INFORMATION AND COMMUNICATION TECHNOLOGY (“ICT”)
Accessibility Policy and Strategic Plan
- 1Report Objectives
This report, entitled, Information and Communication Technology (“ICT”) Accessibility Policy and Strategic Plan 2018 (“the Report”) is a proposed ICT Accessibility Policy which also includes a related Strategic Plan and Proposed revisions to existing legislation. It has been developed to assist the Ministry for Communications and Information Technology (MCIT) to consider an effective mix of policy, regulatory and institutional interventions that could assist in taking the already existent ICT accessibility measures in place in Sudan further, and augmenting them where necessary.
To support this objective, this report deals with accessibility in seven policy areas that are defined based on best practice identified in the ITU Model ICT Accessibility Policy Report and confirmed as relevant for Sudan through interviews with the Sudanese stakeholders. These priority areas are:
- Legal, Policy and Institutional measures;
- Accessibility of mobile devices and telecommunication services (‘mobile accessibility’);
- Web accessibility;
- Television accessibility;
- Accessibility of public access terminals and computers;
- Public procurement policies to promote accessibility; and
- Accessibility of emergency communications
- 2 Report Structure
The report starts by rooting the proposed policy in a Sudanese context by providing an overview of the status of ICT in Sudan and the prevalence and nature of disability in the country – this is in order to contextualize the challenges and opportunities presented by ICTs for persons with disabilities (Part 2). The report then goes on to discuss the policy, legal and institutional framework to support an ICT Accessibility Policy – this is discussed at international, regional and local levels (Part 3). In Part 4, the proposed ICT Accessibility Policy is set out and after discussion the policy’s goals, objectives and values, goes into the key foundational and supporting measures that need to be in place to support this policy. Part 5 discusses each of the identified, policy priority areas, which were canvassed in the consultation with the stakeholders listed in Annex 2 prior to the development of this policy, namely:
- Legal, Policy and Institutional measures;
- Accessibility of mobile devices and telecommunication services (‘mobile accessibility’);
- Web accessibility;
- Television accessibility;
- Accessibility of public access terminals and computers;
- Public procurement policies to promote accessibility
It should be noted that although accessible emergency services is an identified priority area, it is not dealt with on a standalone basis – it is addressed in the mobile accessibility and television accessibility sections of the report.
Each priority area discussed in Part 5 is discussed in terms of the context, scope and application, and objectives and measures for implementation. The support actions for the policy are found in Part 6, followed by evaluation and monitoring mechanisms (Part 7) and financing of the policy (Part 8).
Key annexures to support the implementation of this policy and strategic plan are
- Annex 1 – Acronyms and definitions
- Annex 2 – List of stakeholders consulted
- Annex 3 – Strategic Plan Overview
- Annex 4 – Proposed amendments of existing laws, by-laws and guidelines to support the policy proposals
- 1ICT in Sudan
Information and Communication Technologies (“ICTs”), such as mobile phones, public phones or the Internet, and broadcasting service are a critical infrastructure and services that expand access to key public services, promoting digital inclusion. Mobile cellular telephony is the most prevalent of ICTs in Sudan and mobile penetration is, according to the ITU, about 60%. Thirty-three percent (33%) of households have internet access; and 28 percent of individuals use the internet.Prevalence of Disability in Sudan
According to national census data (2008), 4.8% of the population in Sudan lives with a disability. This statistic is probably significantly understated for a number of reasons. Globally, according to the World Health Organization, approximately fifteen per cent (15%) of the world’s population lives with a disability. Thus, based on global trends, the Sudanese statistic is likely to be underestimated. In addition, the definition used of disability in the census was based on the International Classification of Impairments, Disabilities and Handicaps (ICIDH) and required that each respondent select one or more of a number of ‘disabilities’ namely: “limited use of legs”, “loss of legs”, “limited use of arms”, “loss of arms”, “difficulty in hearing”, “blind”, “difficulty in seeing”, “difficulty in speaking”, “mute”, “mental retardation”, “no disability” or “do not know”. This definition and the terminology used are outdated and not aligned with the new approach to the classification of disability using a social, rather than medical model. In 1999, the ICIDH was replaced by a new classification, the International Classification of Functioning, Disability and Health (ICF)Most persons with disabilities live in rural areas (66.7%), followed by urban areas (26.3%), and lastly the nomadic population (7%).
- The distribution of disability among males and females was very similar with 52.2% males and 47.8% females.
- Physical impairments (28.5% of the population with disabilities) had the highest prevalence, followed by intellectual impairments (24.18%), hearing impairments (5.76%) and visual impairments (4.98%). The remainder fell into the self-reported scale of ‘difficulties seeing’, ‘difficulties hearing’, or ‘difficulties speaking’.
- Children under 15 years old constituted 20.9% of the population of persons with disabilities. Amongst children, intellectual disability had the highest prevalence.
An understanding of the prevalence of disability in Sudan and of the above-mentioned trends are key in informing this ICT Accessibility policy given that a person's ability to use technology may be impaired due to various physical, sensory, emotional or cognitive disabilities.
In 2009, more recent data than the census data was obtained through research conducted by civil society and academiaChallenges faced by persons with disabilities
The joint MCIT/ITU consultation process which preceded the drafting of this policy urged Disabled Persons Organizations (DPOs) to identify challenges that currently exist in terms of ICT accessibility in Sudan. The challenges identified by persons with disabilities in Sudan echo the sentiments expressed by the disability community globally. Some of the challenges that impede ICT accessibility and prevent persons with disabilities from participating actively and on an equal basis in society include that in order to use ICT’s they may require:
- awareness of how and which ICT product and services and assistive technologies can be used to assist persons with disabilities. Even where there is no additional cost, and accessibility features are embedded in mobile handsets, tablets and computers operational systems already available to persons with disabilities, for example, awareness, training and education of both users and service providers are often required in order to break the accessibility barrier.
- access to end-user equipment such as mobile handsets, televisions, tablets and computers, that offer features to enable persons with disabilities to use ICTs effectively. This policy recognizes that there are often challenges with respect to the availability and affordability of end user equipment which, when obtainable, may be at an additional cost to the end user.
- access to and knowledge of assistive technologies that should be free or available at a low cost through subsidies or grants. A broad range of assistive technologies should be available in Sudan and should be affordable. persons with disabilities and those who assist them need to be trained on the use of technologies and features made available.
- access to services and interfaces to ensure that content available on television, the Internet or in other electronic formats is accessible by all users - for example, through the use of captions for users who are deaf or hard of hearing and audio description for users who are blind or visually impaired. There also need to be awareness campaigns on the design and availability of accessible content.
- support from providers of ICT services through access to customer services which understand and address the specific needs of persons with disabilities
- affordable ICT services which can be achieved through general measures to lower the cost of communications, and additionally through the offering of specialist productsand discounted tariff plans that are structured in a way that recognise the ways that persons with disabilities use services – for example, text-only mobile communications packages for deaf or hearing-impaired users.
In Sudan, quality of service issues were not identified as a challenge preventing persons with disabilities from using ICTs effectively, which is the only area where a significant difference in terms of challenges and solutions appears to exist.
- LEGAL AND POLICY FRAMEWORK
A number of international agreements and conventions, pieces of legislation, policies, procedures, guidelines, bylaws, and other documents that relate to disability and/or the ICT sector exist to promote the interests of persons with disabilities in Sudan. This Policy must be read in conjunction with, and must include, amongst others, the key instruments described in this section.
- 1International framework
At an international level, a number of policy and legislative instruments contain key provisions that support the stated goal of this Sudanese ICT Accessibility Policy and the associated strategic plan, which is making ICT accessible for persons with disabilities. This policy is consistent with the following international Instruments for promotion of human rights and these are:
- United Nations Universal Declaration of Human Rights (1948)
- International Convention on economic, social and cultural rights (1966)
- United Nations Convention on Civil and Political Rights (1966)
- Convention on Elimination of all Forms of Discrimination against Women (1979)
- African Charter on Human and People’s Rights (1981), which was ratified by Sudan in 1982
- United Nations Standard Rules on Equalization of Opportunities for Persons with Disabilities (1993)
- Continental Plan of Action for Persons with Disabilities in Africa (2002)
- United Nations Convention on the Rights of Persons with Disabilities (2006)
- Windhoek Declaration (2008)
- 1.1UN Convention on the Rights of Persons with Disabilities
The UNCRPD is the first international, legally binding treaty aimed at protecting the human rights of persons with disabilities. In 2009, Sudan signed and ratified the UN Convention on the Rights of Persons with Disabilities (“UNCRPD”, “the Convention”) which enshrines the principle that persons with disabilities must be able to enjoy human rights and fundamental freedoms on an equal basis with others. It is the first international human rights treaty requiring that information and communications technologies and systems be accessible as a necessary condition for persons with disabilities to fully enjoy these fundamental rights without discrimination. Its dispositions provide a human rights foundation for existing policies and programmes developed by countries, including Sudan, such as universal service and access policies for telephony, audio and video programming and/or web accessibility, and set a clear roadmap for countries lacking such policies.
The UNCRPD recognizes ICT accessibility as a condition for persons with disabilities to fully enjoy all human rights and fundamental freedomsThe obligation for State parties to ensure that persons with disabilities have access to information and communication technologies;
- The obligation to ensure that all content, communication, hardware, software and interfaces are to be accessible;
- The promotion of assistive technologies and information in alternative formats to persons with disabilities to ensure their access to information;
Article 9 of the Convention sets out general obligations for States Parties to ensure that persons with disabilities have access to information and communication technologies and systems. Articles 21, 29 and 30 expand on this and refer to media, communications and ICTs serving as platforms for furthering the rights of persons with disabilities to freedom of expression and opinion, access to information, participation in political and public life and participation in cultural life, recreation, leisure and sport. These Articles collectively call for all content, communication, information, hardware, software and interfaces to be accessible. They further call upon States Parties to encourage the private sector to deliver accessible products and services
- 1.2The 2030 Sustainable Development Goals
The United Nations’ 2030 Sustainable Development Goals (SDGs) recognise the importance of ensuring the full participation of persons with disabilities in society. Five (5) of the seventeen (17) SDG Targets – Goals 4, 8, 10, 11 and 17 – make explicit reference to the needs of persons with disabilities specifically in relation to education, growth and employment, inequality and accessibility of human settlements. They also support the collection of data and monitoring of the SDGs. In summary:
- ·SDG Goal 4SDG Goal 8 states that in order to “promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all, the international community aims to achieve full and productive employment and decent work for all women and men, including for persons with disabilities, and equal pay for work of equal value.”SDG Goal 10 strives to “reduce inequality within and among countries by empowering and promoting the social, economic and political inclusion of all, including persons with disabilities.” SDG Goal 11 seeks to make cities and human settlements inclusive, safe and sustainable. To realize this goal, Member States are called upon to provide access to safe, affordable, accessible and sustainable transport systems for all, improving road safety, notably by expanding public transport, with special attention to the needs of those in vulnerable situations, such as persons with disabilities.SDG Goal 17 stresses that in order to strengthen the means of implementation and revitalize the global partnership for sustainable development, the collection of data and monitoring and accountability of the SDGs are crucial. The availability of high-quality, timely and reliable data that is also disaggregated by disability is critical.Regional framework
(will replace diagram with 2017 report if it is out already and if I can get a copy)
Significant developments have taken place over recent years with regards to the institutional and legal frameworks on disability in Arab countries. Notwithstanding its under-reported figures, Sudan reports the highest incidence of disability in the region, making the regional average far below the global average of 15 percent. Practically, despite these low figures, the region is well aware of the need to have inclusive legal and policy frameworks.
In addition, accessibility has been a key political and social concern in the region for over a decade. The 2004 Arab Summit convened by the Economic and Social Commission of Western Africa (“ESCWA”) and the League of Arab States (“LAS”) declared the period from 2004 to 2013 as the “Arab Decade for Persons with Disabilities.”
- 2National framework
In terms of national laws and policies, the following have the most direct bearing on the rights of persons with disabilities in Sudan:
- Sudan’s 2005 ConstitutionThe General Education Act (1992) which provides for equal opportunity in education for persons with disabilities. After effective lobbying by disabled people’s organisations, the Government decided that all children with disabilities would be entitled to free education from 2002.
- The Disability Act (2009), which outlines a range of rights for persons with disabilities and provides for the establishment of a National Council for Persons with Disabilities to oversee and coordinate its implementation. It is supported by a Disability Policy and a proposed five-year national strategy.
- The Health Insurance Law, the Civil Rights Law, and the Child Welfare law address the needs of persons with disabilities as part of the broader legislation. The Sudanese Civil Service Code furthermore includes a 2% disability employment quota of positions in the public sector to persons with disabilities.
In addition to the above, there are sector specific policies and strategies in the health and education sectors. The National Strategy on Education for Children with Disabilities (2013 -2016), and the National Health Strategic Plan (2012-2016) were both made based on the Strategic Plan of the National Council of Persons with Disabilities (2012-2016). It is proposed in this report that the ICT Accessibility Policy will have a similar status.
The institutional framework to support the interventions linked to improving the situation of persons with disabilities in Sudan is fairly well developed. Thus, this ICT Accessibility Policy is developed against a relatively strong institutional framework.
Key institutions responsible for implementing government policy and enabling the inclusion of persons with disabilities are:
- The Sudanese Ministry of Social Welfare, Women and Children Affairs (“MGCSW”) is mandated to promote gender equality, social justice, and safe guard the rights and welfare of women, children, persons with disability and other vulnerable groups. The scope of the mandate of the Ministry covers gender and women’s empowerment, child and social welfare functions. Its vision is to “contribute towards attainment of a just, peaceful, inclusive and equitable society”. The MGCSW is responsible for law and policy on persons with disabilities, monitoring and evaluation, institutional capacity building, training and implementation at state levelThe National Council for Persons with Disabilities (“the Council”) which became functional in 2013 was established to support the implementation of existing agreements, policies and legislation, including the UN CRPD and the 2009 Disability Act. It was established along with counterpart, state-level councils in each of the 18 states of Sudan. Persons with disabilities, largely drawn from the leadership of DPOs, hold at least 50% of the seats on the governing boards of these councils.
- The Sudan National Human Rights Commission (“SNHRC”) was established by a Presidential Decree in 2012.
- The Advisory Council for Human Rights in Sudan is an advisory unit to the government established in terms of the National Human Rights Commission Act 2008. It includes different committees, and one of them is the Committee on the Rights of Persons with Disabilities. Its role is to raise awareness of the rights of persons with disabilities, make recommendations on existing laws and their suitability to persons with disabilities, and to provide research and studies on laws related to the group.
The key institutions responsible for implementing government policy and enabling the accessibility, availability and affordability of ICTs in Sudan include:
- Ministry of Communications and Information Technology (“MCIT”) which is responsible for the information and communications technology legislation and policy development and sector oversight to create conditions for an accelerated and shared growth of the Sudanese economy.
- ·National Telecommunications Corporation (“NTC”), which is the regulatory authority established in terms of the Telecommunications Act (2001) to amongst other things “lay down the plans, policies and regulations for the provision of the telecommunication services and their establishment thereof on the national level taking into consideration the balanced development and the service of the social and national objectives.National Information Centre (“NIC”) which is the institution responsible for leveraging IT and ICT as a strategic resource to enable government to improve service delivery, procure and to provide support in the rollout of e-government strategy and programmes. The National Information Center is the main authority that supervises ICT development in Sudan and is actively involved in the development of national strategies in the field of information technology. NIC also coordinates information between ministries and other government units, IT institutions, civil society organizations, and the private sectorBroadcasting/ Audi and Visual content…
- Emergency Services
The above summary indicates that at a national level, Sudan has a fairly comprehensive legal, regulatory and institutional framework to address issues concerning access to ICTs by persons with disabilities; although the legal framework is in place, actions need to be taken to ensure effective implementation. Furthermore, Sudan has a robust institutional framework to support the development and implementation of ICT law, policy and regulation.
What is lacking, however, is the meeting point of the disability framework and the ICT framework. In light of this, a specialist ICT Accessibility Committee comprised of the key stakeholders already in place will be created, described in §4.1.6 below to guide and advise on the implementation of this policy.
In addition, the Policy calls for three-year Strategic Plan identifying Strategic Objectives for implementation of the ICT Accessibility Policy as described in Part 4 below. The ICT Accessibility Committee will be responsible for providing guidance to MCIT and on the implementation of this ICT Accessibility Policy and Strategic Plan.
The goal of this policy is to make ICT enabled services available, affordable, and ultimately accessible so these technologies constitute an opportunity to enable the full and effective participation of persons with disabilities in society.
- 2Strategic Objectives
This ICT Accessibility policy seeks to mainstream ICT accessibility and in so doing, improve the general usability of ICT products and services for all people in Sudan. The associated Strategic Plan, seeks to put in place measurable actions and targets to ensure the effective implementation of this policy.
In order to achieve the goal of this ICT Accessibility policy the following objectives are defined:
- Mainstream ICT accessibility in the ICT sector and across government, and ensure effective coordination and implementation of ICT accessibility across government
- Enhance access to ICT enabled services across web, public access, broadcasting and mobile
- Promote accessible ICTs through responsible and inclusive public procurement
Recognizing the importance of accessibility to the physical, social, economic and cultural environment, to health and education and to information and communication, in enabling persons with disabilities to fully enjoy all human rights and fundamental freedoms, the principles listed below underpin this ICT Accessibility Policy. It is important to note that the values are often inter-related and that one cannot apply one of the values in the absence of the other values.
- Non-discrimination – all people should be treated fairly without prejudice.
- Sustainability - all legal, policy and regulatory interventions and the implementation thereof should be able to be maintained over a long enough period to achieve the desired outcomes.
- Awareness – everyone in Sudan should know about ICT accessibility, its benefits and products and services that promote it.
- Accessibility – all products and services should be able to be used by a person with a disability as effectively as can be used by a person without that disability.
- Affordability – accessible products, services and resources should be available at a price that is within the means of persons with disabilities, and if not, alternative funding mechanisms should be available.
- Availability – a person should be able to access networks and services universally regardless of their geographic location, social status or physical ability.
- Universal Design - products, environments, programmes and services should be usable by all people, to the greatest extent possible, without the need for adaptation or specialist design.
- Accountability - stakeholders should accept responsibility for their roles and to work together in a transparent manner to achieve the desired outcomes.
- 4Key Priority Areas
The Ministry of Communication and Information Technology, which is the champion of the policy, will put in place measures to provide an enabling framework to support the development of a culture and practice of ICT accessibility in Sudan in particular in 7 (seven) priority areas for implementation in the next three years:
- (1)Legal, Policy and Institutional measures:
- Mainstreaming ICT accessibility in MCIT and its portfolio organisations through inclusive language, definitions (including guidelines and standards) and provisions in policies, laws and regulations; and through including persons with disabilities as beneficiaries of the Universal Service and Access Fund or any other funding mechanisms or programmes relating to the ICT sector and extending the goals of universal service/access to include accessibility in addition to affordability and availability of ICT produces and services (see section 7.1.1);
- Increasing Awareness, Participation and Representation by persons with disabilities s through encouraging national debate and discourse, by strengthening the Council’s ICT accessibility capacity, setting up specialist committee of the Council to deal with ICT issues, through inclusive policy and regulation-making and public consultation processes (see section 7.1.2). In addition, awareness and participation will be enhanced through the establishment of the specialist ICT Accessibility Committee.
- (2)Mobile Accessibility
Putting in place measures and taking steps to promote ICT product and service accessibility, including mobile and public access services and facilities. Specialist telecommunications services and assistive technologies are available for persons with disabilities, are often not available, accessible or affordable. In addition, critical services must be in place including emergency services, and discounted services to enable persons with speech, hearing and mobility disabilities to communicate with the rest of society at reasonable rates (see section 7.2).
- (3)Web Accessibility
Putting in place measures and taking steps to promote web accessibility: Web accessibility means that all users have equal access to information and functionality, persons with disabilities, as well as the elderly, and people who are illiterate. This translates into the fact that all people, including persons with disabilities can perceive, understand, navigate, and interact with the Web, and that they can contribute to the Web. Web accessibility also benefits others, including the elderly and people who are illiterate. Without accessible public and private sector websites universal access to broadband is unattainable and the participation of persons with disabilities in the digital economy is limited. Standards must be put in place to promote accessibility by persons with disabilities to online content (see section 7.3).
- (4)Audio and Visual Accessibility
Putting in place measures and taking steps to promote broadcasting, or audio and visual, accessibility, whether broadcasting is delivered on an analogue or digital platform. Audio and visual accessibility covers television, radio, video programming and electronic programming guides and is key as television is mentioned explicitly in article 30(1) (b) of the UNCRPD. It addresses access by the deaf or hard of hearing; blind or low vision users; those with cognitive disabilities; and persons with physical disabilities to broadcasting services (see section 7.4).
- (5)Accessibility of Public terminals
Putting in place measures to promote the accessibility of public access terminals, including Automated Teller Machines (ATMs), and computers in public facilities (see section 7.5). This includes availability of accessible premises, equipment and software as well as physical environment accessibility.
- (6)Procurement that promotes accessibility
Putting in place measures and taking steps to support accessible procurementpolicies particularly for public sector organizations to give priority or preference to technologies and devices that are accessible and apply universal design principles and standards (see section 7.6).
- (7)Accessible emergency services
Putting in place measures in the broadcasting and mobile accessibility sub-policies, to support accessible emergency services such that all people can receive assistance in emergency situations.
- 5FOUNDATIONAL AND SUPPORTING MEASURES
A number of key actions and measures need to be undertaken at the outset in order to effectively implement this policy. These foundational measures are critical to taking this policy forward and include the demonstration of political will, conducting of research of ICT accessibility, training and capacity building, the development of a website dedicated to ICT accessibility, and the setting up of a multi-stakeholder committee dealing with ICT Accessibility. These are discussed in greater detail hereunder:
- Demonstration of leadership and a strong political commitment at the highest levels of the MCIT to ICT accessibility and the implementation of the proposed policy recommendations
- Conducting of baseline research on persons with disabilities’ access to ICTs in their specific areas, and annual updates – where possible a joint research approach will be encouraged so that a single national ICT Accessibility baseline is achieved. All relevant stakeholders have identified a lack of credible data as an impediment to making meaningful, evidence-based interventions and decisions relating to persons with disability in general, and thus naturally to ICT Accessibility for persons with disabilities. Although the upcoming census will deal with disability in a better way, there is a need for ongoing, coordinated and reliable research, some of which is specific to the ICT sector, which should be overseen by MCIT and NTC based on data collected from the industry as well as commissioned research. An annual ICT Accessibility Report should be published on the state of accessibility of ICTs in Sudan, the impact of ICT accessibility and the level of participation of persons with disabilities in the ICT sector.
- Contribute to the development of an ICT Accessibility Website and Portal (“ICT Accessibility Website”) and other communication tools to increase awareness of accessible ICT products and services, as well as programmes and initiatives that are in place in Sudan which improve ICT accessibility. This is in response to the fact that it has been noted that awareness is a key challenge facing persons with disabilities. Thus, a centralised, reliable and accessible database of information on ICT accessibility will assist to raise awareness and share information. Amongst the information to be provided on the website is accessibility features of mobile phones, and broadcasting consumer devices, accessibility contacts at ICT companies, information and links to free assistive apps for various computing platforms and contact details for organizations implementing relevant ICT accessibility programmes. The content of the website will be sourced from project owners including mobile operators, who can provide guidance on CSI programmes benefitting persons with disabilities , on products and offers that are accessible and on any other relevant information; in addition, government departments and agencies, including MCIT, NIC and NTC will consistently update the information. Finally, civil society organisations will provide content related to the programmes and projects that they run which are relevant.
NIC should be responsible for the establishment and management of the website and portal.
Other communication tools such as billboards, radio and TV public service announcements, SMS, and social media outreach will be used to increase awareness through campaigns carried out from time to time.
- Ensure relevant training is provided on ICT accessibility, in collaboration with NIC and the ICT Accessibility Committee to ensure that training is relevantEstablishment of a specialist ICT Accessibility Committee which will as its main focus, advise on the effective implementation of the recommendations set out in this policy and the actions set out in the Strategic Plan. Disability organizations, including the Council, have acknowledged that they do not have the requisite ICT specific skills to participate effectively in ICT Accessibility discussions, thus a specialist ICT Accessibility Committee should be established in order to progress the policy goals and recommendations set out in this report and to implement the Strategic Plan.
The ICT Accessibility Committee will have amongst its terms of reference:
- The review and endorsement of this ICT Accessibility Policy and Strategy and any amendments thereto. Considering and deciding strategic approaches necessary to address each of the identified technology and policy areas;
- Developing an awareness raising and communications strategy to promote the policy objectives within government departments, agencies, industry, persons with disabilities and their representative organizations and members of the general public in Sudan;
- Considering and advising the various stakeholders on the supporting capacity building measures necessary to assist in the implementation of these policy recommendations
- Providing input on the ICT Accessibility Website
Membership of the Committee
Implementing the ambitious policy recommendations and plans contained in this report will require significant effort and support across a wide range of individuals and organizations from government, the disability community and industry. The specialist ICT Accessibility Committee should be multi-stakeholder and may include the National Council for Persons with Disabilities, the Advisory Council for Human Rights in Sudan’s Committee on the Rights of Persons with Disabilities, the NTC and the NIC at a minimum, working with and led by the MCIT to oversee and coordinate the implementation this policy. Members of the ICT Accessibility Committee can be encouraged to participate in training on ICT accessibility.
- 5.POLICY PRIORITY AREAS
- 1Legal and Institutional Measures
- 1.1Mainstream ICT Accessibility across MCIT, its portfolio institutions and ICT sector members
Existing ICT policies, legislation and regulations should be revised in order to reflect necessary changes to promote ICT accessibility. Annex 4 provides an overview of proposed amendments. In addition, where necessary, new legislation or by-laws may be developed, for example on public procurement of accessible ICTs. In addition, Sudan’s disability legislation should be amended to refer to ICT accessibility.
In developing legislation, regulations and by-laws or implementing “soft law” strategies, the involvement of organizations of persons with disabilities is crucial.
The MCIT and its portfolio organizations will use effective communications and will also introduce the use of accessible publication formats in all of their processes; MCIT will, importantly, increase awareness of the methods and benefits of accessible publishing. Accessible publishing will enable persons with disabilities to access official MCIT documents and over time to all Sudanese government documentation in an accessible format. This will enable equal access to information and thus facilitate equal participation by persons with disabilities in ICT policy and regulatory processes and ultimately, once applied across government, in society as a whole.
- 1.2Promoting Awareness, Effective Participation and Increasing Representation by persons with disabilities
MCIT and all of its portfolio organizations will be responsible for effective implementation of the various aspects of the policy through their relevant mandates. It is the duty of government to ensure the full realization of the rights of persons with disabilities s.
MCIT recognizes the importance of including persons with disabilities s in the design and implementation of programmes and strategies. In addition to including persons with disabilities in the relevant planning and decision-making sessions, MCIT and its portfolio organizations will at all times encourage effective participation by persons with disabilities through supporting consultative sessions through the use of accessible publication formats and effective communication. Disability organizations, including the Council, have acknowledged that they do not have the requisite ICT specific skills to participate effectively in ICT Accessibility discussions, thus the specialist ICT Accessibility Committee will facilitate this.
To that end, MCIT will also strengthen the already established relations with the various Disabled Persons Organizations, persons with disabilities the Private Sector, Community Based Organizations, faith-based organizations, Civil Society Organizations and Development Partners, amongst others.
- 1.3Accessible Emergency Communications
The importance of accessible emergency communications cannot be overemphasized. MCIT will ensure that the Sudanese frameworks for emergency communications, which is currently being reviewed, provides that emergency services are accessible for persons with disabilities. To give effect to this, the emergency services committee currently reviewing the framework should consult with Disables Persons Organisations (“DPOs”) and ensure that the needs of persons with disabilities are include in the design of the systems. In addition, further to physical access requirements, the measures proposed specifically in the audio-visual and mobile sections of this policy should be considered.
- 2Mobile Device and Service Accessibility
Mobile telephony can promote social inclusion, and enable accessibility to the physical, social, economic and cultural environment, to health and education and to information and communication, in enabling persons with disabilities to fully enjoy all human rights and fundamental freedoms. Access to mobile services, whether basic voice and SMS, or more advanced broadband services, including recently launched 4G services, delivered over a smartphone, is central to people’s active participation in society.
Sudan has a 60 percent mobile penetration rate and 28 percent of individuals using internet regularly, mainly through mobile broadband. Thus, the impact of ICTs on the economy and individuals is already significant. It is therefore important that as ICT penetration and its impact grow, persons with disabilities, estimated to make up at least 15 percent of the population, are not left behind.
Persons with disabilities in Sudan, and globally, often face challenges when trying to harness the potential of mobile technology. There are often challenges with respect to the availability and affordability of this equipment that, when it is available in country, may be at an additional cost to the end user. It should be noted that the MCIT and NTC’s goal is to ensure a certain number of percentage of mobile phones, to be determined by the NTC in consultation with the Accessibility Committee, has a basic set of accessibility features and is compatible with assistive technology such as hearing aids or screen readers so that mobile operators and resellers can stock these accessible devices and train their staff to demonstrate their features to customers with disabilities.
Even where there is no additional cost, and accessibility features are embedded (for example in many mobile handsets, which can be identified on the Global Accessibility Reporting Initiative (“GARI”) website that contains a database of the accessibility features for mobile phones), awareness, training and education of both users and service providers are often required in order to break the accessibility barrier. In addition, products and tariff plans are not always structured in a manner that recognizes how persons with disabilities use services.
- 2.2Scope and Application
The scope of this mobile accessibility policy priority area includes:
- Mobile services (voice, data, broadband), including emergency, relay and directory services
- Mobile industry customer support services including call centres, customer support centres, web sites, and points of sale.
- End-user devices (including basic phones, feature phones, smartphones, tablets, and assistive applications and services)
MCIT seeks to put in place measures to provide an enabling framework to support the development of a culture and practice of mobile communications accessibility. In so doing they will ensure that persons with disabilities have access, on an equal basis with others, to mobile networks, devices, services, applications, and content in urban, suburban and rural areas. This will be achieved through:
- Conducting and publishing baseline research on persons with disabilities ’s access to mobile voice and broadband services in Sudan
- Raising awareness on accessible ICT devices and services, including by publishing on the ICT Accessibility Website and Portal projects undertaken by the ICT public institutions and private sector members of the industry;
- providing information on subsides, funding, scholarships or job opportunities and of interest to persons with disabilities in the ICT sector; information on discounted tariffs and special products or services offered by Sudanese operators to the public; and assistive technologies and other resources available in Sudan to facilitate ICT accessibility. Mobile operators will also advertise and promote accessible mobile products and services, including outreach to disabled persons organizations.
- Promoting affordability of accessible mobile devices and services through requirements for non-discrimination, subsidies and incentives, where possible; and through encouraging the design of tariff plans that meet the needs of persons with disabilities
- Promoting the accessibility of assistive technologies for persons with disabilities
- Identifying relevant standards applicable in Sudan, via NTC and NIC, from time to time and implementing them through type approval and other processes. This will promote accessible and universal design and the distribution of accessible devices.
- Providing that emergency information made available to the public should also be provided in alternative accessible formats such as via relay services and text messages on mobile phones, and encouraging public awareness campaigns that provide information on how persons with disabilities can contact and use emergency and relay services
- Promoting the training of mobile operator staff, in shops and call centres on mobile accessibility and how to provide effective customer care in that regard
Awareness has been flagged as a key issue preventing persons with disabilities from better utilizing ICTs to increase their inclusion in society. The ICT accessibility website will go a long way to address this and will be successful based on the content and information received from the industry on available products, services and programmes to facilitate ICT accessibility. MCIT and NIC will develop the ICT Accessibility Website and other communications tools, within 12 months of coming into effect of this policy document. The ICT Accessibility Website will need to be updated periodically. A quick win would be for the ICT Accessibility Website to include links to the GARI and FCC Clearinghouse websites, amongst others – this would provide immediate access to a repository of information on accessible ICT and mobile devices, equipment and handsets.
Other communications tools will also be used to promote awareness of ICT accessibility and the initiatives taken in alignment with this policy. The MCIT, in collaboration with the Ministry of Social Welfare, Women and Children Affairs, may carry out a national ICT accessibility campaign highlighting key aspects of this policy, and initiatives taken in alignment with this policy, using traditional media including Above the Line (billboards, posters, television and radio), Below the Line (conferences, exhibitions) and social media elements.
Products, Services and Retail outlets
Recognizing that the mobile industry has in depth knowledge of its own products, services and strategies, and noting the initiatives underway presently in Sudan undertaken by the mobile industry, mainly as a form of corporate social responsibility initiatives and sometimes ad hoc interventions to address the needs of persons with disabilities, it is acknowledged by all parties that this does not go far enough to address these ICT accessibility policy objectives, nor are the projects implemented in a sustainable or holistic manner.
NTC and MCIT will encourage the mobile industry to proactively take measures, within the next 12 months, to promote mobile accessibility and report annually to NTC, failing which the MCIT will recommend that the NTC amend the licenses and/or by-laws to put in place obligatory measures as provided for in section 46 of the Telecoms Act.
Measures to be considered by mobile operators as part of the proactive implementation of the policy objectives include:
- Training customer service employees in order to create awareness and to facilitate the effective use of the mobile equipment by persons with disabilities.
- An analysis of the local market for mobile equipment and a gap analysis on availability of assistive technology procured by themselves that can be used with mobile communications,
- The offering of discounted tariffs and specific packages for persons with disabilities, bearing in mind the current pricing regime and ensuring that prices charged do not distort competition.
- The development of more targeted and sustainable CSI programmes to address accessibility requirements. These should also be reported on the ICT Accessibility Website.
In addition to encouraging mobile operators to take positive action to promote mobile accessibility, measures to be taken by NTC include that it:
- Will identify areas for government actions and funding for research and development and clearly indicate these to MCIT.
- May, as part of its type approval framework, consider adopting the European accessibility standard EN 301 549 for accessibility as part of the type approval framework to ensure mobile phones imported into Sudan are accessible.This could include the following steps:
- Identify the relevant requirements from EN 301 549 that relate the mobile phonesDiscuss with the mobile operators the possibility to test conformity of mobile phone handsets against the relevant clauses from EN 301 549.
Should the operators and service providers wish to voluntarily ensure compliance, then the type approval regulations do not need to be amended.
Accessible emergency services
Many mobile phone users may have hearing and / or speech difficulties. Whatever their combination or severity of these impairments, it is important that they be able communicate with other people via their mobile phone. Of critical importance is the ability to communicate with emergency services in times of emergency or accident. One important way is via relay services which are services that enable deaf people to communicate with people with hearing and thus enable people to make, receive and complete telephone conversations via their phones.
With respect to emergency and relay services, provisions in law, by-laws or license conditions in Sudan should require that persons with disabilities should be able to use their everyday communication means (e.g. terminal equipment and services) for reaching emergency services and should be able to contact emergency services free of charge, whatever the technology or device they use.
NIC should, as soon as practically possible, work with the emergency call centres to ensure that they are able to receive and respond to SMS text messages as well as calls from relay services to permit emergency calling by people with hearing or speech disabilities.
The goal of this web accessibility sub-policy is to remove barriers persons with disabilities face in using websites and in accessing internet content. Web accessibility includes all content published on websites. This upholds the fundamental right of access to information by all and is aligned with the Ministry’s objective of increasing universal service and access by making the internet accessible. These objectives cannot be met without enabling persons with disabilities to participate equally on the Web.
Web accessibility is critical for all members of society, including persons with disabilities. Accessibility issues related to the internet and web content and services concern a wide range of persons with disabilities, including persons with auditory, cognitive, dexterity, hearing, mobility and visual impairments. For example, people who are blind or with low vision require websites that are compatible with screen readers that read text aloud; provide text alternatives for images which describe images; allow for resizing of text, images and page layouts and provide alternative web navigation aids. People who are deaf or hard of hearing will require captions for any content that is spoken, including videos, media players and web applications (apps). Persons with mobility disabilities may require additional time to complete tasks on a website and streamlined and keyboard-only compatible navigation mechanisms and page functions allowing use of alternative input devices. Digital content published on websites, for example, using office software and presentations or videos must also be made accessible to persons with disabilities.
Accessing and making use of the web can be achieved for persons with disabilities through the application of accessible web standards applied from the stage of the development of websites and continuing as web pages are maintained and enhanced.
The objective of this part of the policy is to enable persons with disabilities to navigate and interact with the web. This is an important imperative of the Sudanese goal of achieving universal service and access by increasing the usage and uptake of ICTs – with the evolution of technology in many countries this focuses on broadband in particular and seeks to ensure digital inclusion of all population groups.
Existing guidelines in Sudan
The Ministry recognises the Web Accessibility standards developed through the Web Content Accessibility Guidelines 2.0 (ISO/IEC 40500:2012) (“WCAG 2.0”) which already form the basis for internal guidelines that are used by the NIC (see “Principles and guidelines for designing a website for persons with special needs”) ISO/IEC 40500:2012 sets out guidelines that further clarify the purpose of each of the four principles underpinning this policy, namely perceivable, operable, understandable, and robust. These principles are also captured in the current NIC internal website guidelines, entitled “Principles and guidelines for designing a website for persons with special needs.” The web accessibility principles are:
- Perceivable – Information and user interface components must be presented to users in ways they can perceive. This means that users must be able to perceive the information being presented (it can’t be invisible to all of their senses);
- Operable – User interface components and navigation must be operable. This means that users must be able to operate the interface (the interface cannot require interaction that a user cannot perform);
- Understandable – Information and the operation of user interface must be understandable. This means that users must be able to understand the information as well as the operation of the user interface (the content or operation cannot be beyond their understanding); and
- Robust – Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies. This means that users must be able to access the content as technologies advance (as technologies and user agents evolve, the content should remain accessible).
The current NIC web guidelines, which align with WCAG 2.0, need to be formalised and published for application across government with timelines for various levels of conformance; similarly awareness needs to be raised about them. An Arabic translation of the WCAG 2.0 Guidelines is available athttp://www.alecso.org/wcag2.0/. This is an unofficial translation of WCAG 2.0 into Arabic that requires further review before becoming an official W3C translated version of WCAG 2.0. It is included for ease of reference and implementation.
- 3.2 Scope and Application
The scope of the web accessibility policy priority area includes:
- Public sector / government webpages and websites (including internet, intranet and extranet sites), as a first priority
- Digital content in various formats, like videos and electronic documents, etc. made available to the public by public sector web sites
For avoidance of doubt, this policy is applicable to all web pages containing online government information and services. Conformance is sought on all Sudanese government websites, i.e. websites owned and/or operated by government, local government, or on behalf of government by non-governmental entities under any domain. This includes external (public-facing or private) and internal (closed community) sites.
The enforcement of the web accessibility policy is best attributed to National Information Centre in light of its mandate to procure ICTs on behalf of government, and also in light of its central role in coordinating government IT.
- 3.3 Objectives
Recognising the importance of broadband as a means for citizens to participate in the information society, the intent of putting in place a web accessibility policy is to provide effective communication via the web for persons with disabilities. In Sudan this will be ensured through in the main:
- Increasing awareness of web accessibility across the value chain, i.e. from website developers, to government department that publish websites, to members of the public who access websites
- Making available opportunities for training and capacity building both eof the public as users of accessible websites, and IT specialists and developers of websites
- 3.4 Implementation
Web Accessibility Guidelines
The current NIC web guidelinesneed to be formalised and published for application across government with timelines for various levels of conformance; similarly awareness needs to be raised about them. An Arabic translation of the WCAG 2.0 Guidelines is available at http://www.alecso.org/wcag2.0/. This is an unofficial translation of WCAG 2.0 into Arabic that requires further review before becoming an official W3C translated version of WCAG 2.0. It is included for ease of reference and implementation.
Thus, the same principles are already applicable to websites in Sudan, although the standard requires formalisation and communication to the public to facilitate compliance. A proposed revised Web Accessibility Guideline is provided in Annex 4. There is no proposal to make it into a formal instrument like a by-law – it should be published in a manner that NIC can easily amend as the standard is updated. The detail of the standard may change from time to time as it is revised periodically.
NIC will, in the course of implementing its mandate, ensure that there is awareness of the need for accessible digital content on public sector websites to ensure that persons with disabilities can access all available public information on an equal basis with others. For example, any web fill-in form required to complete administrative processes should be accessible in accordance with the standard specifications.
Incentivising compliance and promoting awareness
The government of Sudan will, in the next 12 months, adopt a symbol or symbols for use on all government websites to highlight their ICT accessibility. To the extent possible, this symbol or symbols will be aligned with global standards and initiatives in this regard so that any person landing on a website created or hosted in Sudan will immediately know if the website is accessible for persons with disabilities, and if so, to what extent. MCIT could also issue an award to government agencies which achieve higher levels of accessibility to provide incentives. This will promote awareness of web accessibility as well as support the enforcement of this web accessibility policy.
Capacity Building and Training
All agencies and service providers that are tasked with managing web sites for the government of Sudan will be urged by MCIT and NIC to take steps to ensure that all personnel creating documents and any form of digital content are aware, trained by NIC and proficient in ensuring that such content is created in accessible formats. Accessibility checkers embedded in mainstream office productivity software including word processors, spread sheet, presentation and other commonly used content creation tools can be used to facilitate implementation.
Application to private sector
NIC will endeavour to work with NTC, which has regulatory oversight of the industry, to seek to enrol the support of industry and professional associations to issue voluntary codes of conduct and standards reflecting the same conformance objectives and timelines for public sector web sites. Where this voluntary approach is not effective, and once government websites are generally compliant and thus the standards are set nationally, then NTC may use other measures such as licence conditions and guidelines to encourage and enforce the participation of its licensees. Another key measure would be to require government agencies when procuring web services to procure accessible websites.
In furtherance of this policy, MCIT, NTC, NIC, and all other MCIT portfolio agencies are responsible for:
- Leading by example and maintaining minimum technical requirements for web accessibility on their own websites,
To give effect to web accessibility, the NIC is responsible for
- putting in place mandatory measures to ensure that persons with disabilities have access, on an equal basis with others, to public sector web sites services, applications, and content;
- effectively coordinating with international standard development organizations to promote web accessibility standards among all relevant stakeholders;
- taking a lead, and partnering where necessary, to provide guidance and incentives for education institutions and professional societies to develop courses for computer science students and information technology professionals about web accessibility as well as to provide training to government web and digital content developers on web accessibility implementation.
- Consolidating transition plans of all public-sector web sites in order to guide the implementation of this policy across all agencies;
- Evaluating and promoting across all agencies technical solutions and web templates that are most effective to ensure the accessibility of websites, toward achieving greater efficiency ;
- Monitoring and publishing the progress made by public sector web sites as measured by accessibility tests;
The MCIT can also play a key role by:
- Promoting the training and employment of persons with disabilities for web accessibility related projects and activities
- Promoting awareness of web accessibility
- Ensuring the participation of PwD, including the ICT Advisory Committee, in the monitoring and evaluation process
NTC, as the regulator, can further web accessibility in Sudan through:
- encouraging private entities that offer web sites services, applications, and content to the public to take into account all aspects of accessibility for persons with disabilities, on a voluntary basis – this can effectively be done through identifying, with the assistance of the ICT Accessibility Committee, those private websites of public interest and importance whose owners are already subject to government regulation. For example, NTC has responsibility for the ICT market and can incentivise the operators in its portfolio to have accessible websites. This could be a ‘quick win’ as many of these international operators are already subject to this type of regulation in other regions and hence have capacity and prior experience of making their websites accessible.
- Other regulated sectors to be considered using this approach include banking, health care, insurance, training and transportation.
- 4 Audio and Visual Accessibility
- 4.1 Context
Audio and visual accessibility includes television and radio and the devices and equipment that support the provision of these services, as well as video programming. Television is mentioned explicitly in article 30(1) (b) of the UNCRPD which states that “parties recognize the right of Persons with Disabilities to take part on an equal basis with others in cultural life, and shall take all appropriate measures to ensure that persons with disabilities : a) enjoy access to cultural materials in accessible formats; and b) enjoy access to television programmes, films, theatre and other cultural activities, in accessible formats.” The implication of Article 30 is that metrics for television accessibility need to cover not only awareness of access service provision, but also use and benefit. Finally, article 9(2)(b) stipulates that States Parties to the Convention must “ensure that private entities that offer facilities and services which are open to or provided to the public take into account all aspects of accessibility for Persons with Disabilities” – this covers private sector broadcasters and producers of audio-visual content.
Broadcasting accessibility requirements will have the most impact on audience members who are deaf or hard of hearing; blind or low vision; have cognitive disabilities; and have physical disabilities.
It should be noted that there are a range of accessibility requirements necessary to make programme content accessible for person with disabilities. Access services can be either “closed” (where the viewer can turn them on or off) or “open”, (where the access service is viewed by everyone). The most common access services are subtitling, Visual Signing and Audio description. For ease of reference:
- Subtitles: Subtitles, or text displayed at the bottom of the TV screen that describes the dialogue narrative, provided for people who are deaf or hard of hearing differ to those that are provided for people whose first language is not the same as the programme content, which tend to be more common in Sudan. Typically, subtitles provided for people who are deaf or hard of hearing include additional information such as changes in the text colour representing different speakers or other information about the auditory content in the programme, such as background noises, music etc. Subtitles are typically provided for pre-recorded programming and to a much lesser degree for live broadcasts. Subtitles for live broadcasts are produced in a number of ways including through stenography, similar to that used in courtrooms, and through a process called re-speaking, whereby a trained vocalist restates the live dialogue into a voice recognition application that produces high quality speech to text.
- Visual signing: the use of sign language to convey the information contained in the programme audio (speech and other important sounds) to viewers who are deaf and for whom sign language is their first language. This is already a requirement for the public broadcaster in Sudan on certain programming.
- Audio description: a supplementary audio track designed to provide information about on-screen action to blind viewers.
In addition to programming, equipment must be considered if a holistic, end- to-end view of audio-visual services is taken in the interest of consumers. Key equipment includes the devices necessary for the decoding and presentation of content to the viewer. This encompasses any receiver or consumer equipment that contains a digital tuner which decodes the digital signal and sends it to the screen. There are currently two main classes of devices that do this; set-top boxes and TVs with integrated digital tuners (“iDTV”). Remote controls and Electronic Programme Guides (“EPGs”) are important and are also considered in this policy.
- 4.2 Scope and Application
The focus of this part of the policy includes not only the content itself, but also the information and devices needed by people to enjoy audio-visual content. The scope of the broadcasting accessibility policy priority area of this ICT Accessibility Policy considers the accessibility of end-to-end television service and includes:
- Programming content, i.e. audio-visual content, television programmes and related information, regardless of platform, i.e. analogue, digital, internet, etc.
- Receiver equipment, e.g. TV sets, set top boxes, remote control, Electronic Programming Guides (“EPGs”) and Programme Information
- Public broadcasting services
- 4.3 Objectives
The objective of this policy is to provide an enabling framework to support the development of a culture and practice of broadcasting accessibility in Sudan through:
- identifying and applying policies and standards that mitigate the identified leading barriers to a fully accessible broadcasting ecosystem;
- putting in place measures to ensure that persons with disabilities have access, on an equal basis with others, to broadcasting services, devices, systems, applications, and content provided to the public irrespective of the distribution, delivery mechanism, platform or technology on which it is provided.
- 4.4 Implementation
The Ministry responsible for audio and visual services will ensure that the Sudanese public broadcaster has adequate funding allocated to it to provide a high-quality service to meet the needs of persons with disabilities. The government recognises that additional funding and education will be necessary to provide assistance to facilitate access by persons with disabilities to broadcasting services.
The NTC is responsible for ensuring that the public broadcaster implements captioning, signing and audio description. The NTC can consider making by-laws for the provision of access service to be made a mandatory aspect of public service broadcasting in Sudan. Noting that often codes and voluntary measures are more successful in achieving the stated goals, the NTC can mandated the making of a Code of Practice, which is informed by the public broadcaster’s inputs and those of the ICT Accessibility Committee and the public. This could be achieved, in part, by including a requirement that the Sudanese public broadcaster shall define and provide minimum levels of access services for blind and deaf persons across all its programming schedules and broadcasting platforms. The obligation shall be put in place through the development of a statutory Code of Practice to be developed, implemented and enforced by NTC.
This Code of Practice of the provision of accessible TV equipment and access services should address, at a minimum, the following aspects:
- Minimum levels of access services such as sign language and subtitles for the deaf to be provided on an annual basis. These targets could take the form of a minimum number of hours programming that should be provided across programming types including children's programmes, news programming, current affairs programming, programming produced in Sudan and programming imported from the region and abroad. The programming should be prioritised on the basis of an analysis of the costs and benefits. The ICT Accessibility Committee should be consulted on which types of programming to prioritize for access services in the first instance.
- The size and location of an annual budget for the provision of these access services
- The development of specifications based on the current DVB standards for accessibility features to be included in TV equipment for sale in Sudan. This Code of Practice should be developed in consultation with the ICT Accessibility Advisory Committee as well as persons with disabilities and their representative organizations, TV equipment manufacturers and the representative organizations and producers and production companies of local programming. MCIT, in consultation with the ICT Accessibility Committee shall raise awareness of this Code of Practice and the availability of access services for persons with disabilities. MCIT, in consultation with the ICT Accessibility Committee shall monitor the quality and levels of access services provided and shall review the Code of Practice at least every two years, taking into consideration technological developments, and revise the Code of Practice as appropriate.
Sudan can consider applying the following DVB standards that are widely used in Europe, which are recommended in this policy due to the fact that broadcasting in Sudan uses similar platforms to those used in Europe. In Europe, on digital television two delivery mechanisms are most commonly implemented:
- DVB Teletext (ETSI standard EN 300 472 (external)) delivers subtitles via DVB bitstreams in a form that can be easily transcoded at the receiver and inserted into the Vertical Blanking Interval for display on TV sets capable of displaying Teletext.
- DVB Subtitling (ETSI EN 300 743 (external)) offers a more sophisticated and flexible set of features than Teletext subtitling, whilst also being efficient in terms of required bitrate. In 2011, the document for subtitles TM-4516 with plano-stereoscopic content DVB TM-SUB doc 0022 was added to the DVB subtitling ETSI EN 300743 standard.
Accessibility features in receiver equipment
NTC should, either through the type approval framework or via the promotion of self-regulatory measures, seek to ensure that equipment imported and sold should adhere to the following:
- Interoperability with access services and content: A prerequisite for the provision of access services such as open subtitles is the capacity of the receiver to receive, interpret, mix and output the subtitles onscreen and in sync with the programming content. This capacity is dependent on the interoperability of the receiver with the content it receives. Examples here include the transmission of closed subtitles or meta-data associated with the EPG. It is also important that people know when and what access services for a programme are available.External connections should be easy to reach, particularly those that are most often required such as a headphone or AV socket, to assist persons with reduced mobility or other physical disabilities who may find it difficult to reach around the back of the set top box or television or to move them in order to get at the sockets, such as headphones and USB cables.
- “Plug and Play” devices should be encouraged. The set-up and tuning procedures should be as straight forward as possible, to assist older people and persons with cognitive impairments; furthermore all documentation should be available in accessible formats.
With respect to remote controls in particular, NTC should, in its type approval considerations, review the accessibility of handheld remote controls used for operating television equipment. These can present particular difficulties for people with limited experience in using technology, restricted hand control or strength (prevalent among older users), restricted vision or difficulty reading or understanding words or symbols.Broadcasters, Operators, Service Providers and Distributers who sell or otherwise provide remote controls should ensure that all such equipment and software that is procured and made available to the public is compliant with applicable universal design standards. Key accessibility features include:
- A way for users to quickly locate the required button without sight. For example, a raised dot or line on the number ‘5’ is very useful
- Simplicity - the remote control is as simple as possible given the required functionality and can be used with low physical effort.
Providers of broadcasting equipment should seek to ensure that viewers who are deaf or hard-of-hearing who use hearing aids, will able to hear the programme aided by the use of wireless connections between the television receiver and the hearing aid itself, or, wired connections between the TV receiver and an assistive listening device that a consumer chooses.
Accessibility features in on screen interfaces
In terms of on screen interfaces, EPG and on-screen information about programmes enable viewers to plan their viewing, find programmes and to know what they are currently watching. It also assists them to identify accessible programming. In light of this, access to the on-screen interface for people who are blind as well as people with low vision is essential. This can be achieved by text-to-speech for on-screen information such as “talking EPGs” and by ensuring that the text size and contrast is sufficiently clear. Therefore to the extent that EPG providers are operating from Sudan:
- Electronic Programming Guide and other TV control providers should incorporate such features in their EPGs and other TV controls as are appropriate to enable, so far as practicable, persons with disabilities affecting their sight or hearing to use the EPGs and other TV controls for the same purposes as people without such disabilities.
- EPGs should also provide information about assistance in relation to programmes (e.g. how to navigate radio and television listings, and how to operate television access services such as subtitling, signing and audio description), as well as facilities for making use of that assistance. Broadcasters should ensure this.
- Quality and service standards as well as technical standards for interoperable TV and video programming services with assistive technologies should be considered for adoption.
Accessibility features in programming content
Sudan should consider setting targets either by type of programme (for example news and children’s programmes) or number of hours of programming to include access services accessible broadcasting. This should be done in consultation with the ICT Accessibility Committee. Once this has been established, Sudan will consider adopting common language to notify the public of channels and programs that are accessible. This is bearing in mind the fact that globally, the following globally recognised symbols to denote accessibility - subtitling (S), signing (SL) and audio description (AD). These abbreviations should be explained in public communications and should be explained in an appropriate part of the EPG. MCIT should seek to encourage all of its counterpart Ministries in the Arab region to adopt the same approach given the exchange of broadcast content across the region.
For viewers who are blind or have low vision, television programmes should be made accessible through the provision of audio description/dubbingin Arabic. For non-Arabic content, the language of the AD should be the same as the program audio. Where Sudan uses subtitling rather than dubbing when offering television programmes in foreign languages, viewers who are blind or have low vision, as well as individuals with cognitive impairments or those who have a low reading speed can benefit from audio subtitles. In order to ensure this the translations should be provided in Arabic, as the language of a significant segment of the audience; they should be easy to read; they should provide equivalent information and they should match the timing of the activity on the screen.
Broadcasters should, to the extent technically possible, deliver Closed Captioning/ Subtitling, Sign language (in a form acceptable to the Sudanese deaf community), and Audio Description which are services that will benefit persons with disabilities and enable them to have access to broadcasting services.
The use of open standardised systems is encouraged. Furthermore, the use of Arabic is promoted. It is critical that the quality of subtitles, sign language and audio description services is tested with relevant audiences, and this can be done via the ICT Accessibility Committee. Government and Broadcasters should monitor the effectiveness of the service through contact with organizations representing persons with disabilities.
Accessible emergency services
With respect to broadcasting, provisions in law, by-laws or license conditions in Sudan should require that:
- Public awareness specifically on how persons with disabilities can use emergency services is mandatory and that any public service announcements required to be aired should include such information. It is the responsibility of NTC, licensed broadcasters and all of the public bodies with responsibility for emergency services to create awareness about the availability and accessibility of emergency services by persons with disabilities.
- Emergency information made available to the public should also be provided in formats accessible to persons with disabilities such as sign language and subtitles for the deaf and hard of hearing and audio messages on television/video programming for those with visual disabilities. For example, public communications and announcements that are broadcast in natural disaster situations must be made accessible to persons with disabilities in appropriate forms of communication, thus leveraging mainstream communication channels.
This part of the policy applies to all public access to electronic communications, telecommunications and broadband terminals and services. Public access is critical in providing services to the general public and specifically to persons who do not have individual access to electronic communication services due to lack of affordability or availability of ICT services. Given the link between disability and poverty globally and in Sudan, it is likely that many persons with disabilities rely on public access to ICTs – and yet said access poses a barrier to them. This may be despite efforts such as the implementation of xxxx centres, which provide ICT access for blind users. This could be due to physical inaccessibility of a xxx centre, or the placement of a public payphone in a manner that is not accessible for users in a wheelchair, lack of access to assistive technologies, or rates and charges that are not affordable, amongst others.
Government departments and service providers providing public telephones, public access points and public community internet access points should therefore be encouraged to ensure that phones, computers, ATMS and the facilities that house them are accessible and available on an equal basis to persons with disabilities, and that they are responsive to their needs
- 5.2Scope and Application
The scope of the public access priority area of this policy extends to fixed and wireless public access. It also includes access to Automated Teller Machines. This policy applies to public access devices that are:
- Funded privately and provided by service providers and operators or unlicensed third parties
- Funded publicly or through private public partnerships
- provided on a stand-alone basis (i.e. public payphones, ATMs)
- provided in shared spaces such as kiosks, phone shops, telecentres, multi-purpose community centres and similar ICT facilities
MCIT seeks to provide an enabling framework to support the development of a culture and practice of accessible public ICT access, through:
- Establishing public access centres that embrace the principle of mainstreaming access and are not specific to a particular disability as has been done historically in Sudan. Where centres are already in place that cater only for a single disability, the NTC will put in place plans to expand access and increase accessibility in such locations;
- Putting in place measures to ensure that persons with disabilities have access, on an equal basis with others, to public ICT devices, services, applications and content in urban, suburban, and rural areas;
- Promoting the procurement of accessible ICT devices and assistive technologies at an early stage of design and implementation of public access centres, so that they can be used by everyone and so that no additional costs are incurred to change the facilities after they have been opened. This will assist to promote the provision of low cost services.
- Promoting affordability of public access services through smart partnerships, subsidies and incentives, where possible with civil society organizations and Non-Governmental Organisations as well as the public-sector agencies identified in this policy; and
Buildings/ Physical Access
All buildings providing public access communication services, including public phone services, community Internet access kiosks, ATMs and other publicly available ICT services and devices should be accessible; in particular those funded in part of whole by government. Access ramps must be built to enable access to existing buildings hosting such services and elevators should be in place where facilities are not located on ground level:
Public access devices whether stand-alone (such as public payphones or ATMs) or in a public space (such as computer labs and libraries), must be accessible. Accessible public access communication service devices should include, amongst others enable persons with disabilities to use them independently by having:
- Hearing aid compatibility;
- Volume control;
- Tactile keys for phones with keypads
- Gesture-based screen readers for touchscreen devices;
- Wheelchair accessibility for at least one third of payphones; and
- Allow use of relay services such as video relay, text relay and speech-to-speech relay when remote interaction with an operator is required.
Public access computers and other devices that have screen access, both in centres funded by the Government of Sudan and privately funded establishments provided by civil society, non-governmental organizations, mobile operators, or other bodies should:
- Make use of universal icons to enable ease of use and comprehension by all people;
- Have screen reading software for blind users, where applicable;
- Have an audio jack or audio device located in a private area if the information accessed needs to be confidential, such as in financial and voting transactions;
- Have software that allows for visually impaired users to be able to increase font size and icon sizes;
- Have voice synthesizing functionality to convert text to voice where such technology is available in the national or local language;
- Allow for the use of alternative accessible input/output devices such as joysticks, switches or eye tracking using an integrated or attached camera
- Be accessible by wheelchair; and
- Have Braille readers and Braille printers attached to them, where possible.
As the regulator, NTC will take steps to ensure the accessibility of public access services and facilities as set out in this policy including by:
- reviewing license conditions, and by-laws governing the rollout of public access and reviewing the use of Universal Service and Access Funds.
- Developing minimum accessibility standards for public access centres. An assessment of the public access facilities should be conducted under NTC guidance, in order to estimate the accessibility needs. Once the assessment is completed, needs should be defined an implementation time frame with public and private stakeholders. Furthermore, the existing public access facilities that have been established under the auspices of NTC to address the needs of the blind, should be expanded to be general public access facilities which meet the needs of all people, including all persons with disabilities. The current public access facility for the blind that has been established with the support of NTC can be used as a model for this approach which mainstreams ICT accessibility.
- Encouraging licensees’ employees to receive training in order to be able to assist PwD in the use of public access equipment.
MCIT will liaise with the Ministry of Finance to encourage awareness of the contents of this policy and to facilitate NIC’s efforts to ensure the implementation of the public access sub-policy on public terminals provided by the financial services sector, such as ATMs. The same approach will be followed in due course as other government departments rollout ICT enabled terminals to support their e-government programs (e.g. transportation, health, etc).
- 6Public Procurement
Procurement is a key element for a successful implementation of all the above-mentioned policy areas. In the context, procurement is a key government tool to create a market for accessible ICT services and products.
According to the ITU “Model ICT Accessibility Report”, public procurement policies that require government agencies to procure accessible ICT equipment and services serve two key goals.
- Firstly, by ensuring alignment with universal design standards, and procuring the most accessible ICT equipment and services, government bodies can provide an accessible work environment for its employees and accessible public services for its citizens.
- Secondly, the public procurement of accessible ICTs creates a market for accessible ICTs. Manufacturers and service providers selling to the Sudanese market are incentivized to produce accessible ICTs and suppliers to stock accessible ICTs. This generates greater competition, drives down costs and promotes a greater availability of accessible ICT products and services in the marketplace.
Accessible ICT policies and practices for public procurement are important and result in improving the lives of persons with disabilities through ensuring public bodies utilize accessible ICTs in the delivery of public services, and providing ICT systems and services to the public that are usable and accessible by the widest range of people possible.
Given that the public sector in Sudan is a key source of procurement, and also is mandated to employ persons with disabilities, the importance of ensuring accessibility through procurement is even more important and will influence the supply of ICT devices and services in the market and incentivise the market to make available more accessible ICTs at lower cost.
In Sudan, the NIC is responsible for coordinating IT and ICT procurement on behalf of the government and assisting with ICT related capacity building. This includes ensuring that persons with disabilities working for government are able to work effectively within government departments.
Addressing the ICT accessibility needs of persons with disabilities can be achieved more cost effectively by considering them in the earliest stage of the procurement and development process. This is in line with Article 9(h) of the Convention which requires countries to “promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost”. Practically, this is achieved by including clear statements of user accessibility needs in all calls for tender and in verifying compliance with accessibility criteria. NIC and individual government departments can elaborate such clear statements of accessibility needs through the use of functional performance statements in the procurement process overseen by them.
Functional Performance Statements describe the functional performance of ICTs required to enable users with disabilities to locate, identify, and operate ICT functions, and to access the information provided, regardless of physical, cognitive or sensory abilities. Generally, this means providing alternative modes of communications and interaction for persons with disabilities which make the product or service accessible such as providing audio and tactile interfaces for users without vision. Functional performance statements (“FPS”) set the foundation for accessible ICT procurement. FPS are included in standards – currently there are three relevant and internationally recognized standards, EN 301 549, the US Section 508 and WCAG for websites.
- 6.2Scope and Application
This part of the broader ICT Accessibility policy for Sudan is applicable to all government bodies that procurement of ICT devices, products and services.
This policy seeks
- to ensure the acquisition of accessible ICT as measured through the establishment of a measure to ensure this a through definitions and standards (e.g. the EN 301549 or the US section 508). This objective is set noting that NIC indicated in the sessions leading to this policy that it often refers to global standards to help to achieve economies of scale, lower costs and ensure interoperability between devices, equipment and services used across government.
- to ensure that value for money is achieved in the procurement of accessible ICTs.
Given the institutional framework, this policy is best implemented through NIC which coordinates the procurement of ICTs on behalf of the government. The National Information Centrewill thus review its procurement policies such that they promote ICT accessibility, and in so doing will endeavour to:
- Adopt a set of generally accepted Functional Performance Standards, preferably by referencing global standards, as they are developed, and to share these with other government agencies and the private sector through, at a minimum, its website.
- Define and incorporate accessibility as an attribute in the procurement of ICTs, including as a criterion in the Call for Tender or Request for Proposals. It should include in all calls for tender the user accessibility requirements which are defined by Functional Performance Statements
- Promote the procurement of products and services that align with universal design principles in general, and identify and use appropriate standards, including WCAG 2.0 where they exist; and
- Refer to international accessibility technical standards where available for the specific features of various categories of ICT products (e.g. alternatives to voice-based services, visual output for auditory information and operation of mechanical parts), generally for off-the-shelf products
- Apply systematic processes to check the level of accessibility conformance of the products and services purchased
The approaches may differ depending upon the nature and complexity of the product or service purchased including off the shelf products, custom built products, integrated systems, system development, content development or services.
- SUPPORTING ACTIONS
Actions to support the successful achievement of thepolicy and regulatory actions set out that cut across all of the policy pillars in this document include:
- The provision by mobile phone operators and broadcasters of training, be designed in conjunction with the ICT Advisory Committee, to their customer service staff on communicating with and providing services to persons with disabilities. In addition, staff should be trained on accessibility features and services provided by the consumer equipment relevant to the particular operator or broadcaster, including mobile handsets, remote controls, set top boxes, etc.
- The implementation of all measures and actions following an accessible public consultation process, which includes the participation of persons with disabilities. At all times the ICT Accessibility Committee should be consulted.
- Consideration should be given to the proposals in Annex 4, which sets out proposed amendments to existing guidelines, by-laws and legislation. Any amendments should be monitored for implementation and periodically reviewed.
- MONITORING AND EVALUATION OF THIS POLICY
Participatory monitoring and evaluation that involves all stakeholders, in particular those representing persons with disabilities, will be carried out to identify the efficiency and effectiveness of the interventions for persons with disabilities as set out in this ICT Accessibility Policy. The following mechanisms will be overseen by MCIT:
- Developing verifiable monitoring indicators for every activity set out in the policy and strategy;
- Establishing evaluation structures as part of the specialized ICT Accessibility Committee with a focus on the inclusion of teams of the Council and its constituents in the evaluation of the effectiveness of the policy
- Producing and disseminating reports on regular basis, which the MCIT will collect from its portfolio organisations in order to prepare national level reports;
- Reviewing the policy and strategy every three (3) years
- FINANCING OF ICT ACCESSIBILITY
ICT Accessibility will be funded through public and private sources. MCIT hereby encourages the private sector participants in the ICT sector such as operators and device manufacturers to mainstream ICT accessibility in the delivery of their products and service; and to furthermore fund the development of innovative solutions to promote ICT Accessibility whether through their core business or through their CSI programmes.
In addition, MCIT supports the use by NTC of Universal Service and Access Funds, whose aim is to increase universal service and access and improve social inclusion, for funding accessibility ICT products, services and devices, including assistive technologies.
Any specific budget from MCIT?
Following is a proposed timeline for finalization of the ICT Accessibility Policy and Strategy and immediate steps to be taken for achieving the objectives.
|Share draft ICT Accessibility Policy with concerned stakeholders||MCIT||January 2018|
|Conduct high level endorsement meeting||MCIT/ ITU||February 2018|
ANNEX 1: GLOSSARY AND DEFINITIONS
“AD” Audio Description
“ATMs” Automated Teller Machines
“AV” Audio Visual
“CEN” European Commission for Standardisation
“CENEC” European Commission for Standardisation
“CSI” Corporate Social Investment
“CRPD” Convention on the Rights of People with Disabilities
“CVAA” United States’ 21st Century Communications and Video Accessibility
Act of 2010
“DPOs” Disabled Persons Organisations
“DVB” Digital Video Broadcasting
“EPG” Electronic Programme Guide
“ESCWA” Economic and Social Commission of Western Africa
“ETSI” European Technical Standards Institutes
“FCC” Federal Communication Commission
“FPS” Functional Performance Statements
“GARI” Global Accessibility Reporting Initiative
“ICF” International Classification of Functioning, Disability and Health
“ICIDH” International Classification of Impairments, Disabilities and Handicaps
“iDTV” Integrated Digital Television
“IEC” International Electro-technical Commission
“ISO” International Organisation for Standardisation
“IT” Information Technology
“ICT” Information and Communications Technology
“ITU” International Telecommunications Union
“LAS” League of Arab States
“MCIT” Ministry for Communications and Information Technology
“MGCSW” Ministry of Gender, Child and Social Welfare
“MTN” Mobile Telephone Networks (Pty) Ltd
“NIC” National Information Centre
“NTC” National Telecommunications Corporation
“PwD” People with Disabilities
“RNIB” Royal National Institute of Blind People
“SDGs” Sustainable Development Goals
“SMS” Short Message Service
“SNHRC” Sudan National Human Rights Commission
“The Convention” UN Convention on the Rights of Persons with Disabilities
“the Council” The National Council for Persons with Disabilities
“UAE” United Arab Emirates
“UNCRPD” UN Convention on the Rights of Persons with Disabilities
“W3C” World Wide Web Consortium
“WCAG” Web Content Accessibility Guidelines
“Assistive Technology” or AT” is any information and communications technology, products, devices, equipment and related services used to maintain, increase, or improve the functional capabilities of individuals with special needs or disabilities. Assistive technologies represent a separate hardware or software added to equipment or services to enable persons with disabilities to overcome the barriers they face to access information and communication. Assistive technology term does not include a medical device that is surgically implanted, or the replacement of such device.
“Accessible Publishing” means making information available in an accessible format, which may include, but is not limited to, alternate formats such as Braille, audiotape, oral presentation or an electronic file. An accessible publication is a publication which offers the maximum flexibility to users and allows content to be accessed and manipulated easily by users with or without disabilities.;
“Auxiliary Aids and Services” means aids and services that assist persons with disabilities to understand communications and include, but are not limited to:
- Qualified sign language interpreter services; note takers; computer aided transcription services; written materials or exchange of written notes; telephone amplifiers; assistive listening devices and systems; telephones compatible with hearing aids and cochlear implants; closed caption decoders; open and closed captioning; voice, text and video-based telecommunications products and systems, including videophones and captioned telephones, or equally effective telecommunications devices; videotext displays; accessible electronic and information technology; or other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing;
- Qualified readers; taped texts; audio recordings; materials and displays in braille; screen reader software; magnification software; optical readers; secondary auditory programs (SAP); large print materials; accessible electronic and information technology; or other effective methods of making visually delivered materials available to individuals who are blind or have low vision;
- Acquisition or modification of equipment or devices; and
- Other similar services and actions
"Accessible Communication" includes any means and formats of communication, whether delivered aurally, visually or tactilely, including languages, display of text, Braille, tactile communication, large print, accessible multimedia as well as written, audio, plain-language, human-reader and augmentative and alternative modes, means and formats of communication, including accessible information and communication technology.” meansthe state of being cheap enough for people to be able to buy. Considering that in general persons with disabilities are facing financial constraints, the lack of affordability is also a “barrier” to access ICTs. Therefore, affordability should be considered as a key element to ensure that PwD have access to ICTs.
“Braille” is a series of raised dots that can be read with the fingers by people who are blind or whose eyesight is not sufficient for reading printed material.
“Broadcasting” refers to programming provided via broadcast, cable, satellite, Internet, and programming provided on a stand-alone disc, tape or in any other removable media format
“Effective Communication” means any communication presented in a manner, or for which auxiliary aids are furnished, so that the information provided is equally accessible to individuals with disabilities, including those with visual, hearing, cognitive, learning, speech or motor disabilities. The person with disabilities should be consulted whenever possible to determine what type of auxiliary aid is needed to ensure effective communication.
“Information and Communication Technology” (ICT) refers to equipment and services related to broadcasting, computing and telecommunications, all of which process, store and transmit information through computer and communications systems.
“ICT accessibility” is a measure of the extent to which products, systems, services, environments and facilitates can be used by people from a population with the widest range of characteristics and capabilities to achieve a specific goal in a specific context of use”
ANNEX 2: LIST OF STAKEHOLDERS CONSULTED
- Ministry of Communications and Information Technology
- National Information Centre
- National Telecommunications Company
- National Council for Persons with Disabilities
- Ministry of Welfare and Social Development
- Humanitarian Aid Commission
- Civil Society organisations representing persons with disabilities
ANNEX 3: Proposed 3 -year strategic objectives, key methods to achieve strategic objectives and monitoring indicators
(Long term Objectives)
(Short term Objectives)
|Key Methods to achieve Objectives||Responsible||Monitoring Indicators|
|Mainstream ICT accessibility in the ICT sector and across government, and ensure effective coordination and implementation of ICT accessibility across government||
ICT Accessibility Committee established and operational (12 months)
Annual baseline research on ICT Accessibility published (12 months)
Legal, Policy and Institutional measures:
1.4 Mainstreaming ICT accessibility in MCIT through inclusive language, definitions and provisions in policies, laws and regulations; and through including persons with disabilities as beneficiaries of the Universal Service and Access Fund or any other funding mechanisms or programmes relating to the ICT sector and extending the goals of universal service/access to include accessibility in addition to affordability and availability of ICT services (see section 7.1.1);
1.5 Increasing Awareness, Participation and Representation by persons with disabilities s through encouraging national debate and discourse, by strengthening the Council’s ICT accessibility capacity, setting up specialist committee of the Council to deal with ICT issues}, through inclusive policy and regulation-making and public consultation processes (see section 7.1.2);
2.1 Implement recommendations arising from audit of legislation and policies (Annex 3)
2.2 Set up ICT Accessibility Website
|Enhance access to ICT enabled services across web, public access, broadcasting and mobile||Promote ICT product and service accessibility (Mobile accessibility), including mobile and public access services and facilities. In addition, critical services must be in place including emergency services, and relay services to enable persons with speech, hearing and mobility disabilities to communicate with the rest of society (see section 7.2)||
3.1 Conduct and publish baseline research on persons with disabilities ’s access to mobile voice and data in Sudan within12 months
3.2 Populate Accessible ICT Website within 12 months
3.3 Set up subsidization discounted tariff scheme for persons with disabilities to access ICTs
3.4 Promote accessible assistive technologies
3.5 Identify relevant standards applicable in Sudan and implement through NTC type approval and NIC processes
3.2 MCIT and NIC
3.4 NTC and industry
3.5 NTC and NIC
Annual ICT Accessibility report (1 year)
Accessible ICT website operational with mobile industry content (1 year)
Discounted rate and special products for persons with disabilities
Amended Type approval regulations
Putting in place measures and taking steps to promote web accessibility. Standards must be put in place to promote accessibility by persons with disabilities to online content (see section 7.3);
4.1 Implement WCAG 2.0 across government and promote awareness of web accessibility within government
4.2 Training public sector IT departments and web developers on web accessibility standards
Implement website compliance symbol on government websites (1 year)
training sessions per annum
Web Accessibility Code of Conduct
|Putting in place measures and taking steps to promote broadcasting accessibility, whether broadcasting is delivered on an analogue or digital platform(see section 7.4);||
Audio and Visual accessibility guidelines and implementation (18 months)
Putting in place measures to promote the accessibility of public access terminals, including Automated Teller Machines (ATMs), and computers in public facilities (see section 7.5);
6.1 Put in place policy that all publicly funded public access centres, including those funded by Universal Service Fund, are accessible
6.2 Develop minimum accessibility standards for public access centres
6.3 Mainstream existing public access facility which has been developed for the blind
6.4 Share minimum standards for public access with other government departments to ensure application across all ICT enables facilities, terminals and devices
6.5 Use clear statements of user accessibility needs in all calls for tender for computers in public facilities
6.4 MCIT and NIC
Published public accessibility standards based on this policy (6 months)
Mainstreamed public access facility (12 months)
|3||Promote accessible ICTs through responsible and inclusive public procurement||Putting in place measures and taking steps to support accessible procurement policies particularly for public sector organizations to give priority or preference to accessible or universal design technologies (see section 7.6).||
7.1 Review ICT procurement policies such that they promote ICT accessibility
7.2 Adopt a set of generally accepted Functional Performance Standards, preferably by referencing global standards, as they are developed, and to share these with other government agencies and the private sector through, at a minimum, its website.
7.3 Define and incorporate accessibility as an attribute in the procurement of ICTs, including as a criterion in the Call for Tender or Request for Proposals. It should include in all calls for tender the user accessibility requirements which are defined by Functional Performance Statements
7.4 Apply systematic processes to check the level of accessibility conformance of the products and services purchased
Revised procurement processes
Web Accessibility Guidelines shared, published and trained on (12 months)
ANNEX 4: Proposed amendments to existing legal, policy and regulatory documents
 World Report on Disability 2011 (World Health Organisation)
 ICF first publication was in 1999 – Last version has been published in 2001.
 Convention on the Rights of Persons with Disabilities, Preamble, Section (v)
 Section 8(1)(a) of the Telecommunication Act, 2001
 ITU has developed training materials and programmes that could support these efforts, including a national web accessibility training programme and training on public procurement of accessible ICTs. See https://www.itu.int/en/ITU-D/Digital-Inclusion/Pages/default.aspx.
 The FCC's Accessibility Clearinghouse is established in terms of the 21st Century Communications and Video Accessibility Act of 2010 (CVAA). It includes information on accessibility features of mobile phones, accessibility contacts at telecommunications and advanced communications services companies, free assistive apps for various computing platforms, and organizations implementing the National Deaf‐Blind Equipment Distribution Program. https://ach.fcc.gov
 As defined in Article 2, Convention on the Rights of Persons with Disabilities
2. International Telecommunication Union
 ISO TC159 definition at http://mandate376.standards.eu/accessible-procurement/what-ict-accessibility