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New Zealand Human Rights Commission Submissions |
Last Updated: 27 June 2015
NZ Government Web Standards
2012 Consultation Response Form
Submitted by:
Name (required): Bruce Coleman, Senior Policy Analyst.
Organisation (required): Human Rights Commission
Email (required): BruceC@hrc.co.nz
Phone (optional): 03 353 0952
Date (required): 21 February 2013
Note:
Or mail to:
Web Standards Consultation
Digital Engagement
Government Information
Services
Department of Internal Affairs
PO Box 805
Wellington
Consultation Question 1
Do you agree with focussing the Web Standards on accessibility in this way? If not, what other elements should be added to or removed from the Standards?
Answer 1
The Human Rights Commission (the Commission) is New Zealand’s National Human Rights Institution with functions under the Human Rights Act 1993, including commenting on draft policy and guidelines that may have an effect on human rights. The Commission is part of the monitoring mechanism set up by the Government to protect, promote, monitor and report on the implementation of the Convention on the Rights of Persons with Disabilities (CRPD)
In 2012 the Commission published Better Information for Everyone: Disabled People’s Rights in the Information Age. This publication informs the Commission’s response and is available from Better Information for Everyone // New Zealand Human Rights Commission
The Commission supports the proposed focus of the Web Standards exclusively on web accessibility. The Commission’s consultations indicate that many current critical features of government websites are not accessible and attempts to obtain alternative sources of information, or fulfil citizenship responsibilities are meet with variable responses.
Articles 9 and 21 of the CRPD provide that disabled people should have access to government services and information on the same basis as others. Focusing the Web Standards exclusively on web accessibility has the advantage that all initiatives such as training for staff, resources and common platforms will having a clear focus on access.
The Commission strongly recommends that the Web Standards also include standards for:
Article 2 of the CRPD requires the provision of reasonable accommodation where a service or facility is not currently provided to disabled people on the same basis as others. Reasonable accommodation is appropriate modifications or adjustments that are needed in a particular case to ensure a disabled person has the same access to services or facilities as others. For example, if an on-line form is currently not available in an accessible format it should be very clear from the website what the person can do in order to achieve the same end.
The provision of critical information and resources in NZSL and Easy Read is not currently part of the Government Web Standards and is not included in the International Web Content Accessibility Guidelines 2.0 (WCAG 2.0). The Commission understands that part of the current review of the Government Web Standards is to ensure that the “New Zealand layer” of the Web Standards meets the unique needs of the New Zealand public. The addition of clear standards for use of NZSL and Easy Read would substantially improve the accessibility of websites for Deaf people and other users of NZSL and people with intellectual/learning impairments.
Consultation Question 2
Do you agree with redefining “web page” this way? If not, how should website and web page be defined?
Answer 2
The Commission recommends that the definition of what is covered by the Government Web Standards be dictated by the services, facilities and information that are being offered rather than a technology-based definition. As is pointed out in the discussion document web technologies change relatively quickly. Any definition based on the current understanding of what constitutes a website, web page etc is likely to be quickly superseded. From the Commission’s point of view, all elements of the government web presence that provides services, facilities or information should be covered by the Web Standards.
Consultation Question 3
Do you agree with this reframing of the Web Standards’ scope of application? If not, what range of government web pages should be subject to the Web Standards?
Answer 3
The Commission strongly agrees that the Web Standards should apply to all web presences “produced, maintained or funded, in part or in whole, by Public Service departments”. It is not clear from the discussion document, but the Commission understands this to include all District Health Boards (funded by the Ministry of Health), schools (funded by the Ministry of Education) and all other Crown agencies (various funding sources). In the Canterbury context the Commission understands the Web Standards will apply to recently formed government agencies particularly the Canterbury Earthquake Recovery Authority and the Christchurch Central Development Unit.
The Commission does not agree that government department internal websites, such as intranets, should continue to be exempt from the Web Standards. Government departments have a clear responsibility to promote the employment of disabled people in the public sector (CRPD Article 27 (1) (g)). Monitoring reports published by the Commission clearly demonstrate that the public sector has not lived up to this obligation in recent times. See for instance Crown entities and the Good Employer Annual Report Review 2011 available at http://www.neon.org.nz/crownentitiesadvice/
Consultation Question 4
Do you agree with prioritising certain types of information for repair? Are there other ways to achieve this balancing of agency resources and delivering on accessible content and services?
Answer 4
The Commission recommends prioritising information and services that are potentially “high stakes”. Better information for everyone summarises consultations with disabled people undertaken in 2010 and 201. Those consultations identified high stakes information as the priority being available in fully accessible formats. High stakes information was further defined and examples were included:
The Commission is aware that some of these are the responsibility of agencies not currently covered by the Web Standards. Some will be covered if the expansion of coverage, recommended in Answer 3 is adopted. For others, the Commission recommends that the Government considers incentives to ensure that essential high stakes information is provided to all citizens equally.
Consultation Question 5
Do you agree with this classification of online information and services? What other types of information should be considered “critical”?
Answer 5
In addition, there are sections of websites that might not wholly meet the criteria for being critical but nonetheless because a major audience is likely to be disabled people should be fully accessible. For example the “special education” section of the Ministry of Education website. As part of the background research for Better Information for Everyone a user test was carried out on the “special education” web pages. They rated very poorly in both navigation and content features.
Other examples of web pages that might be expected to be fully accessible include the Office for Disability Issues and the Office for Senior Citizens sections of the Ministry of Social Development website and the Disability Support Services sections of the Ministry of Health website.
Consultation Question 6
Do you agree with the Web Standards implementation taking this phased approach? Are the proposed timeframes realistic?
Answer 6
Consultation Question 7
Do you agree with the Web Standards modifying certain WCAG 2.0 requirements to make accessibility more practical and achievable by agencies?
Answer 7
The Commission does not have the technical expertise to answer the questions 7-12 and neither is it within the Commission’s mandate to become involved in the technical aspects of website design.
The Commission notes, at paragraph 93 in the discussion document, that it is proposed that a Web Standards Working Group be re-established. The Commission would support this initiative particularly if the working group included sufficient representation from Disabled people and their organisations. The Commission recommends that a mechanism such as this is the appropriate forum for responding to technical questions in a timely and consultative manner.
Consultation Question 8
Do you agree with this modification to WCAG 2.0 Success Criterion 1.1.1? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 8
Consultation Question 9
Do you agree with this modification to WCAG 2.0 Success Criterion 1.2.1? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 9
Consultation Question 10
Do you agree with this modification to WCAG 2.0 Success Criterion 1.2.2? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 10
Consultation Question 11
Do you agree with this modification to WCAG 2.0 Success Criterion 1.2.3? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 11
Consultation Question 12
Do you agree with this modification to WCAG 2.0 Success Criterion 1.2.4? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 12
Consultation Question 13
Do you agree with this modification to WCAG 2.0 Success Criterion 1.2.5? If not, why not, and what other changes would you propose to balance the needs addressed by this requirement and the demands on agencies?
Answer 13
Consultation Question 14
Do you agree that Web Standards should focus on principles and outcomes that can be applied to the implementation of relevant technologies?
Answer 14
Consultation Question 15
Are there other issues with the Web Standards or limitations to accessibility that should be addressed?
Answer 15
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