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Response from the Royal National Institute for the Blind (United Kingdom), to the European Commission Green Paper on Public Sector Information in the Information Society


The Royal National Institute for the Blind (RNIB) is the largest organisation in the UK working with and on behalf of blind and partially sighted people. We work to influence the development of public policy at local, national and European levels in the interests of visually impaired people. RNIB is a leading member of the European Blind Union (EBU), which is the only pan-European organisation representing the interests of blind and partially sighted people. There are 1.7 million blind and partially sighted people in Britain and 7.4 million in the EU. The age profile of the visually impaired population is biased towards the older age groups. With the increase in the number of elderly people in Europe, there will be an increase in the number of people with a visual impairment, who are particularly in need of accessible information from public sector sources as so many of them rely on publicly administrated benefits, health and social services, and public transport.

Through its campaigning and public information work on the supply of accessible information to visually impaired people, as in our “See It Right” campaign aimed at both the public and private sector, and our “Web Accessibility” research to make the Internet easier to use for visually impaired people, RNIB has a wealth of expertise on how information can be presented in accessible ways. RNIB is currently campaigning with visually impaired people on a broad range of issues including access to information about public utility services such as gas and electricity, and for information about public transport and the transport services themselves to be made more accessible.

The ability to have access to information from public sector bodies is a fundamental right of EU citizens, as a vital prerequisite for people to be able to exercise all their rights and have equal access to public services. However, huge difficulties are encountered by blind and partially sighted people across the EU when they try to access the same information as their fellow citizens. Information is often presented only in print form, with no alternatives such as larger print, audio cassette, computer diskette or braille being made available. RNIB therefore agrees with the Commission that much of the existing information produced by the public sector is accessible only in principle, not in practice, because too often the access needs of blind and partially sighted people are simply forgotten when public sector bodies produce information.

General comments

RNIB has many practical recommendations about ways in which this situation could be improved, in line with the need for better technical arrangements mentioned by the Commission. For example, public sector bodies can make arrangements for the presentation of existing information in alternative formats when people request this, in order to be able to “read” what the majority of the population would read from a standard size print copy of the information. Common “alternative formats” include audio cassette editions of print material, large print (such as 14 point or 16 point print), computer diskette copies of printed documents and braille.

The presentation of information in these kinds of alternative formats can often be a simple and straightforward process. For example, given that today most public sector documents are prepared on computers, the presentation of a document on a diskette or in a larger print font size does not cause serious difficulty. Similarly, the presentation of information material on audio cassette or in braille can be arranged without major difficulty, particularly when public sector bodies consult with relevant organisations working for visually impaired people on how best to provide audio and braille information.

All documents of direct interest to visually impaired people should automatically be produced in alternative formats. For example, public sector information on welfare benefits available to people with disabilities, or on employment assistance measures designed to enable disabled people to take a job, fall into this category. Other public sector documents should be presented in alternative formats on request. If this is not the case, blind and partially sighted people are excluded from information and consultation processes which any other citizen has the opportunity to take part in. This kind of social exclusion should not be allowed to continue as the EU strives to be a model for social inclusion.

There is little point in alternative formats being available if this is not advertised so that visually impaired people take up the opportunity of accessing the information. The possibility of receiving documents in alternative formats should therefore be advertised by public sector bodies, which can be done by a clear note to this effect on the document concerned, in public advertisements of information, and in general public notices about where citizens can ask for information from a government department, a local authority or other public sector body. This type of advertisement will reach many visually impaired people who have items of information read to them by another person, and could be further advertised by the routine placing of information about public documents and information centres in editions of “talking newspapers”, in editions of news services provided by organisations such as RNIB to visually impaired people and other such outlets.

As public servants employed at public expense, organisations in the public sector should set a precedent and an example of good practice in meeting the information needs of visually impaired citizens. This approach is in line with the UK Government’s Disability Discrimination Act’s “reasonable adjustment” philosophy. When Part III of the Disability Discrimination Act enters into legal force in October 1999, any person or organisation providing a service, including local and central government, will have to take reasonable steps to make their service usable by a visually impaired person. This will include for example providing information in braille or audio cassette if it is deemed necessary and reasonable for the organisation to do so. In some cases it may be that a free telephone number could provide certain information (such as public transport timetables) rather than transcribing all timetables into braille.

RNIB works with government departments to encourage alternative formats and has met with a good deal of success in this area. One good example of a UK public sector body already making a reasonable effort to include blind and partially sighted people, currently being actively supported and publicised by RNIB, is the welcome decision of the UK Home Office to produce an audio cassette version of its information leaflet on the new proportional representation system being used to elect British Members of the European Parliament this year. Similarly, RNIB has worked with the Department of Trade and Industry as it produced its recent booklet for its staff on accessible formats for public information (a copy of this booklet is enclosed). These are two practical examples of how the public sector can work with visually impaired people’s organisations on alternative formats. RNIB hopes that the EU will follow best practice of this kind when agreeing any future actions or legislation resulting from this Green Paper.

Specific comments

In response to some of the specific questions raised in the Green Paper, RNIB would like to make the following points:

To Question 1:

RNIB would recommend that a wide definition of the “public sector” is important, for example the “financial” approach, to include a broad range of public service and public sector bodies mainly financed by public funds, whose information is of interest to the general public. Regarding categories of public sector information to be used in the debate on the Green Paper, we would similarly support a broad ranging approach, for example including information that is relevant for the general public.

To Question 2:

The Disability Discrimination Act means that many visually impaired people in the UK will come to expect that alternative formats will be provided by public sector bodies to allow them to access information. This could create a barrier at European level when UK citizens ask for information from countries in the rest of the EU where this provision of alternative formats is not expected under their national laws. Therefore EU level legislation to make the supply of information in alternative formats the norm rather than the exception, with in addition measures to encourage good design of Internet sites for visually impaired users, would be a practical solution to overcome the differences in national requirements for alternative formats.

To Question 3:

The establishment of European meta-data could help Europe’s visually impaired citizens find their way around public sector information available throughout Europe, if the availability of alternative formats for this information is clearly advertised in such “meta-data” outlets.

To Question 4:

If higher prices are charged for visually impaired people to receive existing information in alternative formats, this is a form of discrimination and exclusion, particularly as many visually impaired people are unemployed or pensioners and unable to pay higher prices for public information. Therefore the standard price for a print copy of a public sector document should be calculated to take into account the costs of preparing alternative formats for visually impaired and other disabled users.

To Question 6:

Different copyright regimes within Europe do represent barriers for the exploitation of public sector information, since people requiring information in alternative formats from an EU country other than their own can face difficulties if the foreign country does not have copyright concessions for this kind of need. In 10 of the 15 Member States there is a lack of clear rules on copyright at present, for example on items which may carry a charge.

Again, people from a country with relatively good access and copyright rules for those needing an alternative format could face problems when asking for the same level of service from a public sector body in another Member State.

To Question 9:

RNIB does not consider that the current policies pursued by the EU institutions in the field of access and dissemination of information are adequate, therefore we warmly welcome the Commission’s initiative in presenting this Green Paper and urge that it be followed up by a drive across the EU institutions and the wider public sector in Europe to improve access by the provision of alternative formats for visually impaired and other disabled people.

To Question 10:

RNIB would look favourably on proposals resulting from this Green Paper for legislation, information exchange, awareness raising, demonstration and pilot projects and education & training projects, where these are aimed at improving access by the provision of alternative formats. Naturally, RNIB will be happy to cooperate and offer its advice to the Commission when any such actions are being prepared.


In the UK, the Disability Discrimination Act will be a major step forwards for visually impaired people to access the public sector information they need to live as full a life as their sighted fellow citizens. RNIB therefore urges that the EU agree a strong commitment in any actions resulting from the Green Paper for EU institutions and Member States to respect the rights and meet the information needs of visually impaired people in the public sector of the Information Society.

Not only will such a strong commitment be a major step towards social inclusion for the estimated 7.4 million visually impaired people in the EU, but it would also assist the social inclusion of older people in the EU’s ageing populations, many of whom have reduced sight as they grow older. In addition, good practice in making information accessible is good for all citizens, including people with or without disabilities.

In an era of increasingly open government, whether at national level (as in the UK with the upcoming Freedom of Information Bill) or at European level, the Information Society represents both a threat and an opportunity for visually impaired people. If not handled with attention to the information needs of visually impaired citizens, the development of Internet information services in the public sector and elsewhere could lead to greater social exclusion, with visually impaired people locked in the ranks of the “information poor” whilst the sighted population in general forms the “information rich”. Hence the importance of the public sector taking the advice of visually impaired people’s organisations on designing websites in accessible ways.

At the same time, the Information Society will still be a place where printed information and other media are important, as not everyone will be able or inclined to use Information Technology. Therefore the public sector should still be urged to provide alternative formats such as large print, audio cassette and braille.

In summary, RNIB believes that the EU’s drive for more transparency and openness can be strengthened by actions resulting from this Green Paper in line with our advice in the above response, to make sure that the EU institutions and the wider public sector across Europe lead by example in countering the social exclusion from information faced by millions of visually impaired citizens at present.

Encl. (With the paper copy sent by post) Copy of UK Department of Trade and Industry booklet “Read Me Again” produced in cooperation with RNIB, as a practical example of how RNIB is able to work successfully with the public sector to meet the access needs of visually impaired people for information.


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