Ensuring Accessibility for Persons with Disabilities in Canada's New Digital Economy Strategy

Summary

Organization and/or author's name: Neil Squire Society, comments written by Gary Birch, O.C., Ph.D., P.Eng., Executive Director

The Neil Squire Society is a Canadian not–for–profit organization whose mission is to enable people with significant physical disabilities to achieve greater independence through the development, adaptation and use of innovative services and technology. Information and communication technologies are either directly or indirectly a form of assistive technology or it is a potential enabler for persons with disabilities. New emerging information and communication technologies (ICT) have the potential to provide opportunities for persons with disabilities to obtain inclusion in the mainstream of society to an extent never before accomplished. This in part, is due to the ever–increasing power of these devices to accomplish various technological tasks. But the bigger factor is that these new technologies are being incorporated into the mainstream of our society in an almost completely ubiquitous manner including such areas as employment, recreation and various forms of service delivery. Then when you add to the fact that these technologies are changing at a very rapid pace this lays the foundation for a perfect storm of inaccessibility for persons with disabilities. As these new technologies come onto the market they are not inherently accessible for a large majority of persons with disabilities and therefore become barriers rather than tools that allow them to take part in society like their able–bodied counterparts.

It is imperative due to the significant digital divide for persons with disabilities that Canada's new Digital Economy Strategy incorporates a comprehensive mechanism to ensure that this digital divide is eliminated as part of the strategy.

Under all five themes, there is a need for an expert Advisory Committee on accessibility that would become an integral part of the Digital Strategy for Canada. As a starting point, I suggest that we make use of the existing Minister's Advisory Committee for Industry Canada on Assistive Devices (ACAD). This committee could serve as an excellent platform to either be the Advisory Committee for the Strategy or help develop and implement a specific advisory committee.

Time is of the essence in terms of accessibility. The sooner the concept of accessibility is built into the emerging Strategy the better. To move quickly and would recommend taking advantage of ACAD as described above, to empower the CRTC to regulate applicable areas such as e–commerce and to ensure that current and new sources of grants and contributions from the Government of Canada include a requirement to meet appropriate accessibility standards as a condition of funding.

Submission

Who We Are

The Neil Squire Society (NSS) is a Canadian not–for–profit organization whose mission is to enable people with significant physical disabilities to achieve greater independence through the development, adaptation and use of innovative services and technology. Since its inception in 1984, the Society has opened the doors to independence for over 20,000 Canadians with significant physical disabilities. The Neil Squire Research and Development Group (NSRDG) is a division of the Neil Squire Society, a non–profit society whose members, employees and volunteers work to enhance the daily lives of persons with significant physical disabilities, seniors, and people recovering from illness or injury. The Neil Squire Society is unique, as it is one of the few non–profit, community–based organizations that maintain an active research and development group. The Society's greater mandate is to use technology to help these individuals fully participate in the activities of society such as living independently, going to school and holding meaningful employment. The focus of the NSRDG is to research and create devices, technologies and products that facilitate and improve the quality of life for these individuals. For 20 years, the R&D group has built a strong national and international reputation for its work in creating technologies to enable these people to achieve their potential in educational, vocational and personal pursuits. The R&D group has highly–qualified and experienced researchers whose areas of expertise include electrical, mechanical, software and human factors engineering. The service side of the NSS provides consultation and assessment services to those requiring assistive technology (AT) and delivers pre–employment/employment training for those with disabilities looking for meaningful careers.

Desired Impact

Our desire is to make new and existing technologies in the area of information and communication technologies (ICT) accessible and improve their usability; ideally we would like to make them accessible from the earliest stages of development to eliminate the accessibility gap¹. We would like to do this by engaging with key industries, governments and other regulatory bodies to change the nature of the technology to make it inherently accessible through setting of standards, regulation and education. New technologies have the potential to enhance the lives of people with disabilities, however too often they form an additional barrier and form of exclusion.

A Persistent Need

Information and communication technologies are either directly or indirectly a form of assistive technology or it is a potential enabler for persons with disabilities. New emerging information and communication technologies (ICT) have the potential to provide opportunities for persons with disabilities to obtain inclusion in the mainstream of society to an extent never before accomplished. This in part, is due to the ever–increasing power of these devices to accomplish various technological tasks. But the bigger factor is that these new technologies are being incorporated into the mainstream of our society in an almost completely ubiquitous manner including such areas as employment, recreation and various forms of service delivery. Then when you add to the fact that these technologies are changing at a very rapid pace this lays the foundation for a perfect storm of inaccessibility for persons with disabilities. As these new technologies come onto the market they are not inherently accessible for a large majority of persons with disabilities and therefore become barriers rather than tools that allow them to take part in society like their able–bodied counterparts. The old paradigm of developing retrofit solutions to access these mainstream technologies for persons with disabilities is failing. This points to the need to focus on new strategies to deal with this unprecedented pace of the introduction of new ICT technologies. The need for this issue to be addressed is becoming better recognized both within in the community of persons with disabilities worldwide and the wider community in general. Perhaps the best, recent example is contained in the Convention on the Rights of Persons with Disabilities.² This convention calls for the accessibility of information and communication technologies and related services (see for example Article 9 and Article 21). As of July, 2009, 62 countries have ratified this convention.³ Canada recently ratified this convention and the United States of America is in the process of working towards ratifying this convention. New technologies will bring new manifestations of the accessibility gap, and each one of these problems will need to be addressed to close the social and economic exclusion that result.

The relevant discussion theme being addressed (one or more): comments will be made under all five themes

Innovation Using Digital Technologies

In terms of conditions that would best incent and promote adoption of ICT by public sectors and in fact businesses is to ensure that all innovations in this area are designed to be accessible and hence usable by all Canadians including those with disabilities. This will maximize the ability to service all Canadians in the public sector and maximize business opportunities for Canadian firms.

A successful digital strategy for Canada would be one that includes a mechanism that ensures that investments in ICT innovations are designed to be inclusive of all Canadians including those with disabilities. This barrier can best be addressed through the formation and/or utilization of an existing advisory group of experts in the area of accessibility (see concluding remarks for further details on this point) that inform and advise throughout the various processes established by the Government of Canada to enhance the innovation of ICT. This would distinguish Canada's strategy amongst other jurisdictions of the world as we believe it would be the first strategy to explicitly include this aspect.

Canada can use its policy and regulatory regime to promote accessibility in the deployment of e–commerce. The inaccessibility of emerging e–commerce services is a serious problem as this was recently studied and documented by the Neil Squire Society (for more details). The CRTC should be investigated as a probable existing regulatory body that can be given the mandate to ensure that e–commerce in Canada is accessible to persons with disabilities.

Digital Infrastructure

As noted in the Strategy discussion paper, all Canadians should have access to high–speed networks. As new infrastructure is introduced in Canada we must ensure that this infrastructure is designed in such a way as to ensure that it is accessible to all Canadians, including those with disabilities. History has already demonstrated that this can not be left up to market forces and this is a place where the government of Canada must regulate to ensure that all Canadians receive maximum economic and social benefit. As discussed above, the proposed expert advisory committee on accessibility would be in a position to advise as new infrastructures are contemplated and therefore ensuring that costs of implementation remain low or nonexistent in terms of accessibility (i.e. designing the accessibility from the beginning) rather than being required to implement retrofit accessibility solutions at a much higher cost to both government and business.

Growing the ICT Industry

As indicated in the introduction of this document, prerequisite for accessibility in ICT will become a global requirement. Some of the most common/cited pieces of legislation in the U.S. that come up in the context of this discussion are: Section 501 of the Rehabilitation Act⁴ and Section 255 of the Federal Communications Commission (FCC) Communications Act⁵ (both currently under review)⁶. Canadian companies must be ready for this global demand from other jurisdictions so that their products and services can be competitively marketed and exported throughout the world. As indicated above, by including a comprehensive accessibility lens or mechanism to Canada's Strategy this would provide an important competitive discriminator from other strategies in other jurisdictions. This would mean that existing programs to enhance Canada's innovation capacity in this area would need to be changed to include requirements for accessibility. In addition, by having a Canadian strategy that includes accessibility because of the growing global demand for accessibility in ICT would also enhance Canada as a destination choice for venture capital and investments in global R&D and product manufacturing.

Canada's Digital Content

As noted in the Strategy discussion paper, consumer expectations will also include, on a global level, expectations related to accessibility such as those that have been created by the Americans with Disabilities Act (ADA)⁷ as well as the legislation noted in the above section. If Canadian innovations in content do not include accessibility they will be profoundly limiting their markets as more and more jurisdictions around the world make accessibility a requirement. Therefore, creating Canada's Digital content with added advantage in the global marketplace it should have a major component related to accessible services and the related hardware platforms (e.g. wireless handheld devices) that deliver those services. To ensure that all Canadians, including those with disabilities (note: this also includes those with moderate to severe mobility impairments which were not explicitly noted in the Strategy discussion paper), will benefit and be able to participate in the digital economy begins with advice and reference from the expert advisory committee already described above in the other sections. An example of providing service that is fully accessible would be the Neil Squire Society's distance learning services which have been developed on platforms which are fully accessible and therefore open to all Canadians. This should become the norm for all private and public institutions providing these kinds of services. Any initiatives that are initiated by the Government of Canada to support innovation in this area should include requirements regarding accessibility as well as input and advice from the expert advisory committee on accessibility.

Building Digital Skills

As the Strategy discussion paper points out there is a digital divide. This is particularly true in the disability community. For instance, a 2000 survey⁸ found that people with disabilities were nearly 30% less likely to have basic computer skills as compared to a person without a disability. It was also found that people with disabilities that are in education or employment opportunities have nearly equal access to computer technology. For individuals that are not students nor employed, there is a large "digital divide"⁹, further marginalizing people with disabilities and limiting their employability and community participation. To address this pressing need the Government of Canada needs to enhance and develop further mechanisms that will support the skill development specifically designed for those with special needs related to disabilities. For example, the Neil Squire Society recently received a contribution from OLES in the Department of HRSDC to develop, pilot and evaluate an accessible distance learning program called Computer Comfort (a specialized program to develop computer skills for persons with disabilities). Further support for programs of this nature will be instrumental in helping to close this digital divide for persons with disabilities.

Concluding Remarks

As noted throughout my comments above under the five themes, there is reference to an expert Advisory Committee on accessibility that would become an integral part to the Digital Strategy for Canada. As a starting point, we suggest that we make use of the existing Minister's Advisory Committee for Industry Canada on Assistive Devices (ACAD). This committee could serve as an excellent platform to either be the Advisory Committee for the Strategy or help develop and implement a specific advisory committee.

Time is of the essence in terms of accessibility. The sooner the concept of accessibility is built into the emerging Strategy the better. To move quickly we would recommend taking advantage of ACAD as described above, to empower the CRTC to regulate applicable areas such as e–commerce and to ensure that current and new sources of grants and contributions from the Government of Canada include a requirement to meet appropriate accessibility standards as a condition of funding.

¹ A time–based social and economic deficit for people with disabilities caused by the introduction and mass adoption of information and communication technologies.

² Convention on the Rights of Persons with Disabilities.

³ Official Documents System of the United Nations.

⁴ Resources for understanding and implementing Section 508.

⁵ Disabled Persons' Telecommunications Access — Section 255.

⁶ Update of the 508 Standards and the Telecommunications Act Guidelines.

⁷ Americans with Disabilities Act .

⁸ Supplemental Tables and Charts for CCSD's Disability Information Sheet #7. 2000. Statistics Canada's General Social Survey (Cycle 14).

⁹ Advancing the Inclusion of People with Disabilities. HRSDC. 2006.