10.1. Option of Multiple Preferred Formats.
10.2. Tests and Exams.
10.3. Application Forms.
10.4. Online Feedback and Surveys.
10.5. Public Consultations.
10.1. Option of Multiple Preferred Formats.
Even the same person may require or prefer a combination of means of doing tests or exams, or of filling in a form or completing a survey. For example, the same person might prefer to read the form or survey in one format, but give the requested information in another. For instance, a person may prefer to read the paper in braille, but give the answer orally –for transcription by a scribe, or by a member of staff on the other end of a phoneline. Similarly, a visually impaired person may require a member of staff to fill in a form for them, over the phone, in the expectation of being able to verify the form later – e.g., by having what was dictated sent to the service-user by email, and which can be affirmed by the service-user’s email response, or by braille etc.
10.2. Tests and Exams.
10.2A. Criteria.
10.2B. Reasonable Accommodation.
10.2A. Criteria.
As recognised by the UN Committee in General Comment No. 4, para. 6, of the Convention on the Rights of People with Disabilities (CRPD), those eligible for reasonable accommodation with regard to education include those with perceived as well as actual impairments. In other words, “provision of reasonable accommodation may not be conditional on a medical diagnosis of impairment, and should be based instead on the evaluation of social barriers to education” (ibid., para. 30).
10.2B. Reasonable Accommodation.
Reasonable accommodation as to how an exam, test, form, or survey is to be done or completed by the visually impaired person, should be agreed as early in advance of the sitting as possible, so that the mind of the candidate or applicant, etc., can be put at ease, and so that they can more adequately prepare.
Reasonable Accommodation can include:
10.2B1. Easily Accessible Exam Locations.
10.2B2. Privacy.
10.2B3. Extra Time.
10.2B4. Accessible Means of Reading.
10.2B5. Intrinsically Inaccessible Exams.
10.2B6. provision of Writing Means.
10.2B7. Spell-Checking.
10.2B1. Easily Accessible Exam Locations.
The location of the exam or test must be accessible to visually impaired candidates. This may include the reasonable accommodations of
- provision of travel assistance, e.g., taxi, from the candidate’s home to and from the exam location.
- provision of a guide so that the candidate can find the exam location and be able to leave, afterwards.
- Where relevant, it should also be ascertained before any exam or test that the lighting conditions in the exam room are appropriate to the needs of a visually impaired candidate.
- where a visually impaired candidate also has a physical impairment, physical objects such as steps should not be obligatory barriers.
10.2B2. Privacy.
A visually impaired candidate should always have the option/choice of sitting an exam in a totally separate space e.g., providing for a candidate to have their own room, with supervision.
Where candidates use a scribe, braille machine or other keyboard device, they don’t have to worry about distracting other candidates if they are separate from them. Also, where extra time is allotted, a visually impaired candidate will not be distracted by other candidates leaving, if they are in their own exam room. Otherwise, though, candidates may be self-conscious about having to write with their face to the page, and prefer to be able to concentrate entirely on the exam rather than having the chance of being worried about being self-conscious or standing out.
10.2B3. Extra Time.
Extra time in tests or exams should be needs-based rather than standard, and clearly agreed and understood by both parties, well in advance of the text. While set times should be aimed for, since this gives the candidate an idea of how much time they should be spending on a particular question; in practice, ‘extra’ time’ should be open-ended, especially where knowledge and understanding are being tested rather than objective speed.
Visually impaired candidates should be permitted to take breaks in such prolonged exams. It might be remembered that for reasons of mental fatigue at least, no candidate will want to unnecessarily prolong an exam.
So that a visually impaired candidate can best distribute their time among questions, the marking scheme should be clearly laid out, beside the target time, at the top of the paper, as well as under each question.
10.2B4. Accessible Means of Reading.
Having the exam, test, or application form, etc., in a format of the visually impaired person’s own choice (e.g., .accessible Word format, braille, large print, or audio.
The primary specialised formats for visually impaired readers are discussed in sections 5-9 of this manual, and provision of such formats should be built into all relevant systems (see Section 1 of this document). However, reasonable accommodations can vary from the norms discussed in Sections 5-9 of this document. For example, a candidate may require a large print version of the exam paper that is white writing on a black background etc. It is advised that the preferances of a visually impaired candidate can be ascertained as precisely as possible well in advance of any test or exam.
10.2B5. Intrinsically Inaccessible Exams.
It must be acknowledged that it may be unreasonable to expect a visually impaired person to sit some types of tests or exams. For example, some tests are sight-dependent, e.g., psychometric tests when applying for positions in the Civil Service, or language questions based on pictograms. While some visually impaired people may be prepared to put up with a workaround, and even relish the challenge, it is unreasonable to expect, by default, a visually impaired person to complete such questions, tests, or exams, and we should be in no way penalised for such lack of completion.
In some cases, an alternative can be arranged, for example, having a candidate complete a social geography question in place of an ordinance survey map based question when sitting Geography for the Leaving Cert.
10.2B6. provision of Writing Means.
Each of us, as a visually impaired individual, is the expert in knowing our own needs when it comes to our means of writing in an upcoming exam.
Scribes: where a visually impaired candidate has requested the use of a scribe, where possible, the scribe should be someone that the visually impaired person is already familiar with and likes working with. The candidate’s own suggestions of potential scribes should be given due weight in this respect.
Writing equipment: while, of course, the mode of writing is definitely a matter of the candidate’s own choosing (e.g., braille, pen, word processor, etc.), the testing institution may be required to provide the use of specialist equipment, and where this is the case, the visually impaired candidate should be closely consulted and actively involved in the setup of the equipment. For example, a candidate may wish to type their exams by word processor. In such cases, a particular screenreading software with particular settings may be required; a particular colour contrast and/or magnification setting may be required; a particular keyboard type may be required; cursor-trails me be required to be in operation, etc. If a braille machine is required, the candidate should be able to check it out at the earliest possible time so that they can ascertain any problems, e.g., a chipped spacebar or broken new-line key.
10.2B7. Spell-Checking.
While many examiners are very lenient when it comes to typos and spelling errors, the approach is not standardised, and presentation of a text is likely to influence how a text is generally received (even subconsciously).
Since a visually impaired candidate may not be able to see what is being written by themselves or on their behalf, spell-checking should always be permitted throughout and after an exam. Some candidates may require assistance with this spellchecking.
10.3. Application Forms.
10.3A. Accessible Supporting Documentation.
10.3B. Accessible Means of Responding.
10.3C. Signatures.
10.3A. Accessible Supporting Documentation.
Visually impaired applicants should not be expected to rely on information provided by third parties that is inaccessible, since such an unfair imposition is discriminatory and is likely to exclude a visually impaired person from independently making an application.
In some cases, for example reading of a card number or identifying a photo for inclusion in an application, a video call from a relevant official could be reasonable accommodation if requested or agreed to by a visually impaired person.
10.3B. Accessible Means of Responding.
10.3B1. Introduction.
10.3B2. Original Form as Guide.
10.3B3. Dictation.
10.3B4. Accessible MS Word Format.
10.3B5. Braille.
10.3B6. .pdf.
10.3B1. Introduction.
As mentioned in 10.1 above, a visually impaired applicant may require a combination of formats in filling in an application form, for example one format for reading an application form and another for filling it in.
10.3B2. Original Form as Guide.
Following on from this, it should be reasonable accommodation, once all required questions are answered in full, that the original application form be seen as a guide, and that responses can be provided in a separate (new) document created by the applicant.
10.3B3. Dictation.
As part of this flexibility, a visually impaired person should be free to dictate their answers (in person or remotely); and then to have those answers sent to them in a format of their own preference for their verification. Once more, the manner of verification needs to be accessible and of the preference of the visually impaired person. An alternative to marking X, or having someone else mark X – which are in themselves frought with security issues – is that of email response, affirming that the answers to a form are accurately recorded.
10.3B4. Accessible MS Word Format.
Where a form or survey is in Word format, it is generally not a good idea to just imagine it as if it were a traditional paper form. For example, the following is advised to make forms and surveys in Word more accessible to screenreader users. See Section 5 for more details.
- question-numbers should be typed, rather than generated using auto-numbering; and similarly, autobulleting should be replaced by asterisk + tab to achieve the same effect accessibly.
- text should not be in text-boxes or tables.
- tick-boxes should not be used.
- guiding lines, e.g., “……..” or “_” etc., should not be used. A space for filling in an answer will suffice.
- where it is planned that the form or survey is to be printed out by an office, having been completed by the applicant/respondent, it should be remembered that the completed form may not be so conducive to easy reading at the office end, since the pagination will have been altered from the original uncompleted form.
10.3B5. Braille.
As mentioned in Section 7 above, Braille forms and surveys generally cannot be filled in in braille, but may be requested so that the reader can better access the questions. Some may prefer to give requested information in a separate braille document.
10.3B6. .PDF.
.pdf file format of a form, which is currently the usual format for downloadable forms, is by default inaccessible to blind people wishing to be independent, apart from the remarkably intrepid, knowledgeable, and patient, who can attempt to transfer them into Word. As such, we recommend the standard production and availability of such forms in an alternative accessible Word or .rtf format.
10.3C. Signatures.
It is reasonable to assert that where a sighted person has filled out a form for a visually impaired person and the latter is expected to sign that form, that such a signature is meaningless, since the visually impaired person cannot be sure what they are signing. So, expecting a visually impaired person to deal with such a form, or coercing them to do so, as sometimes happens, is not acceptable, and is a violation of fundamental Human Rights.
Where a visually impaired person is agreeable to “signing” a paper form, all the information, as written by the assistant, needs to be read back to the visually impaired person before they can sign. Even then, the status of the agreement approximates to that of a verbal contract, or even “non est factum” (a void signature). Indeed, a visually impaired person may choose to sign “non est factum” or “NEF” if they are able, to make this point.
Many visually impaired people can use email, and one alternative to the penned signature is the use of email by either the office requesting verification, or by the respondent in the first place just sending a Word document, for example, in by email, or answering a form or survey’s questions in the body text of an email.
A combination of modes can be used also, so that, for example, an official can fill in a form for a visually impaired person over the phone, and the completed form can then be sent by email to the respondent, asking if they agree that it was completed correctly. An affirmative response suffices as a signature. Where a form is filled in over the phone, it is recommended, as above, that the information just received be read back to the applicant before they can be sent the completed form for their verification in a durable medium (e.g., as a Word document by email or as a braille document).
10.4. Online Feedback and Surveys.
10.4A. Alternatives to Online Feedback and Surveys.
10.4B. Accessible Online Surveys.
10.4A. Alternatives to Online Feedback and Surveys.
Online feedback and surveys, as opposed to feedback and surveys by Word and email etc., have advantages for both the organiser and the respondent. The organiser can share links more easily, including via social media, and the respondent does not have to faff about with downloading a file to work on. Generally, respondents do not look for durable copies of surveys they fill in.
As such, our advice is that an online survey be the default, but that an option be advertised along with all general advertising of a survey, in which forms can be filled in over the phone or by alternative formats such as Word .doc/.docx, on request.
10.4B. Accessible Online Surveys.
Where a third-party service, such as surveymonkey, is used, it should not be presumed that the survey is accessible by default. Such surveys still need to be properly put together in order to be accessible.
The following are measures of accessibility in online surveys:
- questions should be easily navigable using tab and shift-tab.
- tick-boxes for multiple choice answers should be easily ticked by using the spacebar.
- the screenreader user does not need to hear repetition of the same question as they progress through the multiple choice options of that one question.
- it should be possible to activate and remove focus on a field via the keyboard.
- resources allowing, consideration should be given to facilitating the completion of a survey by visually impaired people over the phone, and this alternative advertised along with the survey’s general advertising.
10.5. Public Consultations.
10.5A. Provide Alternative Submission Modes.
10.5B. Durable Formats.
10.5C. Reasonable Accommodation (Deadlines).
10.5A. Provide Alternative Submission Modes.
Where submissions are sought by a public body as part of a public consultation, and presuming that all the necessary information is accessible (as per all Sections of this VVIMAC document), many alternative modes of making a submission must be available to the public, and these should always include a phone and email contact via which submissions can be submitted (verbally through dictation (including with a process of verifiability by the person making the submission)), as well as being able to make a submission directly by email.
10.5B. Durable Formats.
Where online submission forms are used, there should be an option of the retention by the form-filler of the complete submission in a durable format. For example, this could be done by the automatic generation of a Word document, sent by email, to the applicant or respondent.
10.5C. Reasonable Accommodation (Deadlines).
Where the public body has not provided adequately accessible information for consultation, or has set up an inaccessible submissions process, deadlines for submissions (at least to the parties affected by the discrimination) should be extended so that they have the same opportunity of contributing as their non-disabled comparitor.