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Building bridges over the digital divide

A review of developments in addressing the 'digital divide' experienced by older Australians and people with disabilities.

Introduction

The accessible e-commerce report reference

Summary of barriers

Accessible e-commerce Forum

Recommended measures and developments

• Industry association commitments
• Government and private sector web accessibility
• Access awareness and new technologies
• Equipment, training and information
• Legal reform
• Material for students
• Individual initiatives

Conclusion

Appendix 1- Reference given to the Commission

Appendix 2 - Summary of recommended measures and proposed actions

Human Rights and Equal Opportunity Commission

November 2001

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Introduction

This review has been prepared to identify developments in addressing the 'digital divide' experienced by older Australians and people with disabilities since the release of the Commission's report Accessibility of electronic commerce and new service and information technologies for older Australians and people with a disability (Accessible e-commerce report).

The Accessible E-commerce Forum, which was established following the release of the report, requested the review to summarise developments, assist in identifying areas for further work and to inform the community of the many initiatives that are taking place.

The review refers to a number of initiatives that have been brought to the attention of the Commission, but does not claim to have identified them all. By making this review publicly available I hope that organisations that have taken action to address the digital divide will inform the Commission of their work so that information can be made available to others through our web site.

I would like to thank all the members of the Accessible E-commerce Forum for their contribution and hope this review will assist them, government, industry and the community to continue 'building bridges'.

Dr Sev Ozdowski OAM

Acting Disability Discrimination Commissioner

The accessible e-commerce report reference

The accessible e-commerce report was prepared following a reference given to the Commission by the Attorney-General, the Hon Daryl Williams AM QC MP in August 1999. The reference (see Appendix 1) asked the Commission to look at the effect of the rapid development and use of new technologies in electronic commerce and the provision of government and other services on older Australians and people with disabilities.

The report was completed in March 2000 and forwarded to the Attorney-General along with a number of recommended measures and proposed actions.

Summary of barriers

Barriers identified by submissions and research materials included:

• Cost of access to computers and internet connection
• Limited public access facilities for people who cannot afford their own equipment
• Limited sources of resources, assistance and information where adapted or customised equipment is required by people with disabilities and older people
• Needs for awareness, and training in use of, available options
• Inaccessibility of many web pages to people with vision impairments, slower connections and older equipment
• Inaccessibility of many automatic teller machines, EFTPOS facilities, and other similar devices including public transport ticketing machines, to people with limited vision, manual dexterity or memory, or who are using a wheelchair
• Concerns for safety when using ATMs and security when using EFTPOS facilities
• Concerns regarding privacy and security of internet transactions
• Difficulties in using interactive voice response systems (for bill payment and other services by phone) because of insufficient time provided for entry of information by the user, complexity of menus and lack of readily available recourse to human operator
• Lack of provision, or delays in provision of materials in accessible formats (particularly in education), for reasons including copyright or other legal difficulties and the formats in which publishers make materials available.

Accessible E-commerce Forum

Following the release of the report the Commission worked with the Australian Bankers Association (ABA) to jointly establish the 'Accessible E-commerce Forum' (the Forum). The Forum includes representatives from HREOC, the ABA, Commonwealth Attorney-General's Department, Blind Citizens Australia (BCA), the Physical Disability Council of Australia (PDCA), the Disability Council of NSW, Council on the Ageing (COTA), Credit Union Services Corporation (Australia) Limited (CUSCAL), Australian Association of Permanent Building Societies (AAPBS), Internet Industry Association (IIA), Australian Information Industry Association (AIIA), Department of Family and Community Services, Australian Retailers Association (ARA), Property Council of Australia (PCA) and a number of industry service providers, including Telstra and IBM.

The Forum was established to encourage and co-ordinate initiatives aimed at addressing the report's recommendations and has met on four occasions. Terms of reference for the Forum and notes from each meeting are available on the Commission's website at

While the Forum has no authority to direct any of its members, it has proved to be a valuable and effective mechanism for establishing partnerships and identifying opportunities for change. Forum members use the meetings to provide feedback on developments they are aware of and reflect on what action individual members, or the Forum as a whole, can take to ensure real outcomes for people with disabilities and older Australians.

Recommended measures and developments

The accessible e-commerce report included a number of recommended measures and proposed actions (attached as Appendix 2) that have been used by the Forum as a focal point to promote partnerships and identify priorities. While many initiatives that have been identified reflect ongoing commitments made by individuals and organisations before the establishment of the Forum, its existence has become an important reference point for ideas and action.

Rather than address each recommendation this review will report under a number of headings.

Industry association commitments

Perhaps the most promising initiatives have been those of industry associations making commitments to address a variety of barriers and achieve compliance with the objects of the Disability Discrimination Act (1992) (DDA) through the development of industry or association action plans.

The Australian Bankers Association (ABA) has made commitments through its action plan to developing a range of industry best practice standards covering ATMs, EFTPOS, Internet, and telephone banking. Commitments have also been made to ensuring access issues are addressed at the earliest stages in the development of new technology such as Smart Cards.

The has established a number of working groups to develop these industry standards that include representatives from individual banks and the broader financial services industry such as CUSCAL and AAPBS, along with representatives from the disability sector, older Australians, the ARA, IIA, PCA and HREOC.

The industry standards developed through this process will be provided to individual financial institutions in the expectation that they will be adopted and implemented. It is intended that the industry standards will achieve a level of access consistent with the objects of the DDA. This will provide a strong incentive for financial institutions to adopt the standards in their own action plans. The , on behalf of its members, has already committed to the implementation of the industry standard in relation to Internet banking.

The active participation of CUSCAL and AAPBS in the development of the industry standards indicates the likelihood of broad financial service industry acceptance.

The industry action plan also commits to raising awareness of new forms of face-to-face services and emphasises the importance of these services to people with disabilities and older Australians within the banking industry.

The Internet Industry Association (IIA) and the Australian Interactive Multimedia Industry Association (AIMIA) have together nearly completed an Accessible Web Action Plan. This plan commits the two associations to a number of strategies aimed at encouraging awareness about web accessibility and helping members to work towards building and maintaining accessible websites.

The plan specifically refers to the World Wide Web Consortium's Web Content Accessibility Guidelines as the best practice standard for Australian websites and both associations are committed to ensuring their own websites are fully accessible as best practice models for the broader industry.

The plan, developed in consultation with the Forum, association members and the broader community, also includes commitments to education, information and promotional programs, establishing a service to assist members achieve accessible websites and investigating the sponsorship of web access awards.

While not completed yet the Credit Union Services Corporation () Limited (CUSCAL), has also been developing a draft action plan focusing on Credit Union services.

Generally, the associations that have prepared action plans have no authority to require their members to implement the various standards and models that will be developed.

Implementation will to some extent rely on the degree to which associations can advocate with their members; the confidence members have that implementation of proposals will meet customer needs and, as far as possible, fulfil legal responsibilities and finally the capacity of community advocacy groups to lobby and assist service providers to fully implement the proposals. The Forum is also committed to considering ways in which it can assist in implementation strategies.

Government and private sector web accessibility

The Commission's report on accessible e-commerce noted the Federal Cabinet's decision of March 2000 to require, among other things, all Commonwealth sites to pass accessibility testing by reference to W3C standards by .

Considerable effort has been put into achieving that objective, including training seminars for Government Departments and agencies, however, the Commission is aware that full compliance has yet to be achieved. Similarly, many State and Territory Governments have policies in place, but anecdotal information suggests universal compliance has not been achieved.

The Commission will seek ways to improve Commonwealth compliance in consultation with the National Office for the Information Economy and Government On-line.

The Commission will also consider undertaking a second sample survey of a number of government web sites and writing to all levels of government seeking an update on plans to achieve full compliance.

The Commission will continue to support the initiatives of the IIA and AIMIA in their work within the private sector through the implementation of their action plan.

Access awareness and new technologies

The accessible e-commerce report specifically identified the need for government and industry to take an increasing role in educating those developing new technologies on the need to build access into their design and implementation.

While no formal audit has taken place, reports to the Commission and the Forum suggest a significant increase in activity in this area. Developments include:

• Increased IT media focus on access issues
• Association action plans committing to addressing access issues in the design phase of new technologies
• Many IT focussed associations now have a specific web page dealing with access
• Federal Government policies relating to the need to ensure accessible IT developments
• Business sector initiatives to establish centres of access excellence, for example the Telstra centre for accessibility.

These initiatives represent a significant shift in the IT environment, but their effectiveness will only be apparent as new accessible technologies evolve.

The Department of Communications, Information Technology and the Arts AccessAbility program has sponsored a number of projects looking at online access and reports of these projects are due later this year.

Equipment, training and information

Many submissions to the accessible e-commerce inquiry noted the need for a more co-ordinated effort on the part of government and the private sector to the provision of awareness, education and training programs and increased provision of superseded equipment.

Ensuring services and products are accessible is only one part of addressing the digital divide as many service users need access to equipment or training in order to benefit from them.

While many initiatives by individual banks and businesses have been reported there is clearly a need for best practice models for the provision of superseded equipment and training to be developed and adopted.

In this regard the Commission notes the initiative of Council on the Ageing (COTA) that has been working with a number of financial institutions to develop training programs.

Discussions on strategies for developing best practice information and education models, drawing on the experience of COTA, are to take place at an upcoming meeting of the Forum.

Also notable in this area has been the donation by the Attorney-General's Department of 50 superseded computers to community organisations serving the aged and disability sectors throughout . The donation was made by the Attorney-General at a formal ceremony at the Human Rights and Equal Opportunity Commission on .

The Attorney-General indicated at the time of the donation that he would be encouraging other Ministerial colleagues to consider similar donations. The Attorney-General's Department will be briefing the incoming Government on any future action regarding the computer donations as appropriate and has had discussions with the National Office for the Information Economy (NOIE) on this matter.

NOIE is presently developing a set of minimum standards for computer donation as a way of ensuring greater consistency in the quality of computer donations made. NOIE is also investigating the feasibility of developing an online clearing house facility for use by computer donators and potential recipient organisations

Legal reform

Digital access: Most of the issues covered in HREOC's report dealt with ensuring access to information and transactions that are already available using digital technologies. However, the inquiry was also concerned with promoting increased digital access to information which at present is only available through print on paper - because of the potential, as noted by the inquiry, for digital technologies to be used to provide access for people who cannot use print on paper for reasons including vision impairment or other disabilities.

At the time of HREOC's report, reforms to copyright law updating 's copyright regime to take into account rapid developments in communications technology, particularly the Internet, were before the Parliament. These reforms are known as the Digital Agenda copyright reforms. Importantly, the reforms included the extension of the statutory licence for institutions assisting persons with a print or intellectual disability to allow for the digital reproduction and communication of copyright material in accessible formats.

The purpose of copyright law is to protect the rights of authors and to facilitate public access to information. The Digital Agenda reforms were designed to ensure that an appropriate balance is maintained between the rights of copyright owners and users in the digital environment.

These reforms were passed, albeit in modified form, in August 2000 and commenced on . However, application of the DDA to accessibility of copyright materials, and application of the copyright regime to accessibility issues, continues to involve some complexity.

The legislation as passed confirms that the general right of copyright holders to control reproduction of their copyright material includes the right to control digitisation; but also makes this right subject to a number of exceptions including statutory licences for educational institutions and institutions with a principal function of assisting people with a print or intellectual disability. The extended statutory licence for institutions assisting persons with a disability specifically provides for the reproduction of copyright material into accessible digital formats and the electronic dissemination of such formats (subject to the payment of equitable remuneration ).

Just as real property law (land law) creates or recognises property rights in land and buildings, copyright law creates or recognises property rights in literary, dramatic, musical and artistic works as well as sound recordings, films, radio and television broadcasts and published editions of works. Neither of these sets of property rights is absolute, however, and neither excludes accessibility obligations under the Disability Discrimination Act. Building owners have to ensure that premises open to the public are accessible (except so far as this would impose unjustifiable hardship). Rights of copyright holders also have to be exercised in a way consistent with rights under other laws including rights under the DDA.

Copyright material provided as a service: The clearest obligations under the DDA arise where copyright material is provided as a service (for example as a newsletter or update service to subscribers or members).

The DDA covers discrimination in provision of services. This includes indirect discrimination: where a condition or requirement is imposed which is unreasonable and which disproportionately excludes people with disabilities. The DDA does not, however, require the provision of a different service than the provider is in the business of providing, just because that different service would be more useful to people with disabilities. Drawing a distinction between essential features of a service (which the DDA does not require be changed) on the one hand, and an incidental condition or requirement of using the service (which the DDA will require be changed if it has an unreasonable and discriminatory impact) on the other hand, is important for this purpose although where the line should be drawn may often be a matter of argument.

It seems reasonably clear that the format in which users of a service are required to access information is clearly capable of being found to be a "condition or requirement" ancillary to the service, and so covered by the DDA's indirect discrimination provisions, rather than being an inherent feature of the service and thus not required to change.

Copyright material as goods: The DDA also applies to discrimination in provision of goods. It is less clear however how far this requires publishers to make works available in accessible forms. There appears a stronger argument that the printed form of a book, considered as goods rather than as a service or part of a service, is inherent in the goods rather than involving discrimination in the provision of the goods: just as it is not discriminatory to make shoes even though people without feet cannot wear them or make cakes or drinks which a diabetic cannot eat. There are also contrary arguments however that even considered as goods, what is inherent in a book is the information inside rather than the format as between print and digital form - at least where the content actually exists first in digital form before printing as is now commonly the case.

Copyright material in provision of education, library or other services: Even if the DDA is found not to require directly that copyright material such as books, considered as goods, should be available in accessible formats, provision of accessibility or at least permission for others to provide accessibility may often be required indirectly, where access to copyright material is part of the service provided by educational institutions or other organisations including libraries.

Education is covered in its own right under section 22 of the DDA and library services are included within the scope of services covered by section 24.

If a publisher, by failing to provide material in an accessible form or to permit provision in an accessible form, causes an education provider or a service provider such as a library to discriminate, then under section 122 of the DDA liability for this discrimination will also attach to the publisher.

Need for clarity: The Commission believes all parties concerned would prefer resolution of these issues without the need to resort to complaint procedures under the Disability Discrimination Act and without rights and responsibilities having to be deduced from general and in some cases confusing provisions of competing regimes.

In the area of access to physical premises HREOC has been engaged, with industry, consumer and regulatory representatives, in extensive work to deal with this problem, by upgrading the access requirements of the building code with the intention that these should be recognised as authoritative for DDA purposes.

The Commission notes that as a result of the Digital Agenda copyright reforms the availability of copyright material in accessible digital formats has been facilitated through the extension of various exceptions and statutory licences. Such schemes however are complex. It has been argued that this has resulted in a lack of understanding of their practical application by the relevant institutions (such as institutions assisting persons with disabilities), and a lack of certainty as to the scope of the activities allowed under the various schemes.

The Copyright Council has issued a useful information sheet (albeit in PDF format) on "People with a disability: using copyright material": see . This material confirms a view from copyright holders that the Digital Agenda reforms should be given a fairly wide effect, including the point that the statutory licence for organisations assisting people with print disabilities should be regarded as including organisations assisting people who cannot manipulate a book or pages because of a physical disability.

Despite this material, discussions since HREOC's report have identified considerable confusion remaining in relation to what is permitted and what is not even among the best informed sections of the disability and service provider communities.

There appears to be need for further discussion, including through the Accessible E-commerce Forum, of measures needed to clarify rights and responsibilities regarding provision of copyright material in digital form for people with disabilities. 

Materials for students

HREOC's report stated that "there appears to be urgent need for institution (whether by negotiation or regulation) of a regime for timely and reliable electronic provision or reproduction of copyright materials for students, including ensuring that security measures adopted by publishers to protect their own legitimate interests do not lock out or disable accessibility options".

The report referred to evidence of delays of weeks or months involved in working through copyright issues, and arranging for reproduction of materials in an alternative format, which place students with a disability at a vast disadvantage. The report referred to a major collaborative effort launched in the in 1999 to achieve equal access for students who are blind or vision impaired, and indicated that a similar effort is required in .

HREOC is aware that organisations representing blind people and people with a print disability have been discussing these issues, but no specific action to implement this recommendation appears to have been undertaken to this point.

HREOC considers issues in this area a major priority and will work with relevant organisations in 2002 to achieve progress in this respect.

Individual initiatives

A number of financial institutions have either renewed their commitment to addressing e-commerce barriers or established their own action plans since the publication of the Commission's report.

The National Australia Bank and Westpac have DDA Action Plans lodged with HREOC at and the Commonwealth Bank has been working closely with COTA on education and training programs aimed at older Australians.

A stock take of Commonwealth and State and Territory Internet access initiatives completed by the National Office for the Information Economy (NOIE) in 2000 listed over 230 projects to increase individual and community access to the Internet. This list is available at but the future format of the database is currently under review.

Individual initiatives reported by NOIE include:

NetSpots Directory

The NetSpots Directory is a national directory developed to enable people to find their nearest public Internet access facility. People can call 1800 222 797 and ask the operator to find them their nearest public Internet access location. NetSpots can also be accessed online at: .

Save@Home

The Save@Home report examines the benefits of home Internet access across a range of household types, showing that Australians can derive significant benefits from Internet access.

Copies of the report, or a report summary, can be obtained by contacting NOIE on 02 6271 1666 or by emailing access@noie.gov.au .

Computer Recycling

NOIE has compiled a list of organisations that recycle donated computers or offer special deals to some organisations for purchase/leasing of computer equipment. The list is available online at: .

As noted earlier, NOIE is also developing a set of minimum standards for computer donation as a way of ensuring greater consistency in the quality of computer donations made and investigating the feasibility of developing an online clearing house facility for use by computer donators and potential recipient organisations.

Tech Trek

Follow the Tech Trek on its tour of regional in a bus fitted with the latest in wireless communication and Internet technologies. The Tech Trek aims to raise community awareness of the benefits of the Internet and will survey remote as well as regional and metropolitan Australians about the issues affecting their participation in the information economy. The project has been co-sponsored by NOIE and information on current NOIE projects to address the digital divide will be available at Tech Trek events around .

Retirement Request for Tender( RFT)

The Retirement RFT is part of the Commonwealth Government's Trials of Innovative Government Electronic Regional Services (TIGERS) program that is making it easier to transact online with Commonwealth, State and Local Government at a single point.

To help people plan for and enter retirement, TIGERS is developing an online 'service pack' which will help cut through the maze of government departments and agencies involved in this area. The service pack will bring together government information and services relating to retirement from all levels of government in a single website. It will include information from the Commonwealth Government regarding pensions and allowances, assistance with renting costs provided by the Tasmanian Government, and discounts on rates and dog licences provided by local government.

The RFT is available online from the Commonwealth Electronic Tender Service (CETS) at . A briefing session was held in for prospective tenderers on - for further information call (03) 6233 5161.

Initiatives reported by the Department of Communications, IT and the Arts:

Internet Assistance Program

The IAP is a $50 million joint initiative with Telstra to improve Internet data speeds to achieve the equivalent of at least 19.2 kilobits per second across . The IAP provides a range of help services to solve Internet problems for residential and small business users, with up to two phone lines. Through the IAP these customers are now able to get free help to achieve a reasonable Internet speed from their dial-up service.

The IAP Self Help Website - - allows regional communities to test their connection to the Internet against the program's benchmark of 19.2kbps. If their current Internet access achieves an effective data speed of less than 19.2kbps the website provides them with helpful tips to improve access.

Information and data speed tests are available on the Internet at . Alternatively the Online Help Service centre can be contacted freecall 1800 427 457 between Monday to Friday or weekends between .

A Technical Support Service will assist users whose problems cannot be resolved by the Online Help Service. The Technical Support Service will identify technical problems by Internet and line testing services.

New Connections website

The New Connections website provides a region-by-region listing of relevant telecommunications service providers, carriers and funding programs. This is a 'one-stop-shop' regional telecommunications portal where a click of the mouse can access information on subjects as diverse as local projects and funding, available telecommunications carriers and consumer rights.

Networking the Nation

Networking the Nation, the Commonwealth's five-year Regional Telecommunications Infrastructure Fund, is helping bridge the gaps in telecommunications services, access and costs between urban and non-urban .

Networking the Nation aims to assist the economic and social development of regional, rural and remote by funding projects which:

        enhance telecommunications infrastructure and services in those areas;

        increase access to, and promote use of, services available through telecommunications networks; and

        reduce disparities in access to such services and facilities.

For further information visit the NTN website at or free call 1800 674 058.

Other Community/Private Sector Initiatives include:

Telstra centre for accessibility

The Centre for Accessibility is part of the Human Factors Group of the Telstra Research Laboratories (TRL) located at . In the short-term, the major focus for the Centre is achieving online accessibility for blind users of the Telstra web site. The broader, long-term objectives of the Centre are:

• To evaluate the online accessibility of Telstra products, services and systems.
• To promote compliance with the corporate standard on Universal Design within Telstra through workshops and consulting, supported by an Intranet site providing accessibility resources and information.
• To review and report to Telstra stakeholders on developments in accessibility, including the monitoring of standards activities and accessibility developments in and overseas.
• To monitor consumer trends and provide technical input to assist in the identification and resolution of issues.
• To act as a communications link between Telstra Research Laboratories, Telstra's Disability Services Unit and the Business Units, monitoring projects under development for early identification of potential accessibility issues.
• To understand accessibility issues likely to arise from new and emerging technologies.
• To undertake research into ways of improving accessibility for new and emerging technologies.

For more information see

Web-4-All

Web-4-All is a smart card based system that provides Internet access through a variety of alternative-access PC applications for people with non-standard PC/Internet access requirements. It's designed to be used on public Internet access PC terminals. It allows users to select an interface application and configuration, store the setting to a smart card, restore the settings to the PC automatically at the beginning of each new session and restore the default interface settings on the PC at the end. A smart card is used to store the individual's settings, allowing users to invoke their personally configured settings at any public PC/interact access terminal equipped with Web-4-All technology. This system allows one PC to meet everyone's needs as opposed to the usual approach of having specific stations designated to meet the needs of people with each particular requirement.

The training/support kit includes user training materials in alternate formats such as Braille, large print, audiotape, and plain electronic text on computer disk.

A major trial of this system is being undertaken by the Government of Canada. The system has been developed by the Adaptive Technology Resource Centre at the under contract to Industry .

Vision Australia Foundation is implementing an Australian trial of Web-4-All. Contact for further information is Brian Hardy, Manager Information Services Development, Vision Australia Foundation tel (03) 9864 9525 or 0419 102 451 or e mail brian.hardy@visionaustralia.org.au

NEAT

The NEAT listserv (Network on Education, Ageing and Technology) started in December 1999. Its cross-sectoral and interdisciplinary membership includes community, peak, and government representatives, researchers and IT providers with a common interest in enhancing access to, and use of, technology by older people.

The NEAT listserv is based at the Institute for Rural Futures, . It has a cross-sectoral and interdisciplinary membership which includes those with a common interest in enhancing access to, and use of, technology by older people.

The network complements other initiatives by providing a venue for its members to promote activities and programs, share information and has proved to be an effective venue to raise and discuss issues of common concern.

The NEAT listserve is one example of grassroots networks, which are proving to be a crucial component in bridging of the digital divide. Such networks can bring people into contact with information and ideas from elsewhere in the country and elsewhere in the world.

The network members come from every State and Territory of , as well as a handful from other countries. The NEAT listserv currently operates without any funding or sponsorship and as a consequence there is no web site for the network.

For further information or to join the network contact Ros Foskey, Project Director, Institute for Rural Futures, email rfoskey@metz.une.edu.au

Conclusion

Over the past year considerable progress has been made by government, business and the community sector towards addressing many of the recommendations arising from the Commission's inquiry into e-commerce access. While many initiatives have occurred independent to the accessible e-commerce inquiry or the subsequent work of the Accessible E-commerce Forum, the Forum has significantly assisted in clarifying the barriers to be addressed and promoting partnerships to address them.

Commitments have been made by government and the business sector to continue working with the community to find solutions to many of the barriers identified and the Commission is confident that the next six months will see further changes occurring that will result in many of the reports recommendations being addressed.

To find out more about accessible e-commerce look at the Commission's web page

Many other organisations are taking action to address the digital divide and are invited to provide information on their initiatives to the Commission at disabdis@humanrights.gov.au

 

Appendix 1: Reference given to the Commission by the Attorney-General

 

The Attorney-General's reference requested the Commission to:

• Investigate the implications for older Australians and those Australians with a disability of the rapid development and use of new technologies in electronic commerce and the provision of government and other services, and outline their specific needs in accessing services which utilise such technologies;
• Examine the difficulties and restrictions faced by older Australians and those with a disability in achieving full and equal access to services utilising new technologies and deriving full benefit from such technologies;
• Advise on options for use of digital technology in removing barriers to access to government and business information and services for older Australians and people with a disability;
• Conduct an audit of the accessibility of Australian government and business internet sites, in particular for people with impaired vision, by reference to the Disability Discrimination Act and relevant Australian and international guidelines;
• Advise on needs and options for education or training to promote equal access to electronic information and services for older Australians and for people with a disability;
• Suggest other steps that could be taken by the Commonwealth and by service providers to improve access for older Australians and those with a disability to services utilising new technologies and suggest strategies for avoiding the marginalisation of these groups as a result of the use by service provider of such technologies; and
• Suggest minimum standards that should be met when introducing new technologies into service provision.

Appendix 2 Summary of recommended measures and proposed actions

On the basis of submissions received and research conducted for this reference the Commission recommends the following measures for consideration by the Commonwealth, and by other parties concerned:

• Ensuring as far as possible that on line and automated services are used to complement and enhance availability of direct human service rather than completely substituting for it, and that information on available alternatives to automated services is effectively available
• Increased efforts by relevant government agencies in co-operation with industry associations and community organisations to ensure that people developing and implementing new technologies are aware of access issues
• Increased business and government support for community access points for online services and for awareness, education and training for people who might otherwise remain on the wrong side of a "digital divide"
• Specifically, increased provision (in particular by the Commonwealth) of superseded equipment, through organisations such as Technical Aid to the Disabled and computer clubs for seniors
• Increased focus on provision of appropriate equipment, software, training and information to meet needs of people requiring adapted or customised equipment to achieve effective internet access
• Implementation of the Commonwealth's Electronic Transactions Act, and similar electronic transactions recognition measures at State level
• Appropriate resolution of issues affecting access to copyright material, whether by regulatory means in combination with negotiated agreements (as envisaged by the Government's proposed reforms) or by negotiated agreement alone (if those reforms do not progress or only progress as proposed to be limited by the House of Representatives Legal and Constitutional Committee)
• Particular attention to issues of equal and timely access to materials in electronic form for students with disabilities
• Revision of Australian Standards applicable to ATMs and similar devices, to provide more effective guidance on achieving equal access consistent with requirements of the Disability Discrimination Act
• Upgrading of accessibility of ATMs and similar devices including replacement with machines incorporating international best practice in accessibility
• Continued attention by relevant Australian industry bodies to international developments in EFTPOS accessibility options
• Attention to universal design approaches in implementation of automated identification technologies and smart card systems
• Implementation by Commonwealth departments and agencies of Cabinet's decision of requiring web site accessibility
• Other information and service providers ensuring compliance of their web sites with the World Wide Web Consortium's Web Content Accessibility Guidelines
• Wider implementation of the existing Australian Standard on interactive voice response systems
• Ongoing support by the Commonwealth (as currently provided through the AccessAbility program administered by the Department of Communications, Information Technology and the Arts) for assessment by community experts of access issues and options arising from new technologies
• Consideration of means of achieving more open access to Australian Standards, comparable to that now available for legislation and regulatory materials
• Governments providing leadership by requiring and applying international best practice on technology accessibility in their own operations, including specification of clearer accessibility benchmarks than presently provided in policies of most Australian governments
• Relevant industry bodies taking an increased role in educating those developing and implementing new technologies on accessibility issues.