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daily12013-02-28T01:23:34ZGroundbreaking disability rights activist Javed Abidi dies at 53
http://editors.cis-india.org/accessibility/blog/groundbreaking-disability-rights-activist-javed-abidi-dies-at-53
<b>The Centre for Internet & Society (CIS) expresses profound regret at the demise of Mr. Javed Abidi, a groundbreaking disability rights activist.</b>
<p style="text-align: justify; ">As Director of the National Centre for Promotion of Employment for Disabled People (NCPEDP), he was instrumental in bringing issues pertaining to various disabilities under an umbrella organisation, and ensuring greater visibility in mainstream media. He labored to make educational resources, employment opportunities and public spaces more accessible for PwDs across barriers of class and gender.</p>
<p style="text-align: justify; ">A noted voice in the field of disability rights, Abidi contributed immensely to shifting the conversation around disability from a welfarist and paternalistic approach to one that was grounded in rights and freedoms over the past two decades. He worked at the intersection of civil society and government, and under his aegis, the NCPEDP played a key role in the passing and implementation of the landmark Rights for Persons with Disabilities Act, 2018.</p>
<p style="text-align: justify; ">Dr. Nirmita Narasimhan, Senior Fellow and formerly Policy Director at the CIS, says, “I met Mr. Javed Abidi when we started CIS way back in 2008. At that time I was completely overwhelmed by his personality and totally in awe of him and his work. This feeling only grew over the last decade. We first worked on pushing the National Policy on Universal Electronics Accessibility. He also supported our right to read campaign and spread the word about our copyright work. Over the years, he supported and promoted our work on multiple issues, and included us in key discussions amongst the disability leadership in India.”</p>
<p style="text-align: justify; ">As part of his work with CIS, he advocated for greater legislative rights and institutional support through measures such as universally accessible government data and services in the digital space, and affordable aid technology. Dr. Narsimhan continued, “He looked to CIS as an ally and expert in ICT accessibility and always ensured that we were included in discussions on this topic in government committees and outside. At a personal level, I feel privileged that he took a keen interest in my work.” A central concern within this work was to highlight the intersection of disability with poverty, gender disparity, lack of education, and social stigma.</p>
<p style="text-align: justify; ">“The fire and passion in his work, his fearlessness in advocating for what he believed was right, the sheer strength of his personality and mind, his systematic and meticulous approach towards any issue all served as important learning points for me. He made me feel proud to be an Indian and working for the rights of persons with disabilities in India. He has truly touched the lives of millions of people in a way which very few people have done in their lifetime. I hope that we continue and expand our work in digital accessibility and contribute to making his vision of an inclusive India a reality,” concluded Dr. Narsimhan.</p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/groundbreaking-disability-rights-activist-javed-abidi-dies-at-53'>http://editors.cis-india.org/accessibility/blog/groundbreaking-disability-rights-activist-javed-abidi-dies-at-53</a>
</p>
No publisherAmbika TandonAccessibility2018-03-06T14:42:47ZBlog EntryComments on Guidelines for Indian Government Websites
http://editors.cis-india.org/accessibility/blog/comments-on-guidelines-for-indian-government-websites
<b>The Ministry of Electronics & Information Technology, Government of India has published the Guidelines for Indian Government Websites (GIGW). Nirmita Narasimhan on behalf of the Centre for Internet & Society gave comments on GIGW.</b>
<ul>
<li>See the response to suggestions and comments sent on GIGW by committee members <a class="external-link" href="http://cis-india.org/accessibility/files/response-to-suggestions-and-comments-sent-on-gigw-by-committee-members">here</a></li>
<li>See the Guidelines for Indian Government Websites <a class="external-link" href="http://cis-india.org/accessibility/files/gigw-2017">here</a></li>
</ul>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/comments-on-guidelines-for-indian-government-websites'>http://editors.cis-india.org/accessibility/blog/comments-on-guidelines-for-indian-government-websites</a>
</p>
No publishernirmitaAccessibility2017-11-26T07:08:25ZBlog EntryComments on Mobile Accessibility Guidelines
http://editors.cis-india.org/accessibility/blog/cis-comments-on-mobile-accessibility-guidelines
<b>The Centre for Internet & Society (CIS) submitted its comments on mobile accessibility guidelines to the Ministry of Electronics & IT, Govt. of India.</b>
<p style="text-align: justify; ">Consolidated comments on mobile application guidelines:</p>
<ul style="text-align: justify; ">
<li>Overall, this document is very difficult to review and comprehend. It needs to be more structured. If the mobile accessibility practices had provided earlier can be directly adopted that adds more value</li>
<li>Avoid adopting WCAG POUR structure. If it is used use it wisely.</li>
<li>Certain checkpoints do not have appropriate headings. E.g. D, E, G, H must be under perceivable but currently are under Operable. Similarly, I must be under Understandable but currently under Operable.</li>
<li>Some checkpoints are difficult to understand. E.g. Grouping operable elements that perform the same action.</li>
<li>Provide WCAG 2.0 reference with techniques and tools to test wherever appropriate</li>
<li>If any of the checkpoints are differentiated as Mandatory, advisory and voluntary specifically mention them against each checkpoint.</li>
<li>Section specific comments:</li>
</ul>
<ol style="text-align: justify; ">
<li>In section 1.A, The requirement that since screen size is small we should only use native applications does not make sense.</li>
<li>Section 2.d, 2.e, 2.g and 2.i should go in first section i.e. perceivable.</li>
<li>Section 2.F suggests that buttons should be placed where they are easy to access. But there is no criteria to decide what is easy to access? For example, in iOS, back button is at top left and often important buttons such as end call, ok etc. are placed at the bottom of the screen. Similarly, there are conventions for Android. Please check Android conventions and refer to the same in this document. We could require that app developers should follow conventions for the platform that they are building for</li>
<li>Section 3.a would go in part 2 i.e. operability</li>
<li>Section 4.a and 4.b would go in operability.</li>
<li>Section 4d onwards do not belong in robust, they should be in additional section</li>
<li>Include Mobile Practice 10 from Mobile practices v1.0 that deals with custom actions. Custom actions behave like context menus and help screen reader users.</li>
<li>We also recommend that Mobile Practice 2,3,4 and 5 from Mobile practices v1.0 could be included under principle 4 i.e. robust.</li>
</ol>
<p style="text-align: justify; ">A lot of reflection and deliberations happened during development of Mobile Practices so taking those practices would improve the guidelines. For example, practice 2 has a lot more details about why it is important and how to add labels.</p>
<p style="text-align: justify; ">Download the <a class="external-link" href="http://cis-india.org/accessibility/files/mobile-accessibility-guidelines">full submission here</a></p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/cis-comments-on-mobile-accessibility-guidelines'>http://editors.cis-india.org/accessibility/blog/cis-comments-on-mobile-accessibility-guidelines</a>
</p>
No publishernirmita2018-01-03T02:37:10ZBlog EntryWhy GST Is A Step Backward For The Disabled
http://editors.cis-india.org/accessibility/blog/why-gst-is-a-step-backward-for-the-disabled
<b>Imposing taxes on assistive devices is unfair. The countdown has begun to the implementation of the GST in India. Over the past month, discussions about the GST have dominated the scene with several groups protesting in strong measure about the impact on their business.</b>
<p>The article by Nirmita Narasimhan was published by <b><a class="external-link" href="http://www.huffingtonpost.in/nirmita-narasimhan/why-gst-is-a-step-backward-for-the-disabled_a_23009350/">Huffington Post</a></b> on July 1, 2017.</p>
<hr />
<p style="text-align: justify; ">This post is concerned with the impact of an underrepresented group—that of persons with disabilities, who are facing severe impediments to their rights to independent living, mobility and participation if the GST is implemented as proposed in the present notification.</p>
<p class="callout" style="text-align: justify; ">It is unconscionable that disability aids and assistive technology are considered a luxury and taxed at a higher rate than rough semi-precious stones or cashew nuts.</p>
<p>The new GST rules seek to impose tax on assistive technologies and goods and services which are essential for the advancement of persons with disabilities and will consequently, hamper their mobility as well as ability to participate in education and employment.</p>
<p>Some noteworthy points are:</p>
<ul>
<li style="text-align: justify; ">5% GST on Braille typewriters, Braille paper, Braille watches and Braillers (originally set to 18% for typewriters and 12% for Braille paper and watches and reduced after protests from organisations like the National Centre for Promotion of Employment of Disabled People (NCPEDP), the Disability Rights Organisations Forum (DROF), and various regional groups. Only Braille books are exempt from the tax.</li>
</ul>
<ul>
<li style="text-align: justify; "> 12% GST on orthopaedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability. Hearing aids have also been listed under the list of goods with nil taxes, which is contradictory.</li>
</ul>
<ul>
<li> 18% GST on motor vehicles for persons with disabilities.</li>
</ul>
<ul>
<li style="text-align: justify; "> IT software, consulting and support services, online text, audio and video, software downloads etc. have all been classified but no GST rate has been quoted, which implies that they are taxed at 18%. This means software like screen readers, assistive software for persons with cognitive disabilities, online text etc. which are essential aspects of communications and information access for persons with disabilities will also be taxed at 18%, which will severely hamper their ability to communicate and even carry out daily tasks.</li>
</ul>
<p style="text-align: justify; ">It is incomprehensible that the government should choose to impose a tax on the ability to walk, talk and deliberate using crutches, prosthetic limbs, hearing aids and communicating using assistive reading software for persons who have disabilities. It is unconscionable that disability aids and assistive technology are considered a luxury and taxed at a higher rate than rough semi-precious stones or cashew nuts. On the other hand, items such as kajal and glass bangles are not being taxed at all. Is ornamentation more important than the ability of persons with disabilities to lead their lives with dignity and independence? The current GST structure is discriminatory, making it even more difficult for persons with disabilities to participate in society, and contradicts the vision of an <a href="http://accessibleindia.gov.in/content/" rel="nofollow">Accessible India.</a></p>
<p style="text-align: justify; ">Until we are able to assure the level of independence, accessibility and resources to the disabled to live a life of dignity like other countries do, we should not levy tax like them.</p>
<p style="text-align: justify; ">India is measuring herself against other developed countries where a reduced percentage of tax is levied on goods and services for persons with disabilities. Unfortunately however, the comparison ends there and does not extend to providing world-class services and facilities for the disabled, such as accessible roads, transportation, information. It would be wiser to follow our own lead from the past decade when we had not levied any tax on such items. The progress of this group has been painfully slow thus far anyway, so what will happen if GST rates up to 18% are levied?</p>
<p style="text-align: justify; ">As a country, we are not yet ready for this. We are still in a state where thousands of children with disabilities drop out of school even at the pre-primary level because they do not have the resources—technology, books, training and help—to pursue education. We still have a long way to go in terms of achieving basic rights for persons with disabilities, which is no longer the case in the developed countries that we seek to follow. The argument is hence not a blanket opposition to tax for persons with disabilities, just because they are disabled, but on the basis that until and unless we are able to assure the level of independence, accessibility and resources to the disabled to live a life of dignity and inclusion like other countries do, we should not consider levying tax like them. A person using a wheelchair in Germany can travel using public transport, but the same is impossible in India.</p>
<p style="text-align: justify; ">Once we are able to achieve the level of inclusion and accessibility of developed countries, we may consider taxing for certain items, although perhaps still not for all on the list. However, that time is not now. To build an inclusive society, we need to support persons with disabilities in all possible ways and imposing taxes on assistive devices will take us many steps backward.</p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/why-gst-is-a-step-backward-for-the-disabled'>http://editors.cis-india.org/accessibility/blog/why-gst-is-a-step-backward-for-the-disabled</a>
</p>
No publishernirmitaAccessibility2017-07-03T02:39:18ZBlog EntryGST - A Barrier to Human Rights for Persons with Disabilities
http://editors.cis-india.org/accessibility/blog/gst-a-barrier-to-human-rights-for-persons-with-disabilities
<b>The Centre of Internet & Society made a submission on the Goods and Services Tax (GST) which will be coming into play from July 2017 onwards. In this blog post Nirmita Narasimhan assesses the impact of GST on persons with disabilities. </b>
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<th><img src="http://editors.cis-india.org/home-images/ShuttleworthFoundation.jpg" alt="null" class="image-inline" title="Shuttleworth Foundation" /></th>
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<td>Logo of Shuttleworth Foundation above</td>
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<p style="text-align: justify;">The GST Acts - Central Goods and Services Tax Act, Integrated Goods and Services Tax Act and the Union Territory Goods and Services Tax Act passed on 12 April 2017 and the subsequent notification of the Revised GST Rate for Certain Goods on 11th June 2017 have serious and severe implications on basic rights and freedoms for persons with disabilities, hindering them from living independently and pursuing education, and employment. This note outlines the impact of the GST measures as well as recommendations to ensure that the rights of persons with disabilities are not compromised.</p>
<h3 style="text-align: justify;">Problem Statement</h3>
<p style="text-align: justify;">As per the 2011 census, India has over 21 million people with disabilities which is around 2.17% of the population. Persons with disabilities face many hurdles in education and employment which is reflected in the low effective literacy rate of 59%, far below the national level of 74.04% as well as a low work participation rate at 36.3%.<a name="fr1" href="#fn1">[1]</a></p>
<p style="text-align: justify;">Lower levels of literacy and employment in turn imply lower income levels for this group. Thus, additional support through policy, financial and operational measures is required to help persons with disabilities participate fully in the economy. The new GST rules however, seek to impose tax on assistive technologies and goods and services which are essential for the advancement of persons with disabilities, hampering their mobility and ability to participate in education and employment thus further compounding the disadvantages already faced by this group.</p>
<h3 style="text-align: justify;">Main Concerns</h3>
<p>The specific GST provisions that negatively impact persons with disabilities include:</p>
<ul>
<li style="text-align: justify;">5% GST on Braille typewriters, Braille paper, Braille watches and Braillers (originally set to 18% for typewriters and 12% for Braille paper and watches and reduced after protests from organizations like the National Centre for Promotion of Employment of Disabled People (NCPEDP), the Disability Rights Organisations Forum (DROF), and various regional groups)<a name="fr2" href="#fn2">[2]</a></li>
<li style="text-align: justify;">12% GST on Orthopaedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability. Hearing aids have also been listed under the list of goods with nil taxes, which is contradictory.</li>
<li style="text-align: justify;">18% GST on motor vehicles for persons with disabilities.</li>
<li style="text-align: justify;">Braille books are exempt from the tax while other Braille implements are not.</li>
<li style="text-align: justify;">IT software, consulting and support services, online text, audio and video, software downloads etc. have all been classified but no GST rate has been quoted, which implies that they are taxed at 18%. This means software like screen readers, assistive software for persons with cognitive disabilities, online text etc. which are essential aspects of communications and information access for persons with disabilities will also be taxed at 18%, which will severely hamper their ability to communicate and even carry out daily tasks.</li></ul>
<h3>GST – Hampering Accessibility and Inclusion</h3>
<p style="text-align: justify;">Under the existing tax regime, many of these goods have traditionally been exempt from indirect taxes such as VAT, excise and customs. Even with the exemptions, assistive technologies have not been affordable. However, with the addition of GST, the situation becomes even more dire. For instance, according to India Today, the current market price for a Braille typewriter is about INR 34,000<a name="fr3" href="#fn3">[3]</a>, or over 20 times higher than the monthly income of an impoverished urban Indian. Even with the new 5 percent GST (a reduction from the previous 18 percent), this would work out to INR 35,700. Given that 29.5 percent of the total population of India remained below the poverty line in 2011-12 and had a monthly per capita consumption of less than INR 972 in rural areas and INR 1407 in urban areas, <a name="fr4" href="#fn4">[4]</a> assistive technology would be prohibitively expensive even for the average Indian, let alone persons with disabilities.</p>
<h3 style="text-align: justify;">GST – Discriminatory against Persons with Disabilities</h3>
<p style="text-align: justify;">The proposed GST on assistive technology is not only detrimental to the use of assistive technology, it discriminates against the right to equality of persons with disabilities.</p>
<p style="text-align: justify;">Tools necessary for people pursuing their livelihood, such as agricultural implements and hand tools such as spades, shovels, mattocks, etc. used in agriculture, horticulture and forestry are exempt from any tax. However, assistive technologies which are just as vital for the education and livelihood of persons with disabilities, have been included in the list of items taxed under GST. While the Government of India’s move to protect the livelihood of agricultural workers is commendable, it needs to equally protect the right to livelihood of persons with disabilities who are working - 31% of whom are in the agricultural sector and will suffer from the imposition of GST.</p>
<h3 style="text-align: justify;">GST – Impacting Mobility</h3>
<p style="text-align: justify;">The proposed GST on motor vehicles for persons with disabilities also impacts their right to mobility as per Article 41(2) of the Persons with Disabilities Act which calls for the government of India to “promote the personal mobility of persons with disabilities at affordable cost” through measures including incentives and concessions. The imposition of such a high tax on car purchases by persons with disabilities is in direct contravention of this.</p>
<h3 style="text-align: justify;">Legal Framework</h3>
<p style="text-align: justify;">The proposed GST implementation and tax on products and services that are critical for persons with disabilities to pursue independence, literacy and employment with dignity runs counter to both national and international law to which India is a signatory.</p>
<p style="text-align: justify;">Article 38 of the Constitution of India also requires the government to minimize inequalities in income, status, facilities and opportunities among individuals and groups of people.</p>
<p style="text-align: justify;">The Rights of Persons with Disabilities Act 2016, enjoin the government to utilise the capacity of persons with disabilities by providing appropriate environment (Art 3(2) ) and take necessary steps to ensure reasonable accommodation for persons with disabilities (Art 3(5)).</p>
<p style="text-align: justify;">The UN Convention on the Rights of Persons with Disabilities, which India has signed and ratified, calls on nations to promote the development and adoption of assistive technologies and devices for persons with disabilities, again “giving priority to technologies at an affordable cost.” (Article 4 (g)). Additional provisions include:</p>
<ul>
<li style="text-align: justify;">Art 4 – General Obligations asks states parties to take into account the protection and promotion of the human rights of persons with disabilities in all policies and programmes; </li>
<li style="text-align: justify;">Art 5 (3) - asks States Parties to take all appropriate steps to ensure that reasonable accommodation is provided </li>
<li style="text-align: justify;">Article 20 also requires nations to facilitate access to mobility aids, assistive technologies and other intermediaries, and requires that they be made available at affordable cost. </li>
<li style="text-align: justify;">Art 24 on Education enjoins States parties to ensure persons with disabilities have access to inclusive education, that reasonable accommodation is provided and use of Braille, alternative modes and formats is facilitated </li>
<li style="text-align: justify;">Art 27 on Work and employment required nations to protect the rights of persons with disabilities, on an equal basis with others, to just and favourable conditions of work </li>
<li style="text-align: justify;">Art 29 on participation in political and public life advocates the creation of an environment that enables persons with disabilities to participate fully and effectively in the conduct of public affairs </li></ul>
<h3 style="text-align: justify;">International Practices</h3>
<p style="text-align: justify;">While developed countries do levy some tax on assistive technology and devices used by persons with disabilities, these are typically lower than the general rates. Countries in the EU levy lower VAT rates on medical equipment for persons with disabilities <a name="fr5" href="#fn5">[5]</a> for instance 6% in Belgium and 3% in Luxembourg. However, a point to be noted here is that the literacy and employment rates for persons with disabilities in these countries are much higher than in India, where the low literacy and work participation mean that even low levels of taxation on assistive technology make items prohibitively expensive.</p>
<p style="text-align: justify;">An alternative approach more suitable in the Indian context, is that followed by developing countries such as Brazil and the Philippines. In Brazil, which has around 16 million <a name="fr6" href="#fn6">[6] </a>persons with disabilities, the import and sale of assistive technologies such as wheelchairs, Braille machines, calculators with voice synthesizers and hearing aids are exempt from major federal taxes. In addition, persons with disabilities wishing to buy a car also enjoy exemptions from several federal and municipal taxes. <a name="fr7" href="#fn7">[7] </a>In the Philippines, where 1.57 % of the population <a name="fr8" href="#fn8">[8] </a>have some form of disability, the Republic Act 9442<a name="fr9" href="#fn9">[9]</a> guarantees a 20 per cent discount for persons with disabilities and also provides assistance for education. Discounted goods and services include:</p>
<ul>
<li>Restaurants, hotels and other recreation centers </li>
<li>Theaters, concert halls, carnivals, and other cultural and leisure centers </li>
<li>The purchase of medicines from drugstores </li>
<li>Medical, diagnostic and laboratory fees </li>
<li>Medical and dental service, including doctors’ fees </li>
<li>Domestic air and sea travel </li>
<li>Public railways, skyways, and bus fare </li></ul>
<p style="text-align: justify;">In addition to this, Republic Act 10754 <a name="fr10" href="#fn10">[10]</a> adds an exemption from the 12 percent VAT for persons with disabilities as well. Both of these represent a significant discount.</p>
<h3>Conclusion</h3>
<ol>
<li style="text-align: justify;">We fully concur with the representations made by different organisations working for persons with disabilities in India seeking a complete roll back of GST for persons with disabilities. India has in the past, refrained from taxing the disabled deliberately, keeping in mind their particular needs and circumstances and nothing has changed in the past few years to warrant this move. Persons with disabilities remain below the poverty line, without access to information, resources and the ability to enjoy even their basic human rights to live a life of freedom, independence, dignity, inclusion and participation. It is unconscionable to place such articles of basic need such as crutches and wheel chairs without which a person cannot even move on the same level as other goods. Certainly these are more basic than other items such as glass bangles or kajal which are not subject to GST or semi-precious stones which are taxed at a very minimum.</li>
<li style="text-align: justify;">Rolling back GST would be in accordance with national and international legal commitment. India cannot place itself on the same level as countries in the EU for taxing the disabled; we do not have the same infrastructure and resources which these countries have made available for their disabled citizens, nor the social security measures which they offer. They are better placed in terms of development and progress of the disabled, with regard to education, employment and daily living. We cannot impose 18% tax on vehicles for the disabled while we are not providing them with a completely functional accessible transport network, accessible roads and a barrier-free environment. A very small percentage of persons with disabilities in India is actually living a full and complete life with access to resources and aids, an imposition of tax will further minimise chances of progress in the years to come of empowerment and emancipation of persons with disabilities. India has been a thought leader in the field of disability internationally in terms of its policies and served as an inspiration to countries around us. We were one of the earliest countries to sign and ratify the UNCRPD, as well as the first country to ratify the Marrakesh Treaty more recently in 2014. We do not lack in spirit, however do not always follow up with action. The roll back on GST would be an appropriate move in line with our commitment to enable human rights for persons with disabilities and empower them with the use of technology and other tools and resources. </li>
<li style="text-align: justify;">Specified exemptions for use of assistive technologies- Technology has proven a source of tremendous empowerment to persons with disabilities. Given that most ICTs are to be taxed at 18%, we strongly urge the government to specifically exclude all ICTs and downloaded software and content which are intended for persons with disabilities from tax. By imposing tax on an enabling technology, it would be tantamount to imposing tax on a sensory organ, i.e., by imposing tax on a hearing aid or screen reader, which would enable a deaf person to hear/ a blind person to read, it would be like imposing tax on ears or eyes. We hence strongly urge the government to reconsider the present move and set right the error which has been committed by subjecting goods and services for persons with disabilities to tax. We recommend review, complete roll back and explicit exemption on all goods and services for persons with disabilities from the purview of GST. </li></ol>
<p>23 June, 2017</p>
<hr />
<p>[<a name="fn1" href="#fr1">1</a>]. <a class="external-link" href="http://www.censusindia.gov.in/2011census/population_enumeration.html">http://www.censusindia.gov.in/2011census/population_enumeration.html</a></p>
<p>[<a name="fn2" href="#fr2">2</a>]. <a class="external-link" href="http://www.thehindu.com/todays-paper/tp-national/tp-otherstates/drag-seeks-rollback-of-gst-ondisability-aids/article19123085.ece">http://www.thehindu.com/todays-paper/tp-national/tp-otherstates/drag-seeks-rollback-of-gst-ondisability-aids/article19123085.ece</a></p>
<p>[<a name="fn3" href="#fr3">3</a>]. <a class="external-link" href="http://indiatoday.intoday.in/story/gst-goods-and-services-tax-arun-jaitley-narendra-modi-disabledbraille/1/967920.html">http://indiatoday.intoday.in/story/gst-goods-and-services-tax-arun-jaitley-narendra-modi-disabledbraille/1/967920.html</a></p>
<p>[<a name="fn4" href="#fr4">4</a>]. <a class="external-link" href="http://planningcommission.nic.in/reports/genrep/pov_rep0707.pdf">http://planningcommission.nic.in/reports/genrep/pov_rep0707.pdf</a></p>
<p>[<a name="fn5" href="#fr5">5</a>]. <a class="external-link" href="http://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/taxation/vat/how_vat_ works/rates/vat_rates_en.pdf">http://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/taxation/vat/how_vat_ works/rates/vat_rates_en.pdf</a></p>
<p>[<a name="fn6" href="#fr6">6</a>]. <a class="external-link" href="https://www.disabled-world.com/news/south-america/">https://www.disabled-world.com/news/south-america/</a></p>
<p>[<a name="fn7" href="#fr7">7</a>]. <a class="external-link" href="http://thebrazilbusiness.com/article/tax-reduction-for-people-with-disabilities">http://thebrazilbusiness.com/article/tax-reduction-for-people-with-disabilities</a></p>
<p>[<a name="fn8" href="#fr8">8</a>]. <a class="external-link" href="https://psa.gov.ph/content/persons-disability-philippines-results-2010-census">https://psa.gov.ph/content/persons-disability-philippines-results-2010-census</a></p>
<p>[<a name="fn9" href="#fr9">9</a>]. <a class="external-link" href="http://www.ncda.gov.ph/disability-laws/republic-acts/republic-act-9442/">http://www.ncda.gov.ph/disability-laws/republic-acts/republic-act-9442/</a></p>
<p>[<a name="fn10" href="#fr10">10</a>]. <a class="external-link" href="http://www.ncda.gov.ph/disability-laws/implementing-rules-and-regulations-irr/irr-of-ra-10754-anact-expanding-the-benefits-and-privileges-of-persons-with-disability-pwd/">http://www.ncda.gov.ph/disability-laws/implementing-rules-and-regulations-irr/irr-of-ra-10754-anact-expanding-the-benefits-and-privileges-of-persons-with-disability-pwd/</a></p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/gst-a-barrier-to-human-rights-for-persons-with-disabilities'>http://editors.cis-india.org/accessibility/blog/gst-a-barrier-to-human-rights-for-persons-with-disabilities</a>
</p>
No publishernirmitaAccessibility2017-06-25T14:15:05ZBlog EntryReport of the Global Accessibility Awareness Day 2017
http://editors.cis-india.org/accessibility/blog/report-gaad-2017
<b>Aditya Tejas attended the Global Accessibility Awareness Day event organized at NIMHANS Convention Centre in Bengaluru. The event had multiple panels and presentations, including a talk on coding for accessibility, a panel on why accessibility is necessary and how India is lagging behind in implementing it, and a presentation on how accessibility principles are integrated into the product life cycle at Cisco.</b>
<p><strong>Logo of Shuttleworth Foundation below: </strong></p>
<p style="text-align: center;"><img src="http://editors.cis-india.org/home-images/ShuttleworthFunded.jpg/@@images/a7ad882b-1f69-4576-a25a-bffe5f942c79.jpeg" alt="null" class="image-inline" title="Shuttleworth" /></p>
<hr />
<p style="text-align: justify;">Global Accessibility Awareness Day is celebrated across the world on May 3 every year. The objective of the event is to get everyone talking, thinking and learning about digital access/inclusion and people with different disabilities.</p>
<p style="text-align: justify;">This year the Global Accessibility Awareness Day 2017 (GAAD 2017) organized by Prakat Solutions and co-hosted by CIS and Mitra Jyoti, was held on May 18 at NIMHANS Convention Centre in Bengaluru. The event was designed to raise awareness around digital accessibility issues for persons with disabilities. The Shuttleworth Foundation also supported this event. Approximately 250 people were in attendance. The URL for the event is <a href="http://gaad.in/">here</a>. A detailed agenda can be found <a href="http://gaad.in/Agenda.html">here</a>. Video recordings of the event will be made available shortly.</p>
<p style="text-align: justify;">The event ran from 2:30-7:30 PM and featured various discussions and events, including dance ceremonies, skits, and talks by various figures.</p>
<p style="text-align: justify;">The first event was an extended presentation on coding for accessibility by Nawaz Khan of PayPal, in which he discussed how developers can integrate accessibility principles into their software from the design phase, and how persons with disabilities can productively make their issues known to developers. He encouraged developers to adopt international standards such as WAI-ARIA, and also encouraged developers to use accessible open source libraries and testing tools. He took questions about standards for other types of disabilities beyond visual impairment, joining the global conversation around accessibility standards, and accessibility design for mobile platforms.</p>
<p style="text-align: justify;">The main event was a panel on the awareness of accessibility issues in India and how they could be improved, both in the public and private spheres. In attendance were Abhik Biswas of Prakat Solutions, Pranay Gadodia of Deutsche Bank HR, Shalini Subramaniam of PayPal, Balachandra Shetty of Intuit, Sandeep Sabat of ZingUp Life, Kameshwari from Wipro, Mahabala Shetty from NIC, and Srinivasu from Informatica. The panel was moderated by Giri Prakash of Hindu Business Line. They discussed issues including how to promote a stronger government response to accessibility issues, initiatives that can be taken from the private or civil society sector in order to address accessibility issues, the lack of awareness around accessibility in the Indian context, and the responsibilities that developers have to make accessible apps and products. Shalini from PayPal talked about the potential for government initiatives such as Make in India could be used to further the availability of accessible consumer products and services in India.</p>
<p style="text-align: justify;">The second speaker, Kameshwari Visarapu from Wipro, talked about how persons with disabilities need to make their voices heard in society. She stressed that, while the laws are already in place, people do not demand their rights. Without this, the government and any community, even those with the necessary power, would not be able to make the changes. Mahabala Shetty from NIC pointed out that NIC is responsible for developing and updating various government websites. He said he understood that the inaccessibility of government websites and services is a serious problem, and pledged to make sure that all websites would be made accessible in the coming months.</p>
<p style="text-align: justify;">The fifth speaker was Sandeep Sabat of ZingUp Life, also a health tech company, which seeks to help people with issues not just around physical health, but also emotional, mental and spiritual health. He drew a comparison with the beginning of the mobile revolution, when people would say that web on mobile is a small, niche space, which eventually gave way to the idea of mobile-first design. Extending this analogy, he said that design must now be accessibility-first, in order to ensure that it becomes part of the culture of product development.</p>
<p style="text-align: justify;">The sixth speaker at the event was Balachandra Shetty from Intuit. He pointed out that design principles needed to make a product accessible and making that product easy to use for the general public are the same, and that improving the user experience for 20% of the population effectively improves it for everyone.</p>
<p style="text-align: justify;">The seventh speaker was Pranay Gadodia from Deutsche Bank HR, who argued that accessibility was important not just for persons with disabilities, but for everyone. He gave the example of ramps on public entrances, which make access easier for everyone. He demonstrated the use of a screen reader and tried to order food through Swiggy. When he found that the app was inaccessible, he pointed out that they had just lost a customer.</p>
<p style="text-align: justify;">The eighth speaker, Srinivasu from Informatica, talked about his work in the accessibility space for various NGOs and companies. He argued that inaccessibility was never built into a product by design, and that any problems were the result of ignorance. He also said that accessibility work was the only career with two major benefits – that of creating an immediate impact among the community and being the kind of work that not only takes advantage of a business opportunity but also directly benefits consumers.</p>
<p style="text-align: justify;">The ninth speaker, Abhik Biswas, said that he believes that accessibility is a nonissue, because if everyone wrote good code and followed best practices, all products would be accessible anyway. He said this was not always the case with software tools. He gave the example of work that Prakat did with a provider of legal software. In large corporate lawsuits, parties would usually share terabytes of data with each other, and legal e-discovery software is used to discover patterns for evidence. An inaccessible document would be useless to such software so, of course accessibility isn’t an issue only for a certain set of people. If you’re in the innovation space and trying to solve problems, he stressed, then accessibility is an issue.</p>
<p style="text-align: justify;">The moderator then raised the issue of the lack of progress for persons with disabilities in the past five years. He asked what progress has been made in the legal area, and whether there are any solutions that users can come up with themselves rather than waiting for government action. Shalini pointed out the inaccessibility of the Swiggy app, and added that there are automated accessibility checkers for apps, both Apple and Android. She demonstrated this for the audience.</p>
<p style="text-align: justify;">Kameshwari said that part of the problem is that a single person may not be able or willing to make much noise. There are a lot of communities that have been formed on a corporate/state/national level, but collectively making noise is important for major changes. One process that her own company tried was creating a repository of pre-tested accessible components, which has two advantages; the developer can pick the component from a standardized repository, and the component would have been pre-tested for accessibility and responsiveness. This is another possible solution – which people collectively come up with standardized repositories of accessible components.</p>
<p style="text-align: justify;">She then gave the example of an accessible garden in Kerala, where persons with disabilities could visit and touch different types of plants in a guided experience to help them identify and understand them. When talking about inclusivity, she asked, why create a separate garden? Integrate these features into all gardens instead, she suggested.</p>
<p style="text-align: justify;">The third speaker said that the government drains enthusiasm from people, and insisted that it could only play the role of a facilitator. The need is to inspire the necessary passion in people to carry forward the issues themselves.</p>
<p style="text-align: justify;">Sandeep said that the intent is already there, but the government was not capable of doing it alone. The social fabric of the country needs to change, along with the attitude of the society. To that end, they suggested making accessibility a non-issue, and looking for opportunities to integrate it into society at large. Instead of thinking of it through a usability standpoint, consider how to improve the overall user experience of a product through the lens of a user with disabilities.</p>
<p style="text-align: justify;">Balachandra pointed out that while love is a strong emotion, fear too is very powerful. The laws in the Commonwealth are much stricter than those in the US, he pointed out, and yet apps built in those countries are far more accessible than those in Indonesia, India etc. So, he suggested that if a product proved to be inaccessible to a certain segment of the population, the employees responsible could face down the CEO, and fear would drive them to make their products accessible. In addition, he called for stricter laws and a possible amendment of the IT Act, drawing upon laws in the Commonwealth and France. Disability discrimination in the US carries a high penalty, and suggested that similar laws would enforce accessibility in local products.</p>
<p style="text-align: justify;">The moderator asked Pranay: is it possible for app developers or mobile platform providers to make accessibility mandatory for apps that are publicly released? He answered that as a tech developer he might not be the right person to answer that, however, he know that the iOS framework is much more stringent than Android in this regard. He called on users with disabilities to call out inaccessible design wherever they saw it, in order to inform developers and to create a healthy competition to make companies disability-inclusive. He also pointed out that many corporations hold events or draft policy for persons with disabilities without involving them in the decision-making process, and that this needed to change.</p>
<p style="text-align: justify;">Srinivasu stressed that the job of making government services accessible fell on the developers within the government, who are in-house, or the vendors, who work for NIC. There are two things the government can do, he said; when asking for a vendor, they could refuse those who make inaccessible products, thus making accessibility a requirement for procurement.</p>
<p style="text-align: justify;">The second is to raise accessibility issues at the level of education. He gave the example of several apps like TaxiForSure and Cleartrip, all of which responded to accessibility issues raised by their users. He stressed that any user could give feedback, and not just those with disabilities, and that raising awareness is a duty for everyone. He asked the audience to share the event on WhatsApp, and to type with their non-dominant hand, as a simple way of understanding disability. The other exercise he called on the audience to do is to write a post about the event on Facebook or their blogs using only the keyboard, without touching their mouse. In this way, he drew attention to thinking about accessibility whenever one uses a website or software.</p>
<p style="text-align: justify;">Abhik took the opportunity to add one more dimension, an area of concern for app developers in India in particular – that of linguistic accessibility. Most apps, he pointed out, are being developed in English only, and most government apps have the additional burden of considering vernacular languages, while NVDA only supports 10-12. The government can’t solve this problem by making multilingual websites, as developers also need to contribute to projects like NVDA in order to build support for other languages. Accessibility, he stressed, wasn’t anyone’s problem, but everyone’s problem.</p>
<p style="text-align: justify;">After this, Shekhar Naik, former captain of the Indian blind cricket team, talked about his life story. He mentioned that there are over 5c0k blind cricketers in the country. He talked about his passion for cricket, how it brought him to where he was today, and thanked the government for its increased recognition and felicitation of persons with disabilities.</p>
<p style="text-align: justify;">After that, the owner of Pothole Raja, Pratap Bhimasena Rao, spoke about the importance of the accessibility of built environments such as roads. He pointed out that 25% of vehicular accidents cause a disability, and stressed the need to address these issues to promote not just accessibility, but prevent disability.</p>
<p style="text-align: justify;">After this, Amit Balakrishna Joshi from the state government gave a brief overview of the Karnataka government’s accessibility and e-governance initiatives. He spoke about the Karnataka Mobile One app, an initiative to consolidate and digitize several state government services. As the world’s largest Mobile One platform, it would integrate about 40 departments, with the objective of bringing equality in service delivery across socioeconomic, linguistic and literacy divides.</p>
<p style="text-align: justify;">At 7:00, Sean Murphy from Cisco gave a talk on universal design principles. He discussed how universal design is important to maximize market access, ensuring that a company reaches 100% of its market. In Cisco, accessibility is integrated into the product lifecycle right from the design phase to testing to rollout.</p>
<p style="text-align: justify;">He also discussed regulatory standards such as Section 508 in the US, which he stressed were critical to securing industry-wide accessibility. The event ended at 7:30 p.m.<br /><br /></p>
<p style="text-align: justify;"><strong>Images:</strong></p>
<p style="text-align: justify;"><img src="http://editors.cis-india.org/copy_of_SRID6275.JPG/image_preview" alt="GAAD lamplighting" class="image-inline image-inline" title="GAAD lamplighting" /></p>
<p style="text-align: justify;"><strong>Participants light the lamp to commemorate the start of GAAD 2017.</strong></p>
<p style="text-align: justify;"><strong><br /></strong></p>
<p style="text-align: justify;"><strong><img src="http://editors.cis-india.org/copy_of_SRID6299.JPG/image_preview" alt="GAAD Abhik Biswas" class="image-inline image-inline" title="GAAD Abhik Biswas" /><br /></strong></p>
<p style="text-align: justify;"><strong>Prakat Solutions co-founder Abhik Biswas speaks at GAAD 2017.</strong></p>
<p style="text-align: justify;"><strong><img src="http://editors.cis-india.org/SRID6557.JPG/image_preview" alt="GAAD 2017 panel" class="image-inline image-inline" title="GAAD 2017 panel" /><br /></strong></p>
<p style="text-align: justify;"><strong>Panelists discuss accessibility challenges in India.</strong></p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/report-gaad-2017'>http://editors.cis-india.org/accessibility/blog/report-gaad-2017</a>
</p>
No publishernirmitaAccountability2017-06-19T15:07:28ZBlog EntryComments on the draft Policy on IT Accessibility for People with Disabilities
http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-policy-on-it-accessibility-for-people-with-disabilities
<b>The Centre for Internet & Society gave inputs on a document on implementing digital accessibility to Ministry of Electronics and Information Technology on May 2, 2017. </b>
<p style="text-align: justify; ">We welcome the initiative of the MEITY to formulate a policy/ set of guidelines to implement electronic accessibility for persons with disabilities within the government and provide our comments to the draft document below:</p>
<h3 style="text-align: justify; ">Accessibility of the document:</h3>
<p style="text-align: justify; ">The present document is not completely accessible. The first two Annexures cannot be read at all using a screen reader and there is also scope for improving accessibility in the rest of the document. Given the government’s policy requiring electronic accessibility and the nature of this document itself, this error may be rectified immediately. A good resource for creating accessible electronic documents is available at <a class="external-link" href="https://help.rnib.org.uk/help/daily-living/technology/accessible-documents">https://help.rnib.org.uk/help/daily-living/technology/accessible-documents</a></p>
<h3 style="text-align: justify; ">Title and content presentation:<span style="text-decoration: underline;"></span></h3>
<p style="text-align: justify; ">The present title reads- ‘Policy for IT Accessibility for people with disabilities”. This may be rephrased to - Policy for Implementing IT accessibility for persons with disabilities so that its purpose is clear and differentiated from the National Policy on Universal Electronics Accessibility. The policy may be broadly divided into four main aspects- Content and communication, technology, training and procurement, since these are the four areas where specific interventions are required and have different needs and associated standards.</p>
<h3 style="text-align: justify; ">Preliminary sections:</h3>
<p style="text-align: justify; ">The policy would benefit from clearly articulated vision, objectives, scope, applicability and statement.</p>
<h3 style="text-align: justify; ">Content and communication:</h3>
<p style="text-align: justify; ">All communication, including documents and publications, whether print or electronic, should be universally accessible. This could include documents, mails, invoices, leaflets etc. We recommend use of Unicode, EPUB 3, EPUB 3 Accessibility Guidelines and WCAG 2.0 (level AA) as the standards to be followed while creating and publishing electronic documents and information. The need to use Unicode for regional languages is especially emphasised, as also the need to provide alternatives in case of scanned notifications and documents. We would also like to stress the need to use alternate modes of communication for transactions such as Alternative mode of authentication other than visual captcha (IE: One time password (OTP), logical reasoning (2+2) etc.)</p>
<h3 style="text-align: justify; ">Accessibility of technologies:</h3>
<p style="text-align: justify; ">ICT accessibility interventions for different disabilities- This section should be circulated to experts of different disabilities to get their inputs. Attention may be given to also providing technology options such as the screen reader NVDA which are open source, efficient and work with indian languages. Overall, it is recommended that this section, recognises that persons with disabilities be provided with suitable assistive technologies and accessible technologies to enable them to work efficiently. The illustrative list of disabilitywise technologies may be provided as annexures to the policy/ guidelines and not be part of the main document.</p>
<p style="text-align: justify; "><a class="external-link" href="http://cis-india.org/accessibility/files/expert-comments-on-cdac-document.pdf">Click to read the full submission here</a>; and see the Policy and Guidelines <a class="external-link" href="http://cis-india.org/accessibility/files/policy-and-guidelines.pdf">here</a></p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-policy-on-it-accessibility-for-people-with-disabilities'>http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-policy-on-it-accessibility-for-people-with-disabilities</a>
</p>
No publishernirmitaAccessibility2017-05-19T15:33:41ZBlog EntryMobile Accessibility Practices
http://editors.cis-india.org/accessibility/blog/mobile-accessibility-practices
<b>Over the past few months the Centre for Internet & Society along with some like minded organizations had been working on framing a feasible accessibility guidelines for mobile apps which they could recommend to the Government of India, since there is no single standard in existence at the moment. </b>
<h3>Problem Statement</h3>
<p style="text-align: justify; ">The shift to digital governance and availability of assistive technologies have been both empowering as well as frustrating for persons with disabilities, who comprise approximately 150 million of the Indian population. Government initiatives such as the Digital India campaign are increasingly delivering basic functions of governance through information technologies. In the past year, the government, private sector and the world at large have embraced mobile applications as a preferred medium for user interactions and transactions.</p>
<p style="text-align: justify; ">The Mobile Seva App Store hosts 790 government apps, which provide services including voter information, agricultural assistance, welfare scheme signups, and educational content provision. In addition, the overall app market in India has also grown rapidly, with almost 5 times as many apps downloaded in 2015 compared to the previous year. These include apps which let users access everyday services like transportation, communication and entertainment.</p>
<p style="text-align: justify; ">However, for persons with disabilities, many of these apps, and consequently the services they provide, are inaccessible and often impossible to use. Research in the past year that looked at several apps, both government and private, found that a majority of the apps are inaccessible and unusable, especially for persons with low vision and blindness.</p>
<hr />
<p><a class="external-link" href="http://cis-india.org/accessibility/files/mobile-accessibility-practices.pdf"><b>Read the full submission</b></a></p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/mobile-accessibility-practices'>http://editors.cis-india.org/accessibility/blog/mobile-accessibility-practices</a>
</p>
No publishernirmitaAccessibility2017-04-12T13:48:13ZBlog EntryComments on the draft Rights of Persons with Disabilities Rules
http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-rights-of-persons-with-disabilities-rules
<b>The Centre for Internet & Society (CIS) submitted comments on the draft Rights of Persons with Disabilities Rules for the consideration of the Department of Empowerment of Persons with Disabilities, Government of India. </b>
<p>The comments were submitted to the Department of Empowerment of Persons with Disabilities on March 23, 2017. <a class="external-link" href="http://cis-india.org/accessibility/files/comments-on-draft-rights-persons-disabilities.pdf">Click to download the submission here</a>.</p>
<hr />
<h2 style="text-align: justify; ">Introduction</h2>
<p style="text-align: justify; ">We thank the Department of Empowerment of Persons with Disabilities (DEPD) for inviting comments on its draft rules. We provide brief comments on the Rules below. We would particularly like to draw the department’s attention to the need to have rules concerning measures relating to standards compliance, training and monitoring which we feel would help strengthen the Rules to address the issue of accessibility in a timely and effective manner.</p>
<h2 style="text-align: justify; ">Accessibility of the draft rules document</h2>
<p style="text-align: justify; ">At the outset, we would like to draw attention to the fact that the Rules when first published in PDF form were only partially accessible and not easily readable for persons using screen readers. We appreciate that at a later date, an accessible Word version was provided, however we feel that even the original PDF needs to conform to the <a href="https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html">PDF/UA</a><a href="https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html"> </a>standards.</p>
<h2 style="text-align: justify; ">Policy/Guidelines on accessible communication</h2>
<p style="text-align: justify; ">Following from the above point, we would like to propose that the DEPD publish at the earliest a set of guidelines for publishing accessible information and communication. The guidelines may define what constitutes information, explain how to create and disseminate accessible information and identify relevant accessibility standards. They may be applicable to all cases where printed or electronic information such as books, leaflets/ handbooks, mails, invoices, forms, data, policies and acts are created and communicated to diverse stakeholders. This guidelines may be mandatory across the Central and State Governments.</p>
<h2 style="text-align: justify; ">Reasonable Accommodation</h2>
<p style="text-align: justify; ">Rule 3(1) requires that every establishment take steps to provide reasonable accommodation. It may further be added that said measures towards reasonable accommodation be taken within a reasonable time frame, such that persons with disabilities are provided access to resources at the same time as others and not significantly later.</p>
<h2 style="text-align: justify; ">Standards and Guidelines</h2>
<ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">Standards are critical to implement accessibility, and it is important that we adopt the most updated globally recognised standards. To aid this endeavour, we recommend that the DEPD may appoint two experts who will primarily be responsible for implementing accessibility. Their tasks will involve identifying standards and policy requirements in different domains and coordinating with the relevant ministries to notify and implement the same. One expert may be responsible for environmental accessibility, while the other may be responsible for overseeing ICT accessibility. The experts may carry out the tasks of formulating strategies to implement accessibility compliance, as well as researching advances in international policies and standards and making recommendations to relevant Ministries.</p>
<ol style="text-align: justify; "> </ol> <ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">Regarding the Rules relating to the notification of standards for ICT accessibility (Rule 17.c.), we recommend that these may be expanded and made more comprehensive. To our understanding, some of the standards mentioned in relation to ICT accessibility such as telecasting and broadcasting do not as yet address the issue of accessibility. We recommend that the relevant ministries notify standards and guidelines to be followed in their regard at the earliest. There are also critical domains such as procurement, telecommunications and mobile devices, services and applications and emergency and disaster response for which standards and guidelines need to be notified.</p>
<ol style="text-align: justify; "> </ol> <ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">We propose that the deadline for notification of standards be set within 6 months of the Rules coming into force and that the standards to be adopted are those which are globally followed, such as EN 301-549 for procurement.</p>
<ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">Past efforts have proven that the notification of guidelines alone does not necessarily result in the implementation of accessibility, and often times a web site or platform which has been made accessible, reverts to being inaccessible as time elapses and persons who are involved in updating it and maintaining are unaware of accessibility principles to be followed. Hence, each and every person developing, maintaining and updating a website should be familiar with accessibility core principles. Outsourcing accessibility compliance is a temporary solution, it will be rendered pointless as people continue to update the website and post new content that is inaccessible. Therefore, some level of training is an absolute necessity, although the specific level and nature of these trainings may vary based on the individual’s role in relation to the website. For example, a web developer would need more in depth training as compared to a communications or administrative officer whose role may be to upload documents to the web site. Creating accessible documents and communicating in an accessible manner is something which every government official should be able to do, while the needs of developers are more advanced and technical and may require two rounds of training. Each ministry and department at the Centre and state may allocate a certain portion of their budget towards this.</p>
<ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">An Accessibility specialisation unit may also be constituted within the NIC or any other appropriate agency whose task will be especially to provide on-going practical support to government agencies on how to implement accessibility across their web sites and publications. This team may work closely with the DEPD and other government agencies to audit, trouble shoot and guide continuous progress in implementing web site accessibility across the government.</p>
<ol style="text-align: justify; "> </ol>
<p style="text-align: justify; ">All Ministries and government agencies may be required to include a section on accessibility compliance and initiatives as part of their annual reporting. This report may also include their performance on expenditure relating to implementing accessibility, hiring employees with disabilities, trainings undertaken and affirmative action required to be taken by them as given in the RPWD Act 2016, such as steps towards incentivising affirmative action by the private sector and activities undertaken relating to Chapter VI, Chapter VII and Chapter VIII of the RPWD Act.</p>
<ol style="text-align: justify; "> </ol>
<h2 style="text-align: justify; ">Training and Support</h2>
<h3 style="text-align: justify; ">Monitoring and reporting</h3>
<p style="text-align: justify; ">Regarding website accessibility, the DEPD may also consider taking up auditing web sites of government agencies at random from time to time and publish the reports periodically as a measure towards gauging progress. A comprehensive audit of all government web sites of both the Central and state government and applications may be undertaken every 3 years.</p>
<h2 style="text-align: justify; ">National fund</h2>
<p style="text-align: justify; ">Rule 43, relating to the Utilization of the National Fund is not clear on how much money is spent on accessibility initiatives each year. It is proposed that this rule specify the percentage of funds which have to be required to be utilised each year. In the absence of this, there is a concern that the fund will be under utilised, despite there being a large need for spending on accessibility. Details of projects and spending may be published from time to time.</p>
<h2 style="text-align: justify; ">Office of the Chief Commissioner</h2>
<p style="text-align: justify; ">The DEPD may require that at least one person of senior rank within the Office of the Chief Commissioner for Persons with Disabilities be a person with disability. This will ensure that the interests of the concerned group are directly represented at the highest level dedicated to ensuring their welfare and participation.</p>
<h2 style="text-align: justify; ">Transparency</h2>
<p style="text-align: justify; ">Finally we recommend that the rules emphasise the need for transparency in implementing the provisions of the Act and that all initiatives, programmes and expenditure may be published in a timely and accessible manner.</p>
<p>
For more details visit <a href='http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-rights-of-persons-with-disabilities-rules'>http://editors.cis-india.org/accessibility/blog/comments-on-the-draft-rights-of-persons-with-disabilities-rules</a>
</p>
No publishernirmitaAccessibility2017-03-29T03:41:25ZBlog EntryComments on Department of Empowerment of Persons with Disabilities 'Vision Document 2030'
http://editors.cis-india.org/accessibility/blog/comments-on-depds-vision-document-2030
<b>The Centre for Internet & Society (CIS) submitted comments for the consideration of the Department of Empowerment of Persons with Disabilities (DEPD) on the Vision Document 2030 brought out earlier this month.</b>
<p style="text-align: justify; ">We appreciate the efforts by the Department of Empowerment of Persons with Disabilities (DEPD) to put together a vision and strategy document to inform and direct the implementation of the new Rights of Persons with Disabilities Act, 2016 (RPWD), and give effect to the rights of persons with disabilities as enshrined in various international treaties.</p>
<p style="text-align: justify; ">Overall, we recommend that the vision articulate more clearly in terms of quantifiable targets what it seeks to achieve at different points of time and that these targets, while taking into account the realistic situation in our country, are not so minimally set as to undermine the aims of the Act and the national commitments outlined therein.</p>
<p style="text-align: justify; ">We submit that it be kept in mind that this is not the first time that a national conversation has taken place around accessibility and standards, and that many previous attempts such as the Guidelines on Indian Government Websites (GIGW) have been in existence for nearly 8 years.</p>
<p style="text-align: justify; ">Therefore, we submit that the steps taken towards implementing this act should be more ambitious, and should seek to resolve the issue within the next 2-3 years. Accordingly please find our brief comments below:</p>
<h3 style="text-align: justify; ">Background</h3>
<ol>
<li style="text-align: justify; ">Section 2(i) is as follows: Vision: ‘To build an inclusive society in which equal opportunities are provided for the growth and development of Persons with Disabilities so that they can lead productive, safe and dignified lives.’ We propose the addition of the word ‘integration/inclusion/assimilation’ as in the phrase ‘growth, integration and development’, since that implies social acceptance, which is crucial. We also propose the addition of one more sentence as follows: ‘To enable access to technology and technology enabled resources for every person with a disability to facilitate effective communication and integration in society, as well as to ensure that accessibility considerations and standards are included across the board in all government programmes and initiatives.’</li>
<li style="text-align: justify; ">We propose in 3(a) - the inclusion of the word technologies in the phrase ‘providing appropriate aids and appliances.’ This is important since aids and appliances are not always technology-based and often times a new technology may be suitable, efficient and contemporary to address a specific need.</li>
<li>We propose in 3(b) - the inclusion of the word accessibility in the phrase ‘developing rehabilitation professionals/personnel.’</li>
</ol>
<h3 style="text-align: justify; ">Long Term Vision by 2030</h3>
<ol>
<li style="text-align: justify; ">Inclusion of curriculum related to e-accessibility such as knowledge of the Web Content Accessibility Guidelines (WCAG) and universal design principles in all institutes and institutions teaching courses in engineering, computer science, IT etc.</li>
<li>Inclusion of disability-related issues in the curriculum of university courses in other fields as well, such as law, sociology, economics, and architecture. </li>
<li style="text-align: justify; ">Creation of a mechanism to gather more comprehensive and accurate data on persons with disabilities, such as their levels of access to technologies, information and basic resources and amenities.</li>
<li style="text-align: justify; ">Provision of training to use computers for students and children with disabilities in rural areas and provide training to students receiving aids and appliances as part of schemes. In addition, the Government should also focus on providing appropriate training and access to appropriate content in order to make full use of these technologies.</li>
<p style="text-align: justify; "><br /><b>Seven Years' Strategy</b></p>
<li style="text-align: justify; ">The point about making documents, buildings, websites, documents etc. accessible under the Accessible India campaign <a href="#fn1" name="fr1">[1]</a> is appreciated; however, it should be accompanied with a mechanism for transparency and accountability. This should include periodic reports giving updates on the details of websites, documents, etc. taken up for retrofitting. At the moment, this information is not available on any of the public domain web sites such as the Accessible India campaign URLs, and repeated RTIs have failed to make this information available. Hence, there is no clarity on what the exact number of URLs and documents which have been made accessible so far is. Without accountability built into this procedure moving forward, there is very little to ensure that it happens.</li>
</ol>
<h3>Three Years Strategy</h3>
<ol>
<li style="text-align: justify; ">Review of legislations for persons with disabilities : we propose that a time line be set for this, say within 6 months and a list of existing and new policy/ legislation requiring interventions/ formulation be drawn up for action. Priority tasks could be to take up accessible procurement, accessibility of mobile applications, web sites and electronic documents.</li>
<li style="text-align: justify; ">One of the foremost tasks should be to identify and notify appropriate standards for different domains of accessibility such as procurement, electronic documents, television and so on, as well as reaffirm/ update any existing standards already recognized by the Government so that the process of retrofitting existing resources, as well as building new accessible ones commences at the earliest.</li>
<li style="text-align: justify; ">It is recommended that the Government of India put together an advisory committee of subject matter experts from NGOs and other civil society bodies who can advise on initiatives to be taken for environmental and information accessibility.</li>
<li style="text-align: justify; ">Regarding the plan for making 50% of all government web sites and documents accessible<a href="#fn2" name="fr2">[2] </a>, this target needs to be revised. The Accessible India campaign, which lists the same target in its strategy document,<a href="#fn3" name="fr3">[3] </a>has already been underway for the past one and a half years, and we hope that this target would have already been achieved under those efforts. Hence, if the Government sets a target of 50% over the next three years, this implies either that work has not been taking place thus far, or that very little will be done over that period of time. Furthermore, the RPWD Act requires all service providers to make their services accessible within 2 years of notification of regulation by the Central Government<a href="#fn4" name="fr4">[4]</a>, hence the time stipulated under the Act is much lesser than the vision is providing for and should be amended to making all web sites and documents accessible within 2 years. It may further be noted that the GIGW had been notified since 2009 and despite being in place for eight years, there is currently no official information on how many websites been made fully compliant with these standards. Therefore, we submit that a strict approach with regard to any deadlines and regulatory measures are necessary.</li>
<li style="text-align: justify; ">It is respectfully submitted that the number of 500 language interpreters<a href="#fn5" name="fr5">[5] </a> is simply not enough. This would work out to approximately 15 interpreters per state in 3 years, a number that we consider far too low for the time allotted. We submit instead that it is urgent that an attempt be made to train at least 30 people per state/UT per year, which would work out to 90 interpreters per state/UT over the 3-year period.</li>
<li style="text-align: justify; ">It is crucial the DEPD try to work with the Digital India campaign and the Smart Cities Mission to ensure that upcoming smart cities are born accessible. To this end, there needs to be specific measures to ensure that accessibility standards are part of the Terms of Reference and contracts for smart cities and that there is sufficient guidance and accountability for this.</li>
</ol><ol> </ol>
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<p>[<a href="#fr1" name="fn1">1</a>]. Section C.6</p>
<p style="text-align: justify; ">[<a href="#fr2" name="fn2">2</a>]. Section D.6</p>
<p>[<a href="#fr3" name="fn3">3</a>]. http://www.disabilityaffairs.gov.in/upload/uploadfiles/files/Accessible%20India%20Campaign_Brochure.pdf</p>
<p>[<a href="#fr4" name="fn4">4</a>]. Chapter VIII, Section 46</p>
<p>[<a href="#fr5" name="fn5">5</a>]. Section D.7</p>
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For more details visit <a href='http://editors.cis-india.org/accessibility/blog/comments-on-depds-vision-document-2030'>http://editors.cis-india.org/accessibility/blog/comments-on-depds-vision-document-2030</a>
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No publishernirmitaAccessibility2017-02-28T15:58:55ZBlog Entry