1. Principles

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1.1. Universal Design and Mainstreaming

In so far as is possible, information needs to be accessible to all people at the same point and time, regardless of their particular requirements. This concept is known as “mainstreaming”.

All communications systems should be designed so that they are useable by all. This related concept is known as “universal design”. Universal Design also means that where technological aids are required by the service-user to access information in a particular format, the service-provider should operate with the expectation that such a user has the minimum of spec in his or her device, and has minimal technological know-how, skills or ability.

Universal Design also means, in effect, that one size does not fit all, and as such, service-providers need to be flexible and adaptable, as well as having a number of alternatives for service-users to choose from when accessing communications or communicating themselves. Indeed, the same user may require a combination of different formats.

For example, in terms of billing and notification of medical appointments etc., the information system must be able to log the automatic or default communication preferences of each individual service-user, while remembering that in contexts such as billing and appointments, service-users have the right to be given the information in a durable format – i.e., in a retrievable form. Giving such information over the phone etc., may be a useful supplement, if requested, but is not a replacement for an accessible durable format.

1.2. Listening and Adaptability

By accessibility we mean, for the purposes of this document, that all content and functionality that is generally readily available, must also be usable by visually impaired people, across our wide spectrum of needs.

The key to maximum accessibility is the adoption of a system that sets high standards of two-way communication while utilising as many formats as possible. Digital technology has revolutionised accessibility to information by visually impaired people, but such technology is always evolving and statutory bodies need to be open to the use of new technology. However, statutory bodies also need to be mindful of two issues in this regard: firstly, there is a digital divide among visually impaired people – as much if not more than other groups in society; and secondly, high standards of accessibility need to be maintained across present conventional systems, regardless of new technological innovations.

Ultimately, the person-centred approach, which puts a person’s individual rights of access to information and communication above that of the stemic norms, is necessary, and as such, listening to an individual as to what formats they prefer at any given time is essential. The only way to do this is to listen to what are the individual’s preferred formats, and to respect and act on those wishes. This person-centred approach is complementary to a system that is designed to be robust and adaptable so that all preferred formats are planned for, organised according to necessary high standards, and most importantly, be practically useable by the end user, rather than merely being nominally or officially accessible.

So, a good rule of thumb is that if a visually impaired person says that something is not accessible to them, then they, as the experts, are correct. They are not the problem: but rather, the system or the document is the problem, and the obstacles they have identified are likely to affect far more people who just don’t say anything. Being informed that a particular type of communication is inaccessible should be seen as an opportunity, and be taken seriously by the statutory body so that it can make its services fully accessible to all. This responsiveness is a legal obligation (s.i. 358 / 2020).

1.3. Consultancy and Testing

Of course, it is the prerogative of a statutory body to employ the services of a private consultant to advise on the accessibility of its communications, but this document, in conjunction with other online resources and adequate training of developers in accessibility, should be enough for a statutory body’s technical staff to get it right.

Getting an in-house visually impaired person to be a representative tester is not sufficient. There are many types of visual impairment, many levels of workaround skills, and many types of software and other formats. As such, ultimately, the unmediated collective and representative voice of visually impaired people, through their DPO, is the ultimate arbiter on whether a communications system is accessible.

1.4. Outsourcing to Third Parties

Where any services, including information (such as personal communications, leaflets, guides, reports or submissions) are provided by a third party on behalf of the initial service-provider or public authority, such communications need to be accessible to all visually impaired people. This also means that accessible communication requirements should be included as a precondition in any specifications, for example, being explicit throughout a tendering process or reviews of such tenders or contracts. These requirements are, to a large extent, already set out in the Disability Act (2005, S27), and the National Disability Authority’s Code of Practice of Public Services and Information Provided by Public Bodies (2006 / s.i. 16).

Similarly, a visually impaired person should not be compelled to rely on third parties as information sources where such third parties are not providing the required information in an accessible format of the visually impaired person’s own preference. Such compulsion amounts to a discriminatory precondition on access to a service or right to entitlement.

Third parties will generally have to be compliant with the 2019 European Accessibility Act by July, 2025, and a visually impaired person should not be penalised for the discriminatory (and to-be illegal) actions of a third party.

1.5. Languages

Where possible, each document or stream of information should be monolingual – i.e., be in just one language, and not mixing languages, even where they are separated within a document or stream. Specific exceptional contexts include cultural and educational settings, where a second language is either being taught, or where a drama or artistic work retains original multilingual texts to maintain integrity of the original.

Generally speaking, accessible communications should be Available at least in English and Irish, and both choices equally easily locatable.

Electronic documents (including on apps, websites, HTML 5, .doc/.docx, .pdf, etc.), need to be appropriately tagged so that Irish is not pronounced by screenreading technology with English phonemes, e.g., Irish teach (house) should not sound like English ‘teach’ (as in educate). The same need for proper language tagging applies to every language, especially remembering that document producers may be working from a default English tagging.

1.6. Information About Accessibility

  • The fact that particular formats are available on request, e.g., braille or large print, should be made known on websites and through front-of-house staff.
  • All website information relating to accessibility should be in a prominent position and very easy to find using screenreading technology.

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