Delivering Digital Britain: The Interim Report
Comments from Royal National Institute of Blind People (RNIB)
RNIB welcomes the Digital Britain Interim Report and the emphasis the government is putting on the digital information and communications sector.
Digital Inclusion is not just a vital sector for the economy, but also for the inclusion of disabled people and indeed all people in society. RNIB is therefore taking this opportunity to comment on the Report in the interests of helping to ensure that the Digital Britain initiative serves blind and partially sighted people as well as their sighted peers.
Blind and partially sighted people rely on and want to use the digital world as much as, and in some cases more, than their sighted peers. What is more, technology can be empowering for blind people. Whereas a few short years ago a blind person would have relied on somebody else to read their correspondence, text-to-speech screen readers provide a speedy and autonomous alternative. Internet shopping can enable a blind person -who finds it hard to travel to a shop- to purchase the goods they need without leaving their house.
We recently responded to “Delivering Digital Inclusion: An Action Plan for Consultation”. We will not repeat the content of that response here, but we append our response at the end of this document for ease of reference. However, we wish to recall that:
· Using information and communication technology (ICT) and mobile phones has become a key skill for everyday living, enabling access to services, products and leisure opportunities as well as education and employment. These technologies have the potential to be very empowering, further improving independence.
· Blind and partially sighted people face particularly severe obstacles due to the inaccessibility of equipment and services and this restricts their use and enjoyment of digital technologies.
· RNIB believes government leadership is absolutely vital at this time, and we made several recommendations to the DCLG in our comments on digital inclusion
We believe it is vital that the Digital Britain initiative take fully into account the inclusion of blind and partially sighted people. RNIB is pleased therefore that one of the five objectives in the Digital Britain report covers “fairness and access for all”. We are concerned however that neither people with sight problems nor disabled people in general are specifically mentioned at any point in the interim “Delivering Digital Britain” report.
RNIB Comments on specific proposed actions
We concentrate our comments below specifically on the proposed actions in the Digital Britain report, focusing on those of most relevance to blind and partially sighted people.
ACTION 7
We will consider at what point and at what cost the standard offer provided by the Digital Television Switchover Help Scheme could have a return path capability, and we will ensure that such capability is available as an option.”
RNIB was a chief driver behind the Help Scheme, and we welcome the report’s acknowledgement of the use of the Help Scheme and its possible relevance to the roll-out of broadband. A return path could enable access for many people who would otherwise be at risk of exclusion from digital services. As such RNIB welcomes this work. Furthermore, we believe that early work should be undertaken to ensure that any “return path” capability that is devised is made accessible to blind and partially sighted people so they are not excluded from this option. This would have to be done through inclusion of text to speech solutions that read out information on the screen, similar to computer screen reading technology.
However, RNIB is also concerned that the roll-out of broadband through the help scheme should not be done to the detriment of first and foremost resolving the inaccessibility of digital TV equipment for blind and partially sighted people. RNIB therefore suggests that money within the digital switchover Help Scheme should above all earmarked to enable voice output for digital TV menus and EPGs before other developments such as return paths are incorporated.
RNIB also believes that the obligations regarding equipment accessibility (section 10 Communications Act) need to be strengthened, as the current duty on Ofcom to encourage manufacturers is not leading to significant tangible improvements.
ACTION 8
“We will examine how the marketing and communications activity around Digital Switchover could be enhanced to use the region-by-region programme of publicly funded information and advice on one form of digital transition to provide impartial information on wider opportunities of digital beyond digital broadcast television.”
RNIB welcomes this approach, but urges the government to ensure that messages about digital TV switchover are not confused with messages about other digital opportunities. We therefore suggest that the marketing and communications activity around digital switchover remains narrowly focused on TV until a region has gone digital, but that other digital transmissions can be promoted soon after a region as switched. In addition, communications on other digital transmissions such as digital radio and broadband, should be suitably adjusted to ensure that blind and partially sighted people and other disabled people are well informed to choose equipment and services that are most accessible and usable for them.
ACTION 9
“We will take action to support DAB digital radio in seven areas:
a. We are making a clear statement of Government and policy commitment to enabling DAB to be a primary distribution network for radio;
b. We will create a plan for digital migration of radio, which the Government intends to put in place once the following criteria have been met:
– When 50% of radio listening is digital;
– When national DAB coverage is comparable to FM coverage, and local DAB reaches 90% of population and all major roads.
c. We will create a Digital Radio Delivery Group which includes the retailers, the Transmission Networks, the BBC, the Commercial Radio Companies, the Car Manufacturers, consumer representatives and the device manufacturers whose role would be to increase the attractiveness, availability and affordability of DAB and to advise on the Digital Migration Plan.”
RNIB welcomes the recognition that more work is needed on Digital Radio as outlined under action point 9. However we consider that the interim report fails to recognize the level of consumer resistance to a switch to digital radio. It also omits some specific consumer needs that must be addressed and a requirement for the same level of consumer involvement as that which is currently taking place in the switch to digital television. We ask the team to take more account of the report of the consumer impact group of the DRWG into the switch to digital radio. [1] RNIB as well as other organizations representing the more vulnerable consumers contributed to this report and its recommendations should not be ignored. In particular, RNIB wants to re-iterate:
1. The proposed migration criteria of 50% of all listening through digitally enabled devices is too low, and disproportionately affects disadvantaged groups who are less likely to be represented in the first 50% to take up digital radio. We would therefore like to see the 50% figure analysed in more detail and a stronger case made for it.
2. A help scheme will be essential to assist those where the cost of migration is significantly greater than the benefit.
3. The current consumer uses and preferences in radio receivers are not fully understood, particularly among the most vulnerable groups who are also those most dependant on radio. Before a switch to digital can begin research should be undertaken to examine the extent of ownership and usage of analogue and digital radio, particularly amongst disabled people, older people, people whose first language is not English and consumers from low income households.
4. We note that part of the role of the delivery group will be to increase the attractiveness, availability and affordability of DAB. This misses the concerns of expert consumer organisations such as RNIB who commissioned research into the design of sets. This research highlights the needs of blind and partially sighted and the gaps in usability of equipment overall. [2]
5. We are concerned that consumers should have clear and impartial information on all equipment and a kite mark scheme that indicates usability as well as essential technical reliability should be provided.
ACTION 17
We will develop plans for a digital Universal Service Commitment to be effective by 2012, delivered by a mixture of fixed and mobile, wired and wireless means. Subject to further study of the costs and benefits, we will set out our plans for the level of service which we believe should be universal. We anticipate this consideration will include options up to 2Mb/s.”
RNIB supports such a move. A universal service obligation for broadband and mobile is something RNIB has long called for. It is crucial that those furthest from these services are able to access them. By “access”, we do not just mean physically being able to get to a computer. For blind and partially sighted people, access to ICT requires that the hardware, network and accompanying information are all designed or adapted for people with sight loss. Websites must be navigable for people using text-to-speech screen readers, for instance. Help with setting up computers, and helplines for problem solving are also necessary to ensure that blind and partially sighted people have full access to ICT. It is also very important that the affordability of services is taken into account when trying to ensure their accessibility. Unless a service is affordable, it cannot be deemed accessible. Affordability is a particular concern for blind and partially sighted people, many of whom are among the poorest of the UK’s citizens.
ACTION 19
We will encourage the development of public service champions of universal take-up. The Digital Inclusion Action Plan recommended the appointment of a Digital Inclusion Champion and expert taskforce to drive the Government’s work on digital inclusion. Clearly, the work of the Champion will be important in encouraging take-up.”
As mentioned above, RNIB has submitted comments to “Delivering Digital Inclusion: An Action Plan for Consultation”. (See annex below).
We welcome the fact that the Digital Britain Report says
“The Digital Britain team will work together with the Digital Inclusion team in Government and, when appointed, with the external Digital Champion to ensure that the Digital Britain project and the Digital Inclusion programme continue to be closely aligned.”
We urge the government to ensure that disabled peoples’ organisations will be an intrinsic part of this work.
In our response to “Delivering Digital Inclusion: An Action Plan for Consultation”, we questioned whether the envisaged role of the Digital Champion would be ambitious enough given the scale of the challenge ahead. We maintain that the powers and influence of the Digital Champion certainly need to extend further than those enjoyed by the former e-Envoy.
We accepted that a Digital Inclusion Champion and a Charter for Digital Inclusion are good ideas, but said that for blind and partially sighted people progress depends on the UK Government taking action which will ensure that the digital environment in the UK is fully accessible to blind and partially sighted people. This means that the issue of equipment accessibility has to be tackled. Too often inaccessible equipment, that assumes that the user can read on-screen information without providing a voiced alternative is the main barrier to uptake of services by blind and partially sighted people. For example, recent research by i2 media research, looked at how accessible the functional and design features of digital radios are for blind and partially sighted people, people with dexterity problems or dyslexia. The results show that 90 percent of blind and partially sighted people using a digital radio without voice output need help the first time they use their radios. 70 percent continue to need support for subsequent use, whereas this figure is less than 20 percent in the general population and voice output gives blind and partially sighted people a level playing field![3]
RNIB believes a Digital Inclusion Champion can play an effective role in championing improved public procurement processes, working with the Office for Government Commerce, BERR, the Government Equalities Office and other relevant agencies to produce revised guidance applicable across the public sector. For instance one of the most effective things they could do would be to promote the recognition of social criteria in public procurement processes.
We believe that the Digital Inclusion Champion should have an advisory panel that they can regularly refer to, and have a role in demystifying digital technologies and facilitating dialogue between users (and potential users) of technologies and service providers.
ACTION 21
A Public Service Delivery plan: we commit to ensure that public services online are designed for ease of use by the widest range of citizens taking advantage of the widespread uptake of broadband to offer an improved customer experience and encourage the shift to online channels in delivery and service support.”
This is extremely important for blind and partially sighted people. More and more services are being delivered online, which makes access to websites more vital than ever for all citizens. Many disabled people rely even more on public services than their non-disabled peers, for a variety of reasons. A blind person might well have greater difficulty in visiting their council, for instance, and would therefore benefit greatly from being able to access the council’s website. However, a recent EU wide survey found that only some 5% of public websites are accessible. RNIB therefore urges the government to take urgent action to improve the accessibility of public websites.