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e-mail: deaforum@ozemail.com.au
Website: http://www.ozemail.com.au/~deaforum	

Submission to

HREOC Inquiry

Accessibility of Electronic Commerce
and other new service delivery technologies for older Australians and people with a disability.

8 December 1999

Contents
													Page

1.	INTRODUCTORY REMARKS	1

2.	COST ISSUES	1

3.	CONFRONTING NEW TECHNOLOGY	1

4.	FUTURE TECHNOLOGY CONVERGENCE	3

5.	RURAL AND REMOTE AREAS	3

6.	NEED FOR DISABILITY CONSUMER VOICES	4

7.	CONFIDENTIALITY AND PRIVACY	4

8.	TRAVEL SERVICES	4

9.	ABOUT THE DEAFNESS FORUM	5
1.	
INTRODUCTORY REMARKS

Since e-commerce involves the conduct of commerce with the assistance of telecommunications and telecommunications-based tools it is of particular importance that it operate in a manner suitable to persons who have difficulty with particular types of telecommunications. People who are Deaf or many who are hearing impaired need different devices or methods to those used by hearing persons in order to facilitate their use of telecommunications.

The comments in the remainder of this submission primarily just outline some issues. The Centre of Excellence for Students who are Deaf and Hard of Hearing (at Northern Melbourne Institute of TAFE), Vicdeaf, the Australian Communication Exchange and the Centre for International Research in Information Technologies (at RMIT University) this year formed a consortium and put a successful tender to the National Office for Information Economy. Their project involved an investigation of "solutions for online access" for Deaf Australians. Very useful and more comprehensive material about many e-commerce issues, as they affect people who are Deaf, is contained in their successful tender proposal.

2.	COST ISSUES

People on a low income may find it more difficult to access the technology required in respect of some e-commerce applications; e.g. the Internet. People in receipt of Disability Support Pension or other forms of income support, because their disability makes it difficult for them to gain employment, are amongst those who fall into the low-income category. If, for example, banks wish to have customers conduct all their transactions via ATMs, telephone or the Internet, then banks have an obligation to make all of those facilities equally accessible and affordable for all customers. If they do not do so, then the banks are guilty of discrimination against those for whom the facilities are not equally accessible or not affordable.

If it is possible to transact business in a traditional way by visiting the office of a business and speaking face-to-face with a member of staff, it is not fair to penalise the customer who has to do that because a disability prevents that particular customer from accessing e-commerce. So, if being Deaf, or some other disability, prevents a person from using a phone, the Internet or an ATM for a bank transaction, then the bank should not charge a fee when that person transacts their business with a teller in a branch. Where people with disabilities are exempted from fees applicable to in-bank services, that exemption should be adequately publicised.

3.	CONFRONTING NEW TECHNOLOGY

There is an access barrier for many persons (including the aged and people with various disabilities) confronting new technology. In respect of older persons, it would seem most appropriate for the government to take action now in the context of International Year of Older Persons. Older people who are Deaf or hearing impaired are just as likely as older hearing persons to find it difficult to adapt to and use new technologies. Indeed, if their deafness has resulted in them having lower than average literacy skills, then they may be more likely to experience difficulties in learning to use new technologies. For some people the issue is their not wanting to learn about the new technology at all.

A couple of years ago, a Deaf member of the Deafness Forum asked a group of about sixty Deaf senior citizens how many of them had and used access to ATMs. About ten hands were raised, suggesting that one in six were confident in using ATMs. When asked for reasons why they did not use ATMs, the non-users generally said they could not understand the instructions and did not feel comfortable using computers. Without training or information they could readily understand, these people could not move to using ATMs. Those who had taken the step had generally been encouraged to do so by family members (mostly adult children) who, in most cases, had gone to the bank with them to assist with forms’ completion, etc. Since English is a second language for the majority of people who are Deaf, there would be considerable merit in providing a choice of languages for receiving ATM instructions including Auslan sign language.

Telephone banking is another area where older Deaf and hearing impaired people, like older hearing people, can experience difficulties. Menu driven telephone transactions can be a nightmare for hearing impaired people. They can be following through the process and then not be able to understand just one word, which can leave their transaction in limbo. For example, one hearing impaired person has advised that, while using Bpay, she could not understand that she was being asked to enter the “Branch number” for the account she was attempting to pay. When the fee for telephone banking is much lower than the fee for the same transaction undertaken in a branch, then a hearing impaired person unable to use telephone banking is, effectively, subject to discrimination. Some menu driven services are better than others, as the recorded messages are delivered more clearly and slowly. There may well be a place for a standard relating to message clarity.

Speed of speech and clarity are also a big issue in respect of recorded answering messages, such as those that advise callers to call another number. A related issue, not directly relevant to e-commerce, is the problem caused for hearing impaired people when businesses’ telephone systems play recorded promotional material or a radio station while the caller is on hold. A hearing impaired person will often have difficulty determining whether a person has commenced speaking to them, or whether it is “on-hold entertainment”. They find themselves explaining the nature of their business and then realising they are speaking to a recording or a radio station broadcast. When a real person takes them off hold, they ignore them as a result of not immediately recognising that the entertainment has concluded.

Those who are not able to hear voice commands on the telephone are further disadvantaged if the particular bank has not made it possible to use a TTY for banking. Even where a TTY facility is available, the user may be disadvantaged if information has to be keyed in within a short timeframe.

Where customers do have difficulties confronting new technologies, the businesses implementing such technologies for client services have an obligation to teach their clients how to use them. In the case of those Auslan users for whom English is not readily comprehensible, such teaching should be available via Auslan. Web pages filled with extensive English text would be much more user friendly for Auslan users if they provided Auslan signs or, at least, some complementary visual material as well as the text material. It would be even better if the e-commerce providers were to conduct training programs for clients needing help. Such programs themselves would need to be accessible to people with varying disabilities. In the context of deafness, that would mean providing hearing loops, interpreters and captions on any videos used.

4.	FUTURE TECHNOLOGY CONVERGENCE

It is important to look ahead to future technology convergence that may impact on e-commerce. Whatever technological developments emerge, it is important that there be no discrimination against people who are Deaf or have a hearing impairment. All applications of future (and current) technologies must be equally accessible to all people. In the context of deafness, this means that all people who are Deaf or have a hearing impairment must be able to use all new technologies just as readily as can people with hearing. For example, if a phone is employed to utilise any technology for e-commerce purposes, then phones usable by people who are Deaf or hearing impaired must be compatible with the e-commerce technology. At the present time, that would mean it must be possible to use a TTY phone in any application where it is possible to use a voice phone. In future, if (for example) a mobile phone with a Web browser became available and in common usage for e-commerce purposes, then so too should there be a mobile TTY phone with a Web browser available for e-commerce usage by deaf people who are not able to use a voice telephone.

5.	RURAL AND REMOTE AREAS

For people living in rural and remote areas, there is a concern about their losing access to telecommunications-based tools each and every time their power or telecommunications supply is interrupted for whatever reason. While e-commerce may offer significant benefits for people living at a distance from alternative non-telecommunications-based methods of transacting their business, that same distance means they often are at the mercy of repairers from “out of town”.

Another issue for rural and remote area people is that they are likely to incur greater costs to use telecommunications-based tools.

There is a need for disability-friendly coin-in-the-slot Internet kiosks or community Internet facilities in rural centres, to assist people in those centres and nearby areas to access Internet-based e-commerce.

6.	
NEED FOR DISABILITY CONSUMER VOICES.

People with disabilities must have their voices heard in whatever forums deal with access to electronic commerce and the telecommunications-based facilities used for it, just as they have their voices heard at the tables dealing with building access. People with disabilities must be involved at the earliest possible stage in all decision making processes that will lead to the introduction of new technologies that they may have, or wish, to use for e-commerce purposes.
 
7.	CONFIDENTIALITY AND PRIVACY

In particular situations, people may have no choice but to use an ATM, information kiosk or interactive booth. In those situations they have a right to privacy and confidentiality. If these types of facilities were to provide spoken advice about to users about their personal information, it would be important that a hearing impaired person be able to hear that information but not have it overheard by any other person. A user who was Deaf would need to be aware that a nearby hearing person might be able to overhear confidential information.

8.	TRAVEL SERVICES

The Issues paper for this Inquiry invited comments in respect of services such as travel. Travel is an area where new technologies are not being used adequately to deliver services. People who are Deaf and hearing impaired have significant difficulties where information is announced over poor quality public address systems. This commonly occurs at bus terminals, railway stations, sporting arenas, theatre foyers, etc. All such announcements should also be made in a visual form for the benefit of those who can not hear the spoken announcements. This is particularly the case in respect of announcements about travel services. A hearing impaired person who does hear a public address system announcement may not hear sufficient of it to know whether it is a safety message, advice about a change to a particular service or an exhortation to validate tickets before boarding the tram. Even people with good hearing often have difficulty understanding poor quality announcements.

One story will serve to illustrate the problem for people who are Deaf. A young Deaf woman regularly caught a particular train to work. One day a number of trains were running late. This was announced on a public address system, which she could not hear at all. A train arrived at the platform at the precise time her train always arrived. There was no visual display information at this platform, so the woman boarded the train. Some distance later, when the train, turned on to a line that would not take her to her required destination, she realised it was not her train. It was an earlier train running late that had arrived when her train was actually due.

Technology is available to overcome the shortcomings of oral announcements and enhance service delivery in ways that would be helpful to people who are Deaf and hearing impaired. Many city railway stations have visual display systems, some far more technologically advanced than others. Melbourne’s city circle tourist tram provides information via visual display units. Airports often make few oral announcements, because information is provided via visual displays. The larger commercial aircraft have visual display facilities, which could be better utilised than they are to provide visual information for passengers. It is unfortunate that, while some new technologies are being used in less than helpful ways for people with various disabilities, other technologies are not being utilised where they could assist. Automated information booths can also be equipped with hearing loop systems accessible by people with hearing aids designed for use with such loops.

9.	ABOUT THE DEAFNESS FORUM

Deafness Forum is the peak body for deafness in Australia. Established in early 1993, the Deafness Forum now represents all interests and viewpoints of the Deaf and hearing impaired communities of Australia. The representational base of the Deafness Forum is divided into five Sections:

a)	Hearing Impaired Section - persons with a hearing loss who communicate predominantly orally,

b)	Deaf Section - i.e. the Deaf Community - those persons who consider themselves to be members of that community by virtue of its language (sign language known as Auslan) and culture,

c)	Parents section - parents or legal guardians of persons who are Deaf or hearing impaired,

d)	Service Providers section - service providers to the Deaf and/or hearing impaired communities, and

e)	Ear Disorders Section - persons with a chronic ear disorder (such as Tinnitus, Meniere’s Disease or Acoustic Neuroma).

The Deafness Forum exists to improve the quality of life for Australian people who are Deaf or hearing impaired, and those with chronic ear disorders, through lobbying government, making input into policy and legislation, generating public awareness of hearing related issues, providing a forum for information sharing and creation of better understanding between all the diverse areas of deafness.