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.

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.

Universal Design

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.

1.2. Listening and Adaptability

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-centered approach, which puts a person’s individual rights of access to information and communication above that of the systemic 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, they are not the problem – but rather, the system or the document is the problem, and this is 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. Languages

There must only be one language used on any one particular form, webpage, survey/form, or in any one document unless a specific context (e.g., an educational setting), makes it unavoidable.

Accessible communications should be available at least in English and Irish, and both choices equally 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 (which means house in Irish, pronounced ‘tee-ock‘) 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.

1.5. Outsourcing to Third Parties

Where any service (including reports or submissions) is outsourced or otherwise sought from a third party, such communications need to be accessible to all visually impaired people. This also means that accessible communication requirements should be included in any specifications for a tendering process and made clear in any contract with a third party where relevant.

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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