCIT:

i) The Government should formulate a national policy to mandate necessary guidelines so that the web sites are standards compliant for universal web accessibility.

ii) Steps should be taken for sensitization and awareness generation towards this issue through trainings, publicity, workshops, conferences.

iii) R&D projects should be initiated for development of screen readers in Indian languages and other tools for universal web access.

Attendees

Shri N. Ravi Shanker, Joint Secretary, DIT, New Delhi - Chairman
Dr. Govind, Sr. Director, DIT, New Delhi
Shri Mohan Ram, ED, ERNET India, New Delhi
Shri Rajesh Aggarwal, Additional CEO, NIXI, New Delhi
Shri Javed Abidi, Director, National Center for Promotion of Employment for Disabled People (NCPEDP, New Delhi
Shri Dipender Minocha, Director, NAB, R.K. Puram, New Delhi
Ms. Neeta Verma, Sr. Technical Director, NIC, New Delhi
Shri A. Bandopadhyay, GM, Webel Mediatronics Ltd., Kolkata
Mr. Sunil Abraham, Director – Policy, Centre for Internet & Society, Bangalore
Ms. Shilpi Kapoor, Founder and Managing Director, Net Systems Informatics (I) Pvt. Ltd. and Barrier Break Technologies, Mumbai
Shri Vijay Kapur, Microsoft India, New Delhi
Mr. Rahul Gonsalves, Web Accessibility Consultant, Bangalore
Jyotindra V.Mehta, Advisory Systems Consultant, IBM Global Services India
Mr. Zamir Dhale, Sense International India Office, Ahmedabad Gujarat
Shri Jaijit Bhattacharya, M/s Sun Microsystems, New Delhi
Ms. Jayalakshmi Chittor, CSDMS, Noida, U.P
Shri Manoj Jain, TDIL, DIT, New Delhi
Ms. Gitanjali Sah, UN Solution Exchange, New Delhi
Shri Pradeep Gupta, Managing Director, Cyber Media India Ltd., Gurgaon, Haryana
Shri Vijay Krishnamani, Infosys, New Delhi
Shri Ajai Kumar, C-DAC, Pune
Shri Indranil Das Roy, M/s Webel, Kolkata
Shri Deepak Maheshwari, Microsoft India , New Delhi
Shri Vikas Goswami, Microsoft India, New Delhi
Ms. Helen Mahtani, Programmer, NCPEDP, New Delhi
Shri Muthamma B. Devaya, Senior Program officer, NCPEDP, New Delhi
Ms. Nirmitha Naresimhan, Centre for Internet & Society, Bangalore
Ms. Tejal Tiwari, ERNET India, New Delhi
Shri D.P. Misra, NIC, New Delhi
Shri Sachin Rizal, Sense International (India) Ltd., Ahmedabad Gujarat
Ms. Ritu Srivastava, CSDMS, Noida
Shri Santosh Kumar Gupta, CSDMS, Noida, UP
Shri Rajan Varada, UN Solution Exchange, New Delhi
Shri S.K. Aggarwal, Scientist ‘F’, DIT, New Delhi - Convenor

For more details visit https://cis-india.org/openness/blog-old/meeting-by-the-dit-on-a-national-policy-on-e-accessibility-at-delhi-on-jan-30th-2009

Copyright Challenges for Print Impaired Persons in India

nirmita — 2011-08-17T08:51:33Z

Print impaired persons in India face several hurdles in accessing reading materials- the biggest one being the Indian Copyright Act 1957

Background

The Indian Constitution guarantees citizens fundamental rights to dignity, to read, to education, to information and to expression.
India has approximately 70 million disabled persons who are unable to participate in the social, cultural and political life of the country because they cannot access materials in the printed form. These include persons with visual disabilities, persons whose physical impairments prevent them from holding or turning pages of a book and persons who have a learning disability like dyslexia. These groups can access reading materials if they are converted into formats which can be accessed by them in an alternate manner using assistive technologies.
Recent developments in technologies such as screen reading and OCR technology, electronic tactile devices, evolution of multiple audio, audio-video and electronic formats, DAISY etc which can be adapted for use in a multiplicity of platforms have opened up innumerable possibilities for persons with different abilities to access information independently and participate in society.
The process of conversion of a printed book into an alternate accessible format such as large print, audio, Braille and electronic formats involves special effort in terms of obtaining permissions from copyright holders, possessing manpower, infrastructure and monitory resources, concerted involvement of intermediary agencies undertaking conversion and the presence of an effective distribution model.

Challenges in India

Today, print impaired persons in India are faced with several problems that hamper their participation in society-

Lack of availability of affordable technological solutions in English as well as local languages
Lack of availability of printed materials in formats that can be accessed using these technologies
Failure on the part of technology and web developers to adhere to principles of universal design which ensure that web sites are accessible to persons with disabilities
Lack of accessible or compatible mainstream technologies to work with special technologies
Lack of an enabling legal regime.

Disability Awareness around the world

The United Nations declared the decade of 1983-1992 as the decade of Persons with Disabilities and the decade of 1993-2002 as the Asian and Pacific decade of persons with disabilities. The United Nations Convention on the Rights of Persons with Disabilities came into force from 2008.
International bodies like the World Wide Consortium (W3C) and the Daisy Consortium have come out with standards and guidelines which will make the web and publications on the web universally accessible.
The World Blind Union (WBU) has recently proposed a Treaty for the Blind, Visually Impaired and other Reading Disabled, (referred to as the “VIP initiative”) which seeks to harmonise limitations and exceptions at a global level so that countries around the world can freely share knowledge in accessible formats for print impaired persons. This Treaty is now being proposed by three Latin American countries and is presently tabled before the WIPO and is under discussion.

Position in India

The Indian Copyright Act 1957 does not make any provision for the conversion and distribution of books in accessible formats for print impaired persons. Hence organisations serving the print impaired have to get permissions from copyright holders to undertake conversions. Further, Indian organisations are not able to borrow accessible materials from libraries in other countries since the absence of such a provision in our fair dealing clause prevents countries from lending books to print impaired persons in India.
In the case of books published in India, there are no accessible copies readily available in the market and while many publishers in principle are not averse to giving permission, the unwanted fear of piracy and lack of awareness prevents them from allowing organisations to undertake conversions. Consequently print impaired persons are denied the freedom to choose and read any book which is freely available to the public.
In the light of increasing global attention in this matter and in the interests of the large print impaired community in India, we need to have a clear position in our law with regard to converting materials into accessible formats for print challenged persons. It is important to understand this as not merely a legal issue, but also as a social and economic cause. We need to work at various levels to solve this problem:

We need to work towards legally binding norms both at a national as well as international level. We can achieve this by supporting the proposed treaty for improved access for the visually impaired at the WIPO, and by ensuring that necessary amendments are immediately incorporated into the Copyright Act, which afford flexibilities for conversion into accessible formats for print Impaired person.
Publishers, copyright holders, organisations and print impaired persons should work collaboratively towards conversion and distribution of published works in accessible formats. Publishers should give digitised copies of books in an accessible format to recognised organisations serving the print Impaired and in return these organisations should set up a distribution mechanism which will ensure that these accessible books get circulated only within the print impaired community and do not find their way into the mainstream market.
Publishers should explore the large market in India for selling books in electronic, audio and other accessible formats along with the print copy. These copies should be available in the market at the same time and at the same price that the print copy becomes available. In the case of electronic copies, publishers may also consider selling the books at a price which is lesser than the price of the print version since this will not involve cost of paper publication.
Publishers should adopt a standard format for creating digital masters of their publications so that all distribution formats including hard copy print, braille, talking book and digital publications can be derived out of it without wastage of resources on conversions and reproduction of books in accessible formats.
The government should frame incentive schemes for publishers and other persons developing technologies to encourage them to create accessible versions of their content and technologies.
We need to work towards ensuring at least the minimum basic study and reference materials which are required for children with print disabilities to complete their school and college level education in all subjects and languages.
We need to encourage peer to peer models amongst disabled persons and organisations for sharing and generating more accessible content.
We need to work towards establishing public libraries and repositories of accessible content with a healthy system of exchange amongst them.
Work towards generating more Indian language content and developing technologies such as text to speech synthesisers which support regional Indian language content.
We need to work towards facilitating cross-border exchange of books so that persons in India get exposure to foreign authors and also ensure that persons abroad are able to read Indian literature. Libraries in India should be able to freely exchange books with libraries in other countries.
We need to spread awareness about the importance of building in accessibility right at the start so that not much time, effort and money is wasted at a later stage in converting materials into accessible formats.

For more details visit https://cis-india.org/accessibility/blog/copyright-challenges-for-print-impaired-persons-in-india

Copyright Amendment Bill in Parliament

nirmita — 2011-08-30T09:26:44Z

The Copyright Amendment Bill is expected to be presented in the Rajya Sabha by the Minister for Human Resource and Development, Kapil Sibal today afternoon. The much awaited Bill (since it has been in the offing since 2006) has undergone significant changes since its initial appearance.

Given below is a very quick first cut highlight of the Bill from a public interest perspective. A more detailed analysis will follow after the session discussions.

Parallel imports: The parallel imports clause which had been put in as sec 2(m) has now been dropped from the present draft. This is a big setback because educational institutions, libraries and archives, second hand book, etc., were looking to this provision to bring down the prices and hasten the availability of books. This also affects persons with disabilities since they will be unable to import books in accessible formats.
Persons with disabilities: There are two provisions relating to persons with disabilities which have been introduced. Section 52 (1) (zb) relates to the conversion, reproduction, issues of copies or communication to the public of any work in any accessible format, provided that these activities are meant to enable access to persons with disabilities and sufficient safeguards are taken to ensure that these materials do not enter the mainstream market. This section in a sense is broader and more encompassing than some provisions found in other countries, which relate exclusively to the blind or visually impaired. This section would adequately cover persons with other disabilities who cannot read print. A new section 31B also provides for compulsory licensing for profit entities wishing to convert and distribute works in accessible formats, provided that they are primarily working for persons with disabilities and are registered under sec 12A of the Income Tax Act or under chapter X of the Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995.
Many exceptions under 52 (1) (i) relating to fair dealing have been extended to all works except computer programmes. New sections 52 (1) (b) and (c) protect transient and incidental storage from being classified as infringing copies, which offers protection to entities such as online intermediaries.
The scope of compulsory licensing under sec 31 has been expanded from ‘any Indian work’ to ‘any work’. Three new sections 31 B, 31C and 31 D have been introduced. Section 31 B has already been described in the paragraph on persons with disabilities. Section 31 C lays down strict measures relating to statutory licensing in case of cover version, being a sound recording of a literary, dramatic or musical work. Section 31 D relates to statutory licenses for broadcasting organizations wishing to broadcast a literary or musical work or sound recording.
Non commercial public libraries can now store electronic copies of any non digital works they own (52(n)).
The new Bill introduces Technological protection measures (65A and 65B) and makes circumvention and distribution of works in which rights managements systems have been removed an offence which is punishable with imprisonment upto two years as well as fine. In addition the copyright owner can also avail of civil remedies. As such India is not really required to have these provisions in the copyright legislation since we are not yet a signatory to the WCT or the WPPT and such provisions will hamper consumer interests.
Terms of copyright have been increased significantly without reason, thus preventing works from falling into the public domain. For instance, the term of photographs has been increased from 60 years to life of the photographer plus 60 years. This is far in excess of the minimum term stipulated by international treaties.

For more details visit https://cis-india.org/a2k/blogs/copyright-bill-parliament

Comments to the GIGW

nirmita — 2015-05-09T16:00:11Z

The Centre for Internet and Society submitted its comments to the National Informatics Centre on April 30, 2015.

We the undersigned would like to commend the NIC for taking a leadership role in promoting eaccessibility through the notification of the Guidelines for Indian Government websites (GIGW) in 2009. Undoubtedly, web accessibility plays an ultimately crucial role in enabling and enhancing citizen participation and access to information. The development of assistive technologies both hardware and software has increased the potentiality of the constituency of persons with disabilities and elderly to become one of the largest consumer groups on the Internet. We use the word ‘potentiality’ because the current information ecosystem on the Internet, comprising information through text, electronic documents, audio, video and other multimedia presented through Indian websites are inaccessible for persons using screen readers and other technologies.

Despite the passage of 6 years since the GIGW, there has been negligible progress on the front for making Indian government websites conform to the notified standards. An evaluation of accessibility of government websites carried out in 2012[1] demonstrated that the majority yet remained inaccessible, with very slow improvement in the situation thereafter. Our interaction with government departments and government web developers revealed that there was still a relative lack of awareness of the need to conform to these guidelines coupled with an absolute lack of knowledge on how to implement them. Given this background, we submit our recommendations as below:

Mandatory: Since experience has demonstrated that voluntary compliance has not worked to bring about accessibility in government communication through the Internet, it is necessary that these guidelines be made mandatory with a strict deadline beyond which noncompliance becomes an offence, to ensure that it is taken seriously. This is now partly in place since the notification of the National Policy on Universal Electronic Accessibility[2] by the DEITy in Oct 2013. The legal mandate around this will only strengthen once the Rights of Persons with Disabilities Bill comes in force. Hence, the present recommendation.
WCAG 2.0 level AA compliance: We recommend that WCAG 2.0 level AA be specified as the standard for minimum level of compliance in the guidelines. This is recommended for several reasons.
a. These are globally accepted standards which have been well researched
b. These have assigned success criteria for each guideline, which is not present in the current draft of guidelines, thus enabling a developer to know whether the criteria have been adequately met.
c. The task of review is a constant one which is being undertaken by experts around the world through various study groups and technical committees, which will ensure that updates are timely and keep abreast of new developments. Hence, the burden of review will not be upon us. At present, we also do not have the domain expertise on this subject which is available with W3C and elsewhere globally. Instead, efforts may be focused upon making any additions to the WCAG 2.0 which are required to make them more comprehensive in the Indian context.
Meeting success criteria: For each accessibility checkpoint / guideline, there should be defined success criteria to ensure that the implementation meets acceptable levels. There should be Objective measures in place to have technical validation of all the websites. There needs to be a process defined to validate all websites on WCAG accepted tools to ensure compliance to technical standards. The recommended procedure provided by the W3C for evaluating websites known as the Website Accessibility Conformance Evaluation Methodology 1.0[3] (WCAG-EM) may also be followed in this regard.
Onus of implementation: The onus of complying with the Guidelines must be placed on the top management in an organisation/ department/ ministry. Someone like a board member or other senior person.
Accessibility audit: There should be an accessibility audit after the development of a website by a 3rd party entity independent of the website developer and website owner.
Accessibility audit agency: There must be a provision to setup an entity which can perform access audit for all government websites. The agency may include government officials from various departments, ministries or autonomous bodies, leading accessibility firms and must include end users.
Content updation: To ensure the accessibility of new content that is added to a website on a regular basis, there should be a defined accessibility process so that an existing system that is accessible is not broken.
Clarity in the specifications: There should be clear guidelines to make it easy to comprehend for all and not just a technical person. At present, some of the guidelines are ambiguous and may not be easily discernible even to an experienced developer or website development agencies who are not domain experts. For example, guideline5 states: ‘Information structure and relationship is preserved in all presentation styles’. This guideline could be clearer if it specified that tabular information should be specified with table tags, labels should be marked with label tags, Headings should be marked with heading tags. Etc. This reiterates the earlier point that adherence to WCAG 2.0 is best since it provides developers with resources such as Understanding WCAG 2.0 and Techniques for WCAG 2.0 documents. Another example is guideline 19- ‘There is adequate contrast between text and background colour’. However, it is unclear as to what is meant by ‘adequate’. WCAG 2.0 on the other hand, specifies the contrast for each level. IT specifies acceptable colour combinations for background, foreground and text which increase accessibility.
Stress on implementation: A lot of attention should be given to implementing the guidelines. The fact that there has been minimal success in adoption of the guidelines makes out a clear case for a stronger awareness strategy and adoption action plan, with a dedicated team or department in place within NIC which can work towards supporting training and retrofitting efforts with different government departments and agencies around the country. This also calls for a two tier team approach, one at the central level, with contact points set up for each state which are responsible for this implementation, with the time limit for enforcement of these guidelines. For this purpose, partnerships may be sought with private players and organisations serving the disabled and accessibility experts.

We are available to help this endeavour and are happy to provide support whether in the form of clarifications, feedback or any other manner. Our contact details are given at the end of this submission.

[1]. Accessibility of Government Websites in India: A Report (by CIS and Hans Foundation): http://cisindia.org/accessibility/accessibility-of-government-websites-in-india

[2]. Available at http://www.ncert.nic.in/announcements/notices/pdf_files/Nationalpolicyonuniversal.pdf

[3]. Available at http://www.w3.org/TR/WCAG-EEM/

Click to download the submission file.

For more details visit https://cis-india.org/accessibility/blog/comments-to-gigw

Comments on the draft Rights of Persons with Disabilities Rules

nirmita — 2017-03-29T03:41:25Z

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

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

Introduction

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

Accessibility of the draft rules document

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

Policy/Guidelines on accessible communication

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

Reasonable Accommodation

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

Standards and Guidelines

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

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

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

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

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

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

Training and Support

Monitoring and reporting

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

National fund

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

Office of the Chief Commissioner

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

Transparency

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

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

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

nirmita — 2017-05-19T15:33:41Z

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

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

Accessibility of the document:

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

Title and content presentation:

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

Preliminary sections:

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

Content and communication:

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

Accessibility of technologies:

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

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

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

Comments on Mobile Accessibility Guidelines

nirmita — 2018-01-03T02:37:10Z

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

Consolidated comments on mobile application guidelines:

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

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

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

Download the full submission here

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

Comments on Guidelines for Indian Government Websites

nirmita — 2017-11-26T07:08:25Z

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

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

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

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

nirmita — 2017-02-28T15:58:55Z

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

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

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

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

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

Background

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

Long Term Vision by 2030

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

Seven Years' Strategy

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

Three Years Strategy

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

[1]. Section C.6

[2]. Section D.6

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

[4]. Chapter VIII, Section 46

[5]. Section D.7

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

Collaborative Projects Programme

nirmita — 2008-09-22T20:14:25Z

For more details visit https://cis-india.org/research/grants

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

CIS comments on WIPO Treaty

nirmita — 2013-01-28T11:16:44Z

Nirmita Narasimhan of CIS has given her reply comments to the US Copyright Office's call for comments on the proposed WIPO draft proposal to facilitate access to copyrighted works for persons who are blind or have other reading disabilities, in response to the Federal Register Notice of October 13, 2009.

The US Government had called for comments on the proposed WIPO treaty for the visually impaired shortly before the 19th SCCR to which organisations responded from different parts of the world. CIS' comments on the Treaty were also filed with the US Government and are available on their website at http://www.copyright.gov/docs/sccr/comments/2009/reply-2/

SCCR 19: CIS got the status of an accredited civil society in the recent SCCR held at Geneva from 14th-18th of December and had an opportunity to make statements on two of the issues which were being discussed there, namely on the Treaty for the blind, visually impaired and other reading disabled, proposed by Brazil, Ecuador and Paraguay.

Further, for submissions to the DG, WIPO by the visually impaired in India, click on http://www.visionip.org.

For more details visit https://cis-india.org/accessibility/blog/CIS-Comments-on-Treaty

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

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

Bangla eSpeak training with NVDA

nirmita — 2015-07-20T15:02:25Z

The NVDA team conducted an eSpeak training in Bangla on December 19 and 20, 2014 at Blind Empowerment Foundation (BEA) in Kolkata.

The host BEA, had invited 15 teachers and Computer trainers from all across Kolkata and 1 participant was from NAB Jamshedpur. The event was ably supported by two volunteers who helped in the Bengali typing.

The event began with the round of introductions of the participants. The participants also expressed various reasons for participating in the workshop during the introduction. This was than followed by introduction to NVDA and the importance of an Open Source software compared to piracy.

Out of the 15 participants, only two of the participants were using NVDA in their daily use. Hence the session began with the installation of NVDA and its basic configurations and settings. This was followed by the installation of eSpeak and a demonstration was given as to how to use eSpeak for different language options.

Participants were also shown the different advantages of NVDA, in comparison to other screen readers. This demonstration was received very well by most of the participants, as they had never expected NVDA to perform as well.

The post lunch session was dedicated to reading in Bengali. Each participant was given a word file containing current news items in Bengali. The participants started understanding the eSpeak TTS, but showed some reservations regarding its voice. It was explained in detail the reason for the same and why it was important to introduce NVDA with eSpeak to their students at the initial stage of their training in computers.

The host were very generous in their arrangements for lunch and other refreshments. All the participants enjoyed the hospitality, which included a generous serving of the Bengali fish.

Day 2 started with solving querries from day 1 and than typing was introduced using the Bengali Varnmala typing method. Participants were very receptive to this method and were able to type small sentences withing a few minutes. The volunteers who were helping with the typing also emphasized on special words which included special characters.

The post lunch session was dedicated to problem solving and introduction to various Aids and Appliances. The participants were also informed about the ADIP scheme and the appliances available under it.

The workshop was concluded with a round of photos and thanks from the trainers and the hosts.

For more details visit https://cis-india.org/accessibility/blog/bangla-e-speak-training-with-nvda-december-2014