"Disability is not something individuals have. What individuals have are impairments. They may be physical, sensory, neurological, psychiatric, intellectual or other impairments. Disability is the process which happens when one group of people create barriers by designing a world only for their way of living, taking no account of the impairments other people have."

This survey is one of the activities that the Office for Disability Issues has undertaken in order to report on actions taken by government agencies to implement the Disability Strategy. Objective 6 of the Strategy is to:

"Foster an aware and responsive public service: ensure that government agencies, publicly funded services and publicly accountable bodies (such as territorial authorities) are aware of and responsive to disabled people."

Three of the actions arising from this objective relate to the websites developed by such agencies:

6.3 Ensure that all government agencies treat disabled people with dignity and respect.

6.4 Improve the quality of information available, including where to go for more information, the services available and how to access them.

And, in particular:

6.5 Make all information and communication methods offered to the general public available in formats appropriate to the different needs of disabled people.

Therefore, the Disability Strategy requires government agencies to take into account the needs of people with disabilities when providing public-access information by means of a website. Some of these needs relate to how easily – or even whether – people can access the information.

In December 2003, a Cabinet Paper called The New Zealand Government Web Guidelines was presented to Cabinet. In its preamble, it states:

2 Many New Zealand Internet users have disabilities, or face particular circumstances, that limit their ability to access government websites. Often, this problem is exacerbated by the choices government agencies make about website design and technology without properly considering user needs. In most cases, agencies have technologies and design options available to them that would help avoid this problem.

3 The premise of this paper is that building websites that unnecessarily limit some peoples' access to government amounts to discrimination. In terms of the requirements of the Official Information Act 1982 and Human Rights Act 1993, and the relevance of core Public Service values, provision of government information and services via websites is no different from government in the physical world. Discriminating against people online is the same as doing so anywhere else. Government websites are public property - all New Zealanders using the Internet should be able to access them as of right, unless there are legitimate reasons to restrict access.

In response to this Cabinet Paper, Cabinet minute (03) 41/2B Government Web Standards mandated , as a standard for government websites, compliance with the E-government Web Guidelines version 2.1. These guidelines are discussed below.

Compliance with the guidelines is not, in itself, enough to ensure accessibility, although failure to comply with the guidelines makes it probable that a website, or parts of a website, are inaccessible to some audience members. It is therefore fair to use compliance as a proxy for accessibility (see Appendix 2: Our Methodology for a description of the steps). However, a site might be compliant and still present barriers to accessibility; the proof of the accessibility of a website is whether or not it can be used by people who face barriers in their daily experience of the Internet. Therefore, the focus of this survey is not on "does this website comply", but on "can the information in this website be accessed".

Throughout the report, we’ve included comments testers have made in their test reports. We hope this will give readers a sense of the current state of government agency websites; what people enjoy and what they dislike. We hope also to promote understanding of the frustration caused by poor accessibility, and the tremendous benefits that accessible sites offer to people like our testers. (Note that these comments relate only to the 56 sites that were tested in Phase 2.)

What is accessibility?

"Access keys link should be at the top of the page, not bottom. A screen reader user wouldn't know it was there unless [it is] close to the top, since we have to read the whole page to know what's there i.e. can't just glance and see it. A lot of links, are they all necessary? Feels slightly cluttered but very accessible. Lots of helpful verbal comments."

The e-government guidelines define accessibility as:

• providing online content that is accurate, timely and relevant.
• opening the door to government by removing impediments to online access.

In the wider internet community, the focus is on the second of these two bullet points. For a website to be accessible, the information and services it provides must be available to everyone, regardless of physical, sensory or cognitive user disabilities, work constraints or technological barriers.

Therefore, accessibility is measured by how barrier free the technology is. Accessibility problems are those that make it more difficult for those with disabilities, work constraints or technological barriers to use a website than for a person who does not have disabilities, constraints or barriers. Accessible websites ensure that:

• No member of the public is faced with a barrier to obtaining information and services that are available to the wider public audience
• Content is presented in a clear and simple manner, and it is easy to navigate within and between pages.

Note that these same measures also apply to Intranets, Virtual Private Networks and software applications – and the e-government guidelines recommend that agencies should apply the guidelines in the development of such resources in order to provide equal employment opportunities for all employees.

Who is affected?

"Site was one of the better ones, and was well laid out and colourful." Tester A
"It was horrible to use this site with ZoomText because of the colour scheme." Tester B

AccEase testers with different experiences of the same site

Accessibility affects far more people than those who identify as having a physical, sensory or cognitive impairment. In fact, most people who need accessible websites do not consider themselves "disabled".

The issue of accessibility affects those who:

• Are not able to see, hear or move easily or at all
• Have difficulty seeing text. In its simplest form this barrier applies to people who need reading glasses and find small text won’t enlarge on screen
• Have difficulty processing some types of information
• Have difficulty reading or comprehending text. Literacy statistics for New Zealand (quoted later in this report) suggest that this applies to around 50% of the working age population, as well as to people with specific learning, reading or cognitive impairments
• Do not have or are not able to use a keyboard or mouse
• Have a text-only screen or a small screen
• Have a slow Internet connection such as the dial-up connections in most Internet-connected homes, small businesses and community organisations. This applies even more so to those using dial-up connections in rural environments
• Are not fluent in the language in which the website is written
• Are in a situation where environmental factors interfere with their use of hands, eyes or ears, or where their hands, eyes or ears are busy
• Are using non-standard technology, including earlier or unusual versions of browsers or operating systems. This includes not only older technology but ensures future proofing for the increasing trend towards hand-held devices with access to the internet.

In research commissioned by Microsoft, Forrester Research (2003) found that 60% of working-age computer users in the United States could benefit from accessibility features;

38% (64.2 million) of working-age adults are likely to benefit from the use of accessible technology due to mild difficulties and impairments.

22% (37.2 million) of working-age adults are very likely to benefit from the use of accessible technology due to severe difficulties and impairments.

40% (67.6 million) of working-age adults are not likely to benefit due to no or minimal difficulties or impairments.

Similar research has not been conducted in New Zealand . However, 20% (743,800) of New Zealander adults identified in the 2001 Household Disability Survey as having a disability, very similar to the Forrester figure of 22%. Of this 20%, 65% (405,100) report some kind of physical disability involving some restriction of movement or loss of agility. Sensory disabilities, including loss of sight or hearing, affect 41% (256,300). Speaking, learning or remembering disabilities affect 39% (245,000), and another 5% (28,900) have an intellectual disability. Sixty percent of people have more than one disability.

As regards access to the Internet, New Zealand has a high uptake of technology, with around 65% reporting in the E-government 2004 Channel Surfing survey that they had used the Internet during the previous year. However, in December 2004, New Zealand ranked 22 nd in OECD countries for uptake of broadband (high-speed Internet access) technologies, with 4.7 broadband subscribers per 100 inhabitants. It follows that government departments should assume that as many as five out of six users will be accessing information via a modem connection.

Accessibility is related to usability, as both improve ease of website use. However, usability is aimed at ensuring that all website users have a happier experience of the website; accessibility is aimed at ensuring that one or more groups of users do not find it more difficult than others to use the site.

Government information accessibility standards

"A pain to have to scroll back and forth along the line. Text enlarged quite well. Contact vanished off the side with enlargement."

Government agencies are required to comply with two internet information accessibility standards:

• the New Zealand E-government Guidelines and
• the international Web Content Accessibility Guidelines (WCAG) version 1.0 (these international standards are mandated by the e-government guidelines, in clause 6.3.2).

Failure to comply with these guidelines means that disabled people are likely to be excluded from information on the site.

There are three levels of compliance. Failing to comply with all WCAG Priority 1 and e-government "must" requirements means that some audience members will find it impossible to access information. This level is mandatory. Failing to comply with all WCAG Priority 2 and e-government "should" requirements means that some audience members will find it very difficult to access information. This level is strongly recommended. Failing to comply with all WCAG Priority 3 and e-government "may" requirements means that some audience members will find it somewhat difficult to access information. This level is recommended where the site can comply cost-effectively.

E-gov Watch testing

"Supporting the text with visual information could aid accessibility to this site."

In 2003, 2004 and again this year, the State Services Commission commissioned a quality assessment of certain sites against the e-government guidelines and other criteria. This assessment covered required government content, useability, information delivery, e-services delivery, personalisation, cross-organisational integration, feedback and e-consultation, as well as accessibility. The methodology was based on sampling from the site, and provided weighted scores to produce a ranking for each category as well as an overall ranking. The testing is not, and does not claim to be, an accessibility audit, and it is by no means a comprehensive check of accessibility. Its focus is on assessment against the criteria, providing a score that can be used to benchmark the site against others as well as against its own progress, and providing useful feedback for site improvement. While useful to agencies that seek to continuously improve their sites, this process does not – and does not pretend to – offer an assurance that sites are accessible.

AccEase undertook the testing of accessibility-related criteria for E-gov Watch, the agency employed by the State Services Commission to provide this service.

Beyond compliance

"I felt confused and anxious when trying to find information. Not a user-friendly site. Site is okay visually, but navigating through it is frustrating."

Compliance – even with all three priority levels – does not necessarily mean that the site is accessible. For example: a coloured font may be quite legible at a large size and pass the colour contrast tests; however, if the same font is presented in a small size it may blend into the background and be lost to users. Small navigation buttons such as > may present difficulties for those with mobility impairments such as sufferers of Parkinson’s syndrome. Sites may be accessible to people who are blind, but totally inaccessible to people who have low vision; accessible to well-educated people with mobility impairments but inaccessible and frustrating to those with reading impairments.

The e-government guidelines recommend user testing, with accessibility-challenged testers. These are the 20% of users who are most likely to meet barriers when using a site. If the website works well for those who face barriers due to mobility, sensory or cognitive impairments of reasonable severity all of the time, then it will work well for the other 30–40% who face such barriers part of the time, as well as for the remainder of the population.

Universal design

"Lots of visual information which slows down navigation e.g. innercurve.gif (1062 bytes) corner.jpg (1481 bytes) Not necessary. For a good screenreader user this site is satisfactory, but less skilled users would be confused by the information described above."

In essence, the various guidelines promote the principles of universal design, though they seldom use this term.

Universal design is the design of products or environments to be usable by all people to the greatest extent possible without the need for adaptation or specialised design. For example, road crossings in most major cities use universal design principles, providing multiple feedback modes to indicate the presence of a crossing and whether or not it is safe for pedestrians to cross. Tactile surfaces indicate the edge of the footpath; sound and light signals indicate the time to wait and the time to move; but whether they are conscious of one signal or three, all pedestrians cross together.

For more about universal design, see Appendix 5: Principles of Universal Design.