best practices for providing accessibility in the mobile device industry

BEST PRACTICES FOR PROVIDING ACCESSIBILITY IN THE

MOBILE DEVICE INDUSTRY

FINAL RESEARCH PROJECT

BY

DEREK MITCHELL

CLASS 2012

1 | P a g e Mobile Device Industry Accessibility Standards

Table of Contents

Executive Summary ................................................................................................................................ 2

Introduction ............................................................................................................................................. 3

U.S. Accessibility Policy ......................................................................................................................... 4

21st Century Communications and Video Accessibility Act .................................................................. 4

Telecommunications Act ..................................................................................................................... 5

The Convention on the Rights of Persons with Disabilities ................................................................... 7

U.S. Disability Demographics.................................................................................................................. 8

Medical vs. Social Disability Model .................................................................................................... 8

Measuring Disability ........................................................................................................................... 9

U.S. Census Bureau Disability Statistics ............................................................................................ 10

Economics of Disability ..................................................................................................................... 13

Universal Design Concept ..................................................................................................................... 15

U.S. Mobile Device Industry ................................................................................................................. 17

Current Industry Best Practices .............................................................................................................. 18

AT&T- Accessibility Innovation & Sustainability .............................................................................. 18

Universal Design ........................................................................................................................... 19

Integrating Accessibility into Product Development and Value Chain ............................................ 20

Understanding Human Factors ....................................................................................................... 22

AT&T Advisory Panel on Access & Aging .................................................................................... 23

Citizenship & Sustainability Expert Team-Access and Aging ......................................................... 23

Recruitment Practices for Persons with Disabilities ........................................................................ 24

NTT DOCOMO- Universal Design Approach ................................................................................... 25

Dominic Foundation- LUCY Digital Inclusion ................................................................................... 27

Orange- Design for All ...................................................................................................................... 29

U.K. Accessibility Practices ........................................................................................................... 31

Analysis of Industry Accessibility Practices ........................................................................................... 32

Proposal for Accessibility Standards and Guidelines .............................................................................. 34

Conclusion ............................................................................................................................................ 37

Acronyms .............................................................................................................................................. 38

Bibliography ......................................................................................................................................... 39


Executive Summary

New innovations in mobile technology have drastically changed the technology and the lives of

the consumers that the industry serves. Smartphones, tablets and cloud computing have altered

the way we work, communicate, organize document and share our lives. While a great deal of

consumers anxiously await each new innovation with intense enthusiasm in some cases, some

consumers have been able to take advantage of this new technology. Adapting technology to the

needs of the disabled has usually been a development that has not kept pace with that of

technology innovation. This new wave of mobile device innovation has started another phase in

the process of providing persons with disabilities access to the world that is equal to those

without disabilities.

Providing accessibility is complex multi-faceted issues with many perspectives and

considerations. Accessibility policy, industry standards, business interest and the interest of the

disabled and aging community are all critical factors considered when approaching this issue.

Accessibility is a highly debated issue and so far all of the above have not been able to converge

to sufficiently satisfy the interest of all parties affected. As a result there is currently no set of

standard guidelines to govern how companies approach accessibility in order to best serve

disabled consumers and company business interest.

The following research will examine accessibility policy, disability demographics and concepts,

survey the mobile technology industry as a whole and provide analysis on four companies in

order to find a point of convergence as basis for an accessibility standard. Legislation has been a

driving force behind the disability rights for decades and this new challenge of mobile devices

meeting the needs of the disabled is no different. Disability demographics and concepts are

evolving changing the perception what it means to be disabled. The business world’s

perspective on disability is beginning to change as well with an increase of buying power and

population within the disable and aging population. What was once largely viewed as obligation

and compliance is now beginning to be seen as innovation opportunities and potential financial

gains. All interested parties now much reach a consensus on a way to leverage these benefits for

each side that can be adapted across the technology industry.


Introduction

The technology industry has experienced rapid innovations over the past several years changing

what consumers have come to expect to be possible from a computing device. Developments in

mobile technology have made an impact of how consumers communicate, work, shop, dine, plan

travel and activities and capture special moments of life. However, with every innovation there

are drawbacks and areas that require much improvement. The innovations in mobile technology,

while highly praised and adopted by the majority of consumers, have left several consumer

segments without the necessary applications or features to have access to that technology. The

specific segments are aging adults and persons with disabilities who lack the necessary

accessibility tools to fully leverage the use of new innovations within the mobile device industry.

Accessibility refers the measure of how useable a product is for persons with disabilities

compared to persons without a disability and the current accessibility gap is quite wide as new

technology has yet to fully conform to needs of all users.

The U.S. Census Bureau estimates that nearly 1 in 5 people have a disability equaling

approximately 57 million people. That is a large segment of the population that this often not

considered when the latest technological innovations are being developed. Meeting the needs of

this segment is actually viewed as burden by many companies. While there are policies in place

to ensure that the needs of the disabled and aging population are satisfied, there are also methods

circumventing that obligation. In many cases companies only strive to meet the minimum

accessibility compliance requirements which makes glaringly clear that there is wide disconnect

between the needs of the disabled and the commitment of the technology industry as a whole to

meet those needs.

There are of course some companies in the industry that have made a full commitment to

providing accessible products and services for its customer, however there is little continuity

amongst these companies regarding how they provide accessibility. Each has its own processes

and methodologies which meet with varying degrees of success. Standardization of accessibility

guidelines and practices across the mobile device industry is vital to more effectively and

uniformly meeting the needs of the disabled and aging population.


U.S. Accessibility Policy

The U.S. has been on the forefront of establishing policies and guidelines to protect the rights of

the disabled and elderly. U.S. policies address a wide range of accessibility issues from

infrastructure to technology requirements. The two most relevant U.S. accessibility policies

addressing mobile devices are the FCC Telecommunications Act and the Twenty-First Century

Communications and Video Accessibility Act (CVAA). The United Nations initiated

Convention on the Rights of Persons with Disabilities (CRPD) was also adopted by the U.S. in

support of a concerted global effort to address disability issues.

21st Century Communications and Video Accessibility Act

The CVAA was signed into law in 2010 in order to update federal communications law to

increase access to modern devices for persons with disabilities. Recent innovations in digital

technology, broadband service and mobile devices has made past accessibility laws subject to

becoming obsolete. The act specifically focuses on communications access and video

programming establishing the following guidelines: (9)

Communication Access:

Advanced communication products and services are required to be accessible by persons

with disabilities. Advanced communication services are defined as VoIP, electronic

messaging, and video conferencing services.

Mobile device web browsers are required to be accessible to blind or visually impaired

users (a “ramp” to the internet on mobile devices).

Establishes recordkeeping requirements, more stringent deadlines for responses to

consumer complaints, and biennial reporting to Congress.

Establishes clearinghouse for FCC on accessible communications and equipment

Expands applicability of hearing aid compatibility to telephone-like equipment used in

conjunction with advanced communications products and services.

Definition of telecommunications relay services are updated to include persons who are

deaf-blind and allow communication between various types of relay users

Grants FCC authority to pursuit action to ensure reliable access to 9-1-1 service by

persons with disabilities.(8)


Video Programming:

Video programming that is closed captioned on TV must be closed captioned with

broadcast over the internet.

Emergency information must be conveyed in an accessible manner for the blind or

visually impaired by programming distributors, providers and owners.

Expands accessibility requirements for video programming equipment to have the

capability of displaying closed captions on devices with screens smaller than 13 inches

which include portable TVs, laptops, smart phones etc. These devices are also required

to be able to convey video descriptions and emergency information that is accessible to

persons who are blind or visually impaired if technically possible and achievable.

Requires interconnection mechanisms (cables) to transmit (from source device to

equipment which includes TVs) the information necessary to allow the display of closed

captions and make video description and emergency audible.(8)

Telecommunications Act

The Telecommunications Act of 1996 was a vital update to telecommunications policy and the

first in over 60 years. The intent of the act was to eliminate the barriers to entry into

communications industry allowing for more extensive competition. Section 255 of the

Telecommunications Act was included to establish rules that require electronic devices to be

made accessible to persons with disabilities if readily achievable. In cases where accessibility is

not achievable, device manufactures and services providers must ensure compatibility with

peripheral devices and specialized equipment that is commonly used by persons with disabilities.

The FCC has also determined that VoIP providers must comply with Section 255. A consumer

guide to providing accessibility was developed in addendum to Section 255 in order to create a

framework for companies to better serve persons with disabilities. The guide covers the

following topics. (10)

Products and Services Covered by Section 255

All hardware and software telephone network equipment and customer premises

equipment (CPE) which is defined as telecommunications equipment used in the home or


office to facilitate telecommunications. This includes telephones, fax machines,

answering machines, wireless phones and other mobile devices.

The policy also covers various telecommunications services such as regular telephone

service, caller ID, directory assistance, call forwarding, call waiting etc.

Identifying Access Needs

Companies should identify barriers to access and usability by using the completing the

following task:

Engage disabled individuals when conducting market research, product design , testing,

demonstrations and product trials

Companies should develop cooperative relationships with disability-related organizations

Companies should take reasonable steps to test accessibility solutions with persons with

disabilities

Evaluating Access Needs

The accessibility, usability and compatibility of products and services must be evaluated

as early and consistently during the design, development and manufacture

Products must be reviewed for accessibility at every “natural opportunity” including

product redesigns, upgrades or significant packaging changes

Determining Readily Achievable

Companies are required to include accessibility features according to readily achievable

standard which are easily accomplished without considerable difficulty or expense.

Companies must compare the cost and aspects of accessibility required with available

resources in order to determine readily achievable in effect obligating larger companies to

achieve a higher level of accessibility than smaller companies

Readily achievable determinations are made on a case by case basis for which certain

factors are considered such as product functionality, usability of features and alterations

of product dimensions as a result of providing accessibility


The Convention on the Rights of Persons with Disabilities

The CRPD was adopted by the United Nations on December 13, 2006 with the highest number

of opening signatories in UN history. The CRPD is the first human rights treaty of the 21st

century and addresses a broad categorization of persons with disabilities and articulates the rights

of the disabled to have access to human rights and fundamental freedoms. The U.S. signed the

treaty nearly three years after its adoption, but has yet to ratify it. The CRPD is a milestone

policy because it not only condemns discrimination against persons with disabilities, but also

specifies the legally binding actions that should be taken in order to create a more enabling

society necessary to facilitate equality for the disabled. There is also a social element included in

the policy which is a new development for many parts of the world and provides a stark contrast

to the traditional view of disability. The U.S. already has policy in place to protect the rights of

person s with disabilities which is may be part of the reason why the CRPD has not been ratified

nullifying its legal enforcement, however U.S. acknowledgement of the treaty does support the

focus on international cooperation that the CRPD emphasizes.(17)

The CRPD has eight guiding principles that provide the framework for the policy which are:

1. Respect for inherent dignity and individual autonomy

2. Non-discrimination

3. Full and effective participation and inclusion in society

4. Respect for difference and acceptance of persons with disabilities

5. Equality of opportunity

6. Accessibility

7. Equality between men and women

8. Respect for the evolving capacities of children with disabilities and the right to preserve

their identity

Article 9 asserts that persons with disabilities should be enabled to live independently and fully

participate in all aspects of life. The CRPD places the responsibility on the states parties to

ensure persons with disabilities access to information and communications technologies by:

“Promoting access for persons with disabilities to new information and communications

technologies and systems, including the Internet”(20)


“Promoting 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.”(20)

While the CRPD may not yet provide any legal enforcement in the U.S., it does create a more

comprehensive perspective of disabilities and identify specific measures to be taken in order to

effectively serve the needs of the disabled population. Accessibility is a complex issue with

many factors that require careful consideration. Accessible technology alone is a very broad

issue consisting of various facets that need to be addressed in order to have an effective policy.

This issue is so broad in fact that one policy cannot effectively protect the disabled population,

but rather a comprehensive collection of policies that are able to address a range of specific

needs that affect the degree of access that persons with disabilities have to their environment.

U.S. Disability Demographics

Persons with disabilities are often underserved as consumers and in some cases left without any

access to certain products and services. One of the major causes is due to a lack of knowledge

and understanding of the needs of the disabled. Until recently the data on the disabled

population was limited to only general quantities distinguishing those who are disabled from

those that are not broken down by disability categories. The methods of measuring of disability

have become much more sophisticated and informative. Companies at one point only had

limited data to use as basis for providing accessible products and determining how to serve

persons with disabilities. This limitation led the disabled market to be viewed as a segment that

did not warrant commercial focus or attention. Now that the basic definition and attitude

towards accessibility shifting, the responsibility of serving persons with disabilities is beginning

to look like more of an opportunity than a burden.

Medical vs. Social Disability Model

The traditional medical model of disability defines a disability as a physical, mental or

psychological condition linked to a medical condition that limits a person’s activities. The

model has recently been recognized as being insufficient in providing an effective or

empowering framework in which to promote inclusion for persons with disabilities. The new


model of disability has been expanded to include the medical and social model of disability.

Mike Oliver, British author and professor, coined the term social model of disability as starting

point to reframe how disabilities were perceived, but used this idea along with the traditional

model. The social model of disability has created a different perspective on disability shifting

the focus from a medical viewpoint to one “arising from the interaction of a person’s functional

status with the physical, cultural, and policy environments.”(17) According the social model a

person disabled as a function of the interaction with the environment and a person is only

disabled when lacking the tools to have access to the surrounding environment.

This model is much more expansive than the medical model because it also takes into account

temporary disabilities caused by various circumstances such as an injury, side effects of a

medical procedure or any other situation that causes a disability as a specific moment while a

person is attempting to interact with an aspect of their environment. The social model has

provided empowerment and opportunity for the disabled population to have their needs met as

well as creating more of a responsibility of satisfying those needs. According to the social model

a person that is born disabled does not have to remain that way if provided with tools to access

their surroundings whether that be services, facilities or technology.(17) Options are created for

persons with disabilities instead of just a permanent diagnosis or label that cannot be

surmounted. Persons with disabilities are now empowered to find solutions for a lack of access

to their environment and demand that society provide them the tools necessary to narrow the gap

between any existing disability and their environment.

Measuring Disability

The traditional view of human capability labeled people as either able-bodied or disabled and did

not take into consideration that a person’s capability and capacity could potentially change

drastically during a lifetime. Generally seven human capabilities are grouped into three

categories which are: (17)

Sensory-vision and hearing

Cognitive-thinking and communication

Motor-locomotion, read, stretch and dexterity


Many people experience some form of impairment or loss of one of these capabilities during

their life for various reasons whether it is temporary or permanent. One of main and most broad

reasons for these impairments is aging. The medical model failed to recognize the loss of

sensory, cognitive or motor capability as a person ages as well as the medical advances that have

been developed to correct these impairments. Due to the lifespan of the population in develop

countries, the amount of people that will need accessibility tools and policies not only to give

them access to the world, but also protects there rights increase dramatically.

The U.S. Census Bureau was one the first government agencies to shift the disability

measurements towards the more expansive social model. The Census Bureau now uses more

functional measurements of disability in order to provide more accurate disability demographics.

The questions the bureau now asks are more related to the ability to perform certain tasks rather

than the disclosure of medical history and conditions. Aging adults that develop certain vision

impairments or suffer some measure of hearing loss would not report themselves as being blind

or deaf on a survey, but still require some accessibility technology in order to perform everyday

tasks. The new methodology uses questions regarding daily activities such as using the

telephone, a computer, or reading in order to identify disabilities.

U.S. Census Bureau Disability Statistics

The U.S. Census Bureau estimates that nearly 1 in 5 people have a disability which translates

into about 56.7 million people.(5) That is roughly 19 percent of the population was considered

to have a disability in 2010 of which half reported a severe disability. Since the last report of this

type in 2005 the overall number of persons with disabilities rose by 2.2 million and the number

needed assistance also increased.(5) While these numbers are quite staggering, they do not

provide a sufficient basis to determine what percentage of the population requires accessible

technology in order to have access to mobile devices.

A good starting point to narrow down the approximate number within the disabled population

that would likely have problems using a mobile device to begin by breaking down the population

according to categories which are sensory, cognitive and motor as well as various capabilities

and severity associated with each (see Table 1):


Category Number

Sensory 15.7 million

Vision 8.1 million

Severe 2 million

Hearing 7.6 million

Severe 1.1 million

Cognitive 15.2 million

Speaking 2.8 million

Severe 523,000

Mental function 10.6 million

Alzheimer’s, senility, dementia 2.4 million

Learning disability 3.9 million

Intellectual disability 1.2 million

Autism, cerebral palsy etc. 944,000

Other mental conditions 4.7 million

Motor 19.9 million

Ability to lift 17.2

Severe 2.8 million

Ability to grasp 6.7 million

Severe 893,000

Table 1: Disabled population by category and severity Source: U.S. Census Bureau Report

Table 1 indicates that there is an immense disabled population that may require some form of

accessibility in order to have usable access to a mobile device. The percentage of the population

with severe disabilities including blindness, deafness, severe mental and learning disorders,

inability to speak or to be understood while speaking, difficult grasping objects such as a glass or

pencil and the inability to grasp at all will almost certainly have difficulty using a mobile device

requiring some measure of accessibility.

The research the Census Bureau has done allows for more specific measurements than just the

broad categorical numbers above. Measurements regarding the daily activities are also available

to establish more of a solid basis for the need of increased accessible technology. A few


examples of the daily activities measured by the bureau are difficulty using the toilet, eating,

bathing, using the phone and dressing. While the data does not specify which type of phone the

respondents have difficulty using whether a mobile phone or household phone it is not a stretch

to conclude this pool of individuals may require specific accessibility features in order to operate

a mobile phone or other type of mobile device. The respondents who had difficulty with bathing,

toileting or eating could also have some dexterity issues that could easily translate to difficulty

operating a mobile device. Table 2 highlights the respondents with difficulties performing

certain daily activities that may also include difficulties using a mobile device.

Daily Activities Number

Difficulty using the phone 2.8 million

Needed assistance 1 million

Did not need assistance 1.8 million

Difficulty eating 1.8 million

Needed assistance 1 million

Did not need assistance 813,000

Difficulty toileting 2.8 million

Needed assistance 1.8 million

Did not need assistance 966,000

Difficulty bathing 5.5 million


Did not need assistance 2 million

Difficulty dressing 4.3 million


Did not need assistance 1.5 million

Table 2: Disability measurement by daily activities Source: U.S. Census Bureau Report

The aging adult population also had a major impact on the census data due to the likelihood of a

disability being present with advancing age groups. Those in the oldest age group, 80 years and

older were 8 times or 70.5 percent as likely to have a disability as those in the youngest group of

15 years or younger.(1) The occurrence of severe disabilities also increased with age with the

probability of being disabled at 1in 20 for people 15 to 24 and 1 in 4 for those aged 65 to 69.


The accuracy of the results for the older age groups are suspected to be a little inaccurate due to

an estimated 1.4 million of people aged 65 and older living in nursing homes.(1) The disability

rates for the older age group would certainly be higher if that population had been included in the

results.

Economics of Disability

The economic status of persons with disabilities is a vital factor in addressing accessibility.

Equal access to the workforce is a critical component of serving the needs of the disabled

population. Persons with disabilities having access to the workforce results in increased buying

power and resources for a more independent lifestyle. The current economic outlook for the

disabled population is rather disparaging when compared to the non-disabled population.

Disability is a key driver of poverty in the U.S. and of the main reasons for the need of greater

accessibility.

The U.S. Census estimates that 41.1 percent of disabled individuals aged 21 to 64 were

employed compared to 79.1 of persons without disabilities during the time census data was

provided.(1) Once again broad statistics such as these do not reveal the entire scope of the

employment issue within the disabled population. When severity of disability is considered,

what is seen is that a larger portion of adults with non-severe disabilities are employed than their

severely disabled counterparts; 71.2 percent compared to 27.5 percent. Different types of

disabilities are also accompanied by different employment rates, for example people with a

communicative disability have a higher employment rate, 73.4 percent, than those with other

types of disabilities.(1) When you compare the employment rate of people with communicative

disabilities to those with a physical or mental disability, which are 40.8 percent and 51.9

respectively, a clear indication is shown that not all people with disabilities face the same

employment challenges. (1)

There is also a disparity between the income and expected earning potential of persons with

disabilities. The median monthly income for disabled adults aged 21 to 64 is $1,961compared to

those without disabilities earning $2,724. The median income is even lower for people with

severe disabilities which is $1,577, but higher for those with non-severe disabilities earning a

median income of $2,402. The same divergence amongst disability categories that is seen in

employment rates is also indicated in income measurements. People with a communicative


disability earned a monthly median income of $2,838 which is nearly identical to that of non-

disabled persons. However, those with a physical or mental disability earned less with a

respective median income of $1,998 and $1,619. People with a combination of all three

disabilities earned $1,051 monthly.(1)

While these employment and income statistics can at first glance be considerably disparaging,

consideration of another perspective can put the economic situation of the disable into a different

light. It has been statistically proven that persons with disabilities are likely to on average earn

less than those without a disability, but that does not mean that there is an absence of purchasing

power. The way in which these types of comparisons are used is a major cause of the disabled

population being underserved. The worth of persons with disabilities as consumers is

consistently being measured as a comparison to those with disabilities and even though the

disabled earn less on average it does not make them less valuable as consumers.

The U.S. Department of Labor estimated that in 2002 the discretionary income of the disabled

market has grown to $175 billion.(4) At that time the disabled population had four times the

purchasing power of the tweens (8-14 year olds) which are heavily marketed and catered to by

businesses. According to the American Association of Retired Persons (AARP) that four million

Americans a year reached the age of 50 and people in the 50 and over age group spent nearly

$400 billion in 2003. People in this age group are also more likely to develop age-related

impairments that could affect hearing, mobility, vision, and cognition. The AARP also asserts

that due to this fact people aged 50 and over tend to patronage businesses that provide services

and products to accommodate their needs. Another study states that the 50 and older age group

comprises 25 percent of the U.S. population, but controls 50 percent of the purchasing power and

75 percent of the nation’s assets totaling $150 billion in discretionary income.(4) While these

numbers are dated, they do provide a frame of reference for a general assessment of the financial

power of the disabled population and the potential financial gains companies can realize by

better meeting their needs. It is possible to make some rough estimates of the current purchasing

power of the disabled population through the use of the U.S. Census data. Considering that

nearly 57 million persons with disabilities have a median monthly income of nearly $2,000, it

can be estimated that the disabled population has an aggregate purchasing power of over a $1.3

trillion!


Universal Design Concept

According the C.R.P.D., Universal Design (UD) means the design of products, environments,

programs and services to be usable by all people, to the greatest extent possible, without the need

for adaptation or specialized design and shall not exclude assistive devices for particular groups

of persons with disabilities where this is needed.(20) Using the term Universal Design while

addressing accessibility can cause some confusion, however the two are closely related.

Accessibility, which was previously defined, is a part of Universal Design just focusing the

disabled population. While accessibility efforts are certainly necessary to ensure the persons

with disabilities have access to products and services, Universal Design is the overarching goal

with products and services designed to not only be accessible, but usable by the most extensive

range of people possible. Accessibility and Universal Design each specific principles which are

closely related and in some cases overlap.

The term Universal Design was coined in the 1980s but popularized by architect Ron Mace who

founded the Center for Universal Design in 1989 at the North Carolina State School of Design.

His view of Universal Design was ”The intent of universal design is to simplify life for everyone

by making products, communications, and the built environment more usable by as many people

as possible at little or no extra cost.(12) Universal design benefits people of all ages and

abilities.” His pioneering work in accessible design played an instrumental role in the passage of

several pieces of legislation including The Americans with Disabilities Act of 1990. The center

which he founded and is also a part of his legacy developed seven principles of Universal

Design: (11)

Principle One: Equitable use

The design is useful and marketable to people with diverse abilities

Principle Two: Flexibility in use

The design accommodates a wide range of individual preferences and abilities

Principle Three: Simple and intuitive use

Use of the design is easy to understand, regardless of the user’s experience, knowledge,

language skills, or current concentration level

Principle Four: Perceptible information


The design communicates necessary information effectively to the user, regardless of

ambient conditions of the user’s sensory abilities.

Principle Five: Tolerance of error

The design minimizes hazards and the adverse consequences of accidental or unintended

actions.

Principle Six: Low physical effort

The design can be used efficiently and comfortably and with a minimum of fatigue.

Principle Seven: Size and space for approach and use

The design can be used efficiently and comfortably and with a minimum of fatigue

These principles of Universal Design can undoubtedly be utilized in the development of

accessible products and services as the two concepts do intersect. Applying the concept of

Universal Design early in the conceptual and developmental phase of any process will result in

accessible design and help eliminate the need for cumbersome and expensive post-production

adjustments.

The necessary steps of the Universal Design process include exploration, creation and

evaluation. The needs of persons with disabilities and aging adults must first be thoroughly

researched in order to develop a comprehensive understanding of what is needed to approach the

problem. This is a common pitfall of accessibility efforts. Delving into an accessibility project

without a fundamental understanding of how to serve the disabled population can easily turn into

an ineffective attempt that has no impact on the population. Creativity is also essential in

exploring ways to address accessibility. Thinking beyond current solutions and being able to

innovate is critical for the progression of accessible design quality as well as frequently

evaluating the effectiveness of how well the solutions are meeting the needs of the disabled

population. Universal Design maybe a separate concept, however when properly applied the

results can be leveraged in the development of accessible solutions. G3ICT’s e-Accessibility

Policy Handbook defines accessibility as the extent to which persons in a society can live

independently and participate fully in all aspects of life. According to the handbook an

accessible product has the following features: (17)

Utility- extent to which product provides functionality to meet user needs


Usability- extent to which product can be used a specific user to achieve specific goals

Accessibility- extent to which is usable to persons with widest range of abilities

Desirability- extent to which ownership and uses leads to satisfaction

Affordability- extent to which the perceived value of the product is greater than its cost

Viability- extent to which the sales of product achieves success for the company

Compatibility- extent to which the product works with other devices and conforms to

current standards, guidelines and laws

U.S. Mobile Device Industry

The mobile device is defined as the manufacturing of mobile phones, wireless communicators,

handheld computers, and portable media devices.(2) This industry has received a tremendous

boost in the last few years due to major innovations in smartphone and tablet technology. The

total revenue of the technology industry as a whole was $625 billion in 2010 and while it is

difficult to distinguish the portion of that revenue that can be attributed to mobile device sales, it

is safe to say that those sales have an impact.(21) Devices such as Apple’s iPhone and iPad,

Samsung Galaxy smartphones as well as other devices selling millions of units at price points

upwards of $800 have definitely added new life to the technology industry and the enthusiasm

for the industry’s products. The current status of technology usage and concentration in the U.S.

currently stands as: (7)

Telephone-main lines: 150 million

Telephones-mobile: 270 million

Internet users: 231 million

DOI: 0.66

The DOI or Digital Opportunity Index is used to evaluate a country’s overall information society

according the standards of opportunity, infrastructure and utilization of Information and

Communication Technology (ICT). The rankings are on a scale between 0 and 1, currently the

U.S. ranks 20th below Germany.(6)


Current Industry Best Practices

As a whole the technology industry maybe quite a distance from developing standard

accessibility guidelines and methodologies, but there are certain companies that are giving their

disabled and aging consumer base superior products and services. While many companies

consider accessibility a burden and seek methods of circumventing the responsibility of

expanding the inclusion of products, other companies such as AT&T, NTT DoCoMo and Orange

have integrated accessibility in their respective corporate cultures. These companies have

realized that the accessibility of their products cannot reach its full potential in isolation or be

developed in silos. Another differentiating factor of these companies is the perspective they

have developed with regard to accessibility. These companies have recognized the opportunities

that accompany accessibility initiatives which include innovation, an expanded consumer base

and increased goodwill. AT&T and Orange both stated in case studies the benefits on making a

commitment to accessibility which include cost reductions in making devices accessible and

developing a core competency in serving the disabled consumer market. The previously

mentioned companies have been able to create a sizeable differentiation in their accessibility

efforts by thoroughly scrutinizing and documenting their methods. These companies were

chosen for analysis because they were among the few companies to actually have available

documentation of its accessibility approach.

AT&T- Accessibility Innovation & Sustainability

AT&T is one of the best examples of a company that has fully embraced accessibility. They

have developed a methodology to provide their disabled and aging consumers with the best

products and services possible. Accessibility has become embedded into

the AT&T company culture across multiple divisions and business units

because it is understood that accessibility at its best doesn’t stop with the

addition of features on a product or service. A G3ict case study

published in 2011 documented AT&T’s process of establishing a

foundation of accessibility in core values of the company. AT&T integrated accessibility into all

areas of the company’s value chain from product development to customer service. The specific


areas in which AT&T excels to provide quality products and services to its disabled and aging

consumer base are the following: (13)

Recognizing the benefits of accessibility

Developing a standard Universal Design methodology applicable to all products and

services

Integrating accessibility into early stages and throughout product development

Embedding accessibility into the company culture including employee recruitment

Creating panels to obtain input and feedback from consumers and employees

Conducting research to understand disabled and aging market demographics

Leveraging advancements in all company products lines in order to make accessibility

improvements

Making Universal Design methodology available to suppliers and third-party developers

At the heart of AT&T’s accessibility initiatives is the company’s recognition of the benefits that

go along with addressing accessibility. As a matter of fact Alexander Graham Bell’s invention

of the telephone grew out of his attempt to develop the first hearing aid. If such a monumental

invention such as the telephone grew out such an early accessibility attempt, just think what

other innovations might result as a byproduct of current accessibility initiatives. Accessibility

has permeated all aspects of AT&T’s value chain and made an impact on the company on

multiple levels from the employees to executive leadership.

Universal Design

Universal Design is a pivotal factor in the company’s strategy to design its products and

services to the usability of its aging and disabled consumer base. However, AT&T has a

larger goal with the company’s Universal Design strategy of making its products,

services and application available to the widest range of consumers possible considering

various circumstances as well as physical, sensory and cognitive limitations. The word

disability usually refers to a long-term life altering impairment, but situations that bring

about short-term impairments are usually not considered in this scope. In reality one

mishap or accident is all it takes to cause a disability whether it is an injury or side effects

of a medical procedure at some point a person that is not permanently disabled may also

be in need of some type of assistive product. Making a product accessible to those with


disabilities may inadvertently lead to that product being more accessible to other is one of

the key ideas of AT&T’s perspective on Universal Design. There are several examples

of mobile device features that provide accessible use for persons with disabilities, but

also provide for convenience for those without disabilities. One of those features is

vibrating features that assist users with hearing loss and also allow prevent another user

from causing a distraction in a quiet environment when receiving a call. Another feature

is talking caller ID which is essential for a user with vision loss, but can also alert a busy

user with perfect hearing exactly who is calling providing the option of not interruption

themselves to discover who is calling.(13)

AT&T has also looked beyond its internal operations and collaborated with its suppliers

in order to push its Universal Design methodology. The company made this information

available to persuade the companies to shift more focus on the needs of the aging and

disabled consumer and also in hopes of developing innovations as a result of new joint

developments.

Integrating Accessibility into Product Development and Value Chain

The usual approach that many companies take to accessibility is to develop a product and

post-production develop methods of making the product accessible. This often means

developing accessories, application or services that must then be created for compatibility

with the specification so the device. Retrofitting a product for accessibility is not always

possible and can be exceptionally costly when possible. AT&T has taken the approach of

addressing accessibility from the early stages of product development and throughout to

ensure that the product meets the needs of its disabled and aging consumer to fullest

extent.(13)

While many companies may develop accessible products and include the process

involved into the product development to an extent, the marketing of these products is

lacking in many cases. The problem that often causes this gap between development and

marketing is the motivation of a company to develop an accessible product which is often

for compliance. AT&T’s purposes for investing in accessibility reach far beyond

compliance to the possibilities of innovation and developing a competitive edge. This is

why the company’s advertising and customer service have also been focused on the


meeting the needs of the aging and disabled. AT&T developed an advertising campaign

to highlight the accessibility features of the company’s products providing detailed

descriptions of the exact benefits to the aging and disabled consumers. This also

presented an opportunity to enhance the accessibility of the advertising by person with

disabilities. For example, since 2007 nearly all of AT&T’s commercials have been close

captioned and company ads have also been run in publications focused on persons with

disabilities to have the widest possible in advertising the company’s accessibility

efforts.(13)

Accessible customer service has also been a major focus of AT&T’s Universal Design

strategy. The principle of making customer service available to widest possible range of

consumers accommodating the various possible circumstances stretches beyond

accessibility, but also includes it. The focus is not to just make customer service

accessible to compensate for physical, sensory or cognitive limitations, but also to cater

to different preferences of doing business. Whether a customer wants to call to have a

problem resolved, chat with a representative online, consult a FAQ sheet or visit a retail

location; AT&T wants to provide options to meets consumer needs and preferences.

However, specifically serving the needs of the disabled has been a long-standing priority

of AT&T since the opening of the first call center focused on disabled customers in 1978.

Since then the AT&T National Center for Customers with Disabilities (NCCD) has been

created to handle requests and questions regarding products and services. This center is

based in Baton Rouge, LA and is staffed by customer care personnel who have received

training on accessible products and services as well as being trained to address certain

needs of disabled and aging customers. While these efforts are admirable steps to better

serve their consumers, the realization that providing the best accessibility customer

service could not be provided in silos soon set in. AT&T set out to train more of its

employees in disability awareness in 2009 in order to spread the commitment to

accessibility throughout the company in order cement it in the company culture. This

involved developing a 45 minute instructor-led course or self-paced e-learning program

which covers: (13)

Disability definitions and demographics


Section 255 of the Telecommunications Act

Interaction and communication with persons with disabilities

Understanding accessibility requirements regarding mobile phones and

wireless services

To date more than 160,000 AT&T employees have completed the training and company

leaders agree that the program has benefitted the company competitively.

Understanding Human Factors

AT&T takes a user-centered approach from product inception to production to achieve

this. Taking time to understand the usability of the products and services from the

consumer’s perspective has given AT&T an advantage over the competition in serving

persons with disabilities. The Human Factors Group was created in order to study and

better understand the aging and disabled consumer demographics as well as the products

and services being offered. The accessibility design process is iterative and aging

consumers as well as those with disabilities are invited to take part in the group’s studies.

AT&T frequently works with NGOs to obtain recommendations and feedback on product

accessibility. The overall goal of the group is to help create product development process

that leads to the technology conforming the needs of the consumers during production

rather than afterward. AT&T believes that technology should adjust to user instead of the

user having to adjust the technology.

The team that makes up the Human Factors Group is taken from various business units

within the company which bring different insights, product knowledge and experience to

the process. The diversity within the team also allows product developments in different

areas of the company to be utilized in developing accessibility solutions as well as

applying those solutions to various product lines. AT&T has also created other panels

and teams in order to obtain valuable feedback and input which include: (13)

The AT&T Advisory Panel on Access & Aging (AAPAA)

The Citizenship & Sustainability Expert Team-Access and Aging

Developing an employee base including persons with disabilities


AT&T Advisory Panel on Access & Aging

Seeking input from the disabled and aging community is not a new process for AT&T,

but the input has had several iterations such as the Wireless Access Task Force (WATF)

and secret shopping with the cooperation of community organizations. The latest

iteration of this process is the AAPAA which meets three times a year with key staff from

the company’s major business divisions to discuss issues and provide recommendations

that make an impact on consumers and employees. The issues that the panel addresses

include emerging and usable technologies, current products and services, customer

service, strategic marketing and employment issues. The work being done by the

AAPAA is partly a continuation of the efforts of the WATF which consisted of aging

adults and person with disabilities meeting with AT&T official in order to provide input

and feedback on the company’s wireless business practices. The WATF also had the

opportunity to meet with handset manufactures which is also a part of the company’s

efforts to involve the suppliers in accessibility initiatives. The panel was very productive

during its existence contributing to the development of several accessible products and

services including a telecommunications device for the deaf or TTY, hearing-aid

compatible devices and network-based voice dialing.

Citizenship & Sustainability Expert Team-Access and Aging

The Citizenship & Sustainability Expert Team on Access and Aging has more of an

internal focus than the AAPAA seeking cooperation in the company’s accessibility

efforts across units and business divisions of AT&T. The team is made up of employees

who spread the message of the necessity of accessibility throughout the organization to

bring the issue to the forefront of all aspects of product and service developments,

deployments, customer management as well as internal policies and employee

recruitment practices. At AT&T accessibility is just a part of broader issues such as

sustainability which is also core focus of the team as seen by the title of the panel. The

overarching purpose of the panel is to bring together representatives within the company

who drive various aspects of sustainability which includes imperative accessibility

initiatives that fit into the company’s efforts to be a good corporate citizen. According to

the Director of Public Affairs for Corporate Citizenship and Sustainability, Roman Smith,

“fostering an inclusive workplace and offering customers with disabilities products and


services that support them to live more sustainable and independent lives” is an integral

part of that goal.(13) Some of the key projects of the Expert Team on Access and Aging

include advocating and providing support for awareness and competency training for

hundreds of thousands of employees across all division of the company. The team also

conducts briefings between AT&T divisions regarding product and service innovation

providing key information necessary for product adjustments for aging and disabled

consumers.

Recruitment Practices for Persons with Disabilities

Recruiting and providing career opportunities for persons with disabilities is another

internal effort by AT&T to provide the best accessible solutions for its customers by

giving representatives of the disabled community a solid presence within the company.

What better way to show a commitment to meeting the needs of a consumer segment than

having a workforce that is representative of those consumers and providing them with a

voice to influence change from within the organization. AT&T has developed alliances

with several programs to spearhead these recruitment efforts such as Career

Opportunities for Students with Disabilities (COSD), The Washington Center, which is

collaboration with historically black colleges and universities (HBCU) supporting

students with disabilities and a customer care program staffed by U.S. veterans with

disabilities. AT&T has also invested in the development of employees with disabilities

by co-founding the UCLA Anderson School of Management’s Leadership Institute for

Managers with Disabilities. To assist employees in satisfying their work commitments,

the Integrated Disability Service Center was created to give disabled employees the tools

necessary to be successful at AT&T. The center provides disabled employees with work

restrictions, accommodations to assist in job performance, and consideration for

temporary work assignments as needed.(13)

AT&T serves as a great example within its industry as well as outside as a company that fully

committed to inclusive practices. From product development, marketing, customer service and

employee recruitment to reshaping the company’s corporate culture; AT&T has made

accessibility an essential component of its business practices throughout the organization.

AT&T has advocated for accessibility internally and also beyond the boundaries of the company


in to order bring the necessity of addressing this issue and those affected by it to the forefront.

While AT&T’s accessibility model is not yet seen on a broad scale within the industry, it does

provide a hopeful example of the impact a company can make when its resources are committed

to fulfilling it responsibility to the community that supports it.

NTT DOCOMO- Universal Design Approach

NTT DOCOMO is Japan’s leading mobile provider of voice, data and multimedia services.

DOCOMO has over 60 million subscribers making it one of the world’s largest mobile

communication providers.(18) The company is also providing one of

the world’s best examples of serving the disabled population.

DOCOMO has embraced this market at all levels of the company

providing accessibility in its products, services and retail stores.

However, DOCOMO has not only made a commitment to accessibility,

the company has made an overall commitment to universal design and

providing access for all. DOCOMO’s universal design culture and company actions have a

foundation in that initiative which has been dubbed “DOCOMO’s Hearty Style”.(18)

One of the products of the company’s universal design culture is the DOCOMO Hearty Plaza.

The plaza, designs and the services offered at the location in downtown Tokyo were all

developed in conjunction with universal design experts and persons with disabilities. The

services offered at Hearty Plaza include instructions on mobile phone usage for customers with

vision and hearing disabilities, sign language staff, accessible counters and toilets. The sessions

are designed to give the customers comprehensive demonstrations on various tasks such as

sending e-mails, making video calls and messaging.(18) DOCOMO has also focused on the

design of its retail locations and invested considerable effort into creating barrier-free stores.

The barrier-free store layouts include such features as priority disabled parking, wheelchair-

accessible restrooms, store openings with wide passageways and sloped ramps and a number of

other features that make the locations more accessible. DOCOMO had a total of 217 barrier-free

stores as of March 2007.(18)

DOCOMO has well defined standards and guidelines concerning the design and development of

its mobile devices. The company’s product development process is founded in a set of concepts


that embody the DOCOMO’s universal design culture. The product development concepts are:

(18)

Usability: Ensuring the mobile phone functions are easy to use and understand

Accessibility: Pursuit of accessibility and expansion of consumer base regardless of age

and capacity (Raku-Raku Phone)

Interface: Usability limits on mobile phone technology requires bridge to external

systems

Adaptation: Able to provide dedicated services to customers through third party devices

and services

DOCOMO also created a set of mobile phone universal design principles in order to optimize the

usability of the devices. The company’s five universal design principles are:

1. Easy access of information

2. Product lineup with good design at a reasonable price

3. Features responsible to individual needs

4. Understandable and usable user interface

5. Consistent user interface to keep away miss-operations

The Raku-Raku phone, which is specifically designed for seniors, is the

product of DOCOMO’s product development and universal design

principles. The ease of use of the Raku-Raku phones is due to three of its

essential functions which are the large screen and letters, one-touch dial

buttons and a voice reading function. The versatile voice reading function

is able to be utilized to access mail and operation menus, but also web

content. This feature has led to 80 percent of the visually impaired

population of Japan to using the device. As of 2009 DOCOMO has released 14 versions of the

Raku-Raku phone that each has certain level of technological sophistication ranging from simple

calling and texting features to e-wallet applications and digital TV functions. The Raku-Raku

mobile phone series has become a successful product line with 15 million units sold as of

2009.(18)


NTT DOCOMO is a great example of a company that made a commitment to accessibility

throughout its organization. Achieving accessibility through universal design is not just a task

for the DOCOMO; it is part of the company’s culture. This commitment can be seen in

DOCOMO’s mobile devices, services offered including special disability discounts, Braille user

materials, barrier-free stores and the Hearty Plaza. Incorporating accessibility into the company

from the development phase to the point-of-sale terminal in its stores has been a driving force in

DOCOMO serving its senior and disabled customers. The success that the company has realized

as a result of its efforts should serve as a model for the industry.

Dominic Foundation- LUCY Digital Inclusion

The Dominic Foundation is a Switzerland based charitable NGO that promotes, supports and

finances technological projects that are focused on ICT

development to improve the life and increase the

independence of persons with disabilities. One such

project is the LUCY Digital Inclusion initiative. LUCY is

a comprehensive methodology, approach and tool dedicated to improve accessibility.(3) The

project was named LUCY in reference to the fossil of the same name which is the first

discovered hominid to walk erect. This name symbolizes a focus on human oriented design and

technology. The Dominic Foundation is a different than other for-profit companies that were

analyzed for this research due to its primary focus being to serve the need of the disable

community.

The primary objective the LUCY project is to provide internet access and accessible e-content to

all people irrespective of age, economic standing or capabilities. Providing consistent and

affordable access to ICT services, to people who would otherwise not have access, through a

cloud based infrastructure is the LUCY project will accomplish this goal. This project is

especially focused on particularly vulnerable groups such as persons with disabilities and a result

the LUCY platform is fully accessible, meeting international standards and universal design

principles. Four areas, critical mass, technology, standards and sustainability, had to be

addressed during the development of this technology in order to better ensure the success of the

project.(3)


Critical mass: A lack of critical mass is major cause of failure for past digital inclusion

projects and the factor had to be vital consideration from the beginning as well as more

business focuses approach.

Technology: The LUCY project encompasses state of the art and accessible cloud based

technology that reduces cost and reduces deployment time. The reduction of time

constraints and cost is major component of providing accessible solutions and this project

is exemplary of both. A cloud bases platform allows for infrastructure centralization and

optimization which allows one technological center to serve regions in the geographical

area. The accessibility features of the platform provide the best assistive technology in

one web browser toolbar giving full access to persons with disabilities. These features

can also be enabled on smartphones and tablets providing full and free mobile access.

Standards: In order for this technology to reach its optimal level a standard approach and

methodology must be developed. Technological standards must also be established in

order to ensure the quality of the tools and services. The implementation of the LUCY

digital platform must also be standardized in order to create baseline process that can be

applied to various regions during localized implementation.

Sustainability: This is the key factor to any accessibility initiative to guarantee its long

term survival and effectiveness. Reaching a critical mass with LUCY premium services

are essential the sustainability of the platform by generating operating revenue.

A standard approach to implementing the LUCY Digital Inclusion platform is necessary when

localizing the technology in various areas of the world to create a standard of quality to meet

different economic, social, cultural, regulatory and accessibility needs. The Dominic Foundation

has chosen Public Private Partnerships with international organizations as well as local

governments and organizations to achieve successful localization. The cloud based format along

with standardization allows for cost reductions to users and the LUCY project. Users avoid

hardware, software licensing and service cost by only purchasing what services are needed while

deployment costs are significantly reduced by the avoidance of infrastructure cost and

implementation time reductions.(3)

The vision of LUCY is to provide innovative ICT to those who have had limited or no access to

technology. E-accessibility is defined as the measure of accessibility of a computer system to all


people regardless of disability or severity of impairment.(3) The LUCY project strives to

provide open e-accessibility to people of various age, ability, income, language, location and

knowledge. One facet of the LUCY strategy is to use existing infrastructures such as

government building, schools and office building as community centers by converting them with

low-cost internet and accessible computer equipment. While LUCY maybe be sponsored by a

charitable organization, the program itself is not a charity or philanthropic experiment, but based

on a new business model.

Orange- Design for All

Orange is key brand for France-telecom, one of the world’s leading telecommunications

companies. The company is one of the main European mobile providers

with over 169 million mobile customers in 33 countries.(14) Orange has

embraced the responsibility that accompanies serving such an immense

number of customers. Accessibility has been made a major priority within

the company and the efforts that Orange has made to meet the needs of their

disabled and aging adult customers are definitive proof of that commitment. The comprehensive

documentation of its accessibility initiatives through case studies and presentations is also an

undertaking that sets Orange apart from other companies. Orange has taken a strong stance for

accessibility advocacy internally and externally with its partners and suppliers in order to

integrate the principles into all aspects of the company including product development,

distribution, marketing, customer service, community outreach and industry partnerships.

Orange took a fresh and comprehensive approach to meeting the needs of its disabled and aging

customers by defining what accessibility would be for its company as well as the potential

impact. According to Orange accessibility is: (15)

“The fact a product can be used by all and any of our customers

A forward-looking process with a simplification of access, great economy, a straight-

forward use

A duty and an opportunity for all the employees: be performant and take in account the

needs of the elderly people (brand value, innovation…)”


Orange also identified what the potential impact of making a commitment to accessibility could

have on the company. This list of the areas of the company which could be affected were

labeled the stakes of accessibility which include: (15)

“Introduce a differentiation versus our competitors, by addressing a huge market

including the ageing population

Avoid specific cost adaptations and legal adaptations by integrating a total accessibility

up-stream (Design for all)

Increase use and loyalty: a better proximity with our customers

The opportunity to sell <<life services>> by our sales force and to give more to society

than just a product”

With these stakes depending on the company’s response to its customers accessibility needs,

Orange initiated its Design for All strategy. This strategy was also in response to market

research that concluded 48 percent of the population over 50 in Europe was unsatisfied the

mobile products and services available. Orange’s Accessibility Department Group is charged

with driving this strategy and producing results that are effective companywide. The Group

approaches these challenges in four areas which are adapting products and services, creating a

tailored distribution network, integrating accessibility into all processes from design to marketing

and partnering with institutions, organizations and customers to more accurately identify their

requirements. The efforts of Group serve to drive the overall accessibility vision and its five

main priorities: (19)

“Integrate the accessibility in the conception of Orange’s offers

Creation of an adapted range of products for elderly and disabled persons (fix, mobile,

internet, television, accessories)

Develop a dedicated distribution channel with training program

Web accessibility; apply all our knowledge on the mobile…

Information, communication and partnerships”

The practical applications of the Design for All strategy are founded on usage feedback from

disabled and aging adult customers. The Group’s R&D accessibility project focuses that

feedback into developing mechanisms to integrate persons with disabilities and aging adults who


experience difficulties using communications tools into various population groups. The goal is

to develop new method of device interaction and interfaces to leverage existing sensory and

perception skills. This research will lead to a range of products Orange has designated

Autonomy offerings to cater to each type of disability including: vision, hearing, speech,

mobility and cognition. In addition to developing this technology Orange also publishes a

catalog to ensure that the disabled customers have access to the products.

The catalog is just the first step in Orange’s dedication to making its accessible technology

available to its customers. The company has created a specialized distribution network catering

to the special needs of its disabled and aging customers giving full access to Orange products and

services. This multi-faceted distribution network includes: (19)

6,000 salespeople and 750 advisors specially trained in Autonomy offerings and dealing

with the disabled

231 Autonomy shops and four Rainbow areas which are openly accessible to disable

customers

A dedicated customer service center for persons with disabilities

Enables customers to contact specially trained advisors in French sign language or real

time text

In order to develop these types of products and services Orange embraces new ideas to

constantly improve the manner in which the company meets the needs of its disable customers.

The Group participates in several accessibility organizations and functions including large

corporation’s accessibility club, international groups such as the European Commission and

major accessibility exhibitions such as the U-Enabling Mobile Summit organized by G3ict.

Orange’s deep involvement with the accessibility community and development of a

comprehensive accessibility knowledge base filters down to its employees through regular

presentations to the Group’s members.

U.K. Accessibility Practices

Orange’s response to the needs of the disabled and aging adult community as well as other

telecommunications providers in the U.K. were a result of the Disability Discrimination Act of

1995 (DDA). The policy placed obligations on providers to make adjustments to goods, services


and facilities offered to persons with disabilities. The DDA also embraced the expansive social

disability model by defining a disabled person as someone who has a physical or mental

impairment which is substantial, adverse and long term that inhibits their ability to perform

normal daily activities.(16) A good practice guide was developed in order to assist companies in

compliance with regulations. The guide focused on eight areas in which providers needed to

adhere to in order to be compliant and better serve disabled and aging customers. These areas

are: (16)

1. Making reasonable adjustments

2. Examples of reasonable steps providers must take to make services accessible

3. Communicating with customers

4. Staff training

5. Examples of reasonable steps providers must take in relation to policies, procedures and

practices

6. Retail Environment

7. Refusal to serve

8. Commitments from the DDA Code of Practice

The DDA was repealed in 2010 with the Equality Act which consolidated all U.K. anti-

discrimination law into one comprehensive policy. The progress that the policy prompted in the

improvement of the products and services for the disabled and aging adults is a lasting impact

that is evident in the practices of companies such as Orange.

Analysis of Industry Accessibility Practices

AT&T, NTT DOCOMO, the Dominic Foundation and Orange are all great examples of

companies that have met the challenge and responsibility of providing better products to disabled

consumers. Each of these companies has devised its own methodology and practices to address

accessibility, but can any of these practices be called best practices? While these methods may

work for these companies, are they applicable to other companies across the technology

industry? The ADA set a strong precedence for accessibility standards of telecommunications

technology. The technology which was subject to the policy at that time had already reached a

maturity level in its product lifecycle and did not have the immediate potential of rendering the


policy ineffective. Recent innovations in mobile technology have forced policy makers to

reassert their efforts to protect the rights and independence of the disabled community.

Likewise, manufactures and service providers have been obligated to develop new practices to

extend accessibility to new technology. These new practices are evolving just as rapidly as the

technology that it governs and there is still much work to be done in order to solidify a standard

for best practices. There was not even a broad industry accessibility case study as a basis for this

research, only company specific information that was internally initiated.

Regardless of a lack of research, there are certain factors to providing accessibility that have

become intuitive for many companies and should be for the industry as a whole. Any best

practice regarding accessibility will be developed in conjunction with the disabled community.

The slogan of the disabled community is “nothing about us without”. Orange refers to its

approach to accessibility as empathetic because it involves a wide range of partnerships within

the disabled community and every effort the company makes to serve disabled and aging

customers is done their input. How can a company effectively serve a customer whose needs

they are unfamiliar with? It simply cannot. Quite a few companies have realized this and

adjusted their approach to accessibility accordingly while so many others have not. Involving

the disabled community in the development of products and services specifically designed to

meet their needs is essential. The disable and aging adult consumers differ from other segments

in some ways. This group has specific needs and there are guidelines in place to ensure that

those needs are met. They know what they want and expect companies whose products they

purchase to accommodate those expectations. When developing products for consumer groups

who have no clear vision of the role product innovation will play in their lives, it is much easier

to steer consumers to adapting to technology as opposed to the technology adapting to them.

This is not the case with disabled and aging adult consumer group and any efforts to serve their

interests without their input will likely be rejected with the phrase "nothing about us without us".

Another critical factor to addressing accessibility is early adoption and entrenchment.

Accessibility cannot be an afterthought. It must be represented in every stage of product

development and have a solid foundation in the company structure. Addressing accessibility in

the early development phase reduces the cost and increases the effectiveness of accessibility over

adapting or retrofitting a product to make it accessible after it has already been manufactured.


Once again, the consumer should not have to adapt to the technology, but rather the technology

adapt to the needs of the user. Accessibility must be also be a factor throughout the development

of a product to marketing, distribution and customer service as well as across business units to

ensure that every facet of a customer's experience with product is made accessible. AT&T and

NTT DOCOMO do an exceptional job on embedding accessibility concepts into multiple facets

of the companies. While AT&T has a department that specializes in accessibility, employees

companywide receive accessibility training because AT&T understands that truly effective

efforts to serve the disabled community cannot happen in isolation within the company. NTT

DOCOMO has a universal design approach for all products and services which make designs

that are usable for widest possible range of consumers a priority from preliminary design in the

development process to distribution in retail locations. The success that AT&T and NTT

DOCOMO have had in providing accessible solutions to its disabled customers is a testament to

how much effort and commitment it requires. Accessibility must become a company value that

is present from the first idea for a product to the sale terminal and beyond to claim the level of

success these two companies have experienced with the disabled consumer.

The third essential factor to providing accessibility is creating a company culture that is

reflective of the consumer base. If a company aims to tailor certain products to meet the needs

of a diverse consumer market, one of the fundamental steps is to develop an employee base that

is representative of that market demographic. A company requires internal advocates at various

levels raising awareness throughout the company regarding accessibility and to create a level

sensitivity to the needs of the market that is the target of company efforts. The phrase “nothing

about us without” once again is applicable because how can a company serve the disabled

community without the willingness to allow them to have a voice within the company.

Proposal for Accessibility Standards and Guidelines

Throughout the technology industry there are various sets of practices that exist to serve the

disabled and aging adult consumer. These practices exist for some companies in order to satisfy

a compliance standard and for others to provide the most accessible offering to the customers by

taking extra steps to meet their needs. The creation and adoption of industry-wide standards,

which is currently lacking, would lead to best practices amongst companies to offer their best


accessibility solutions instead of minimum compliant efforts. The following recommended

guidelines are based on the previously stated accessibility factors and are intended to establish a

basis for standard best practices for providing the most effective accessibility solutions for the

mobile device industry.

1. Internal or external audit of accessibility initiatives

The first step for any company to provide the most effective accessible products and

services is to take an inventory of its current practices. Until a company has assessed if

its current efforts are effective it will be difficult to expand existing initiatives or develop

new ones with any certainty of success. Every step in a company’s accessibility

approach must be heavily scrutinized whether it by facilitated by outside consultant or

internal audit team.

2. Engaging the disabled and aging adult community

The involvement of persons with disabilities and aging adults is a necessity in meeting

that group’s needs. The company needs to develop partnerships not only with

consumers, but also accessibility organizations and government institutions.

Accessibility should be a convergence of consumer input, policy compliance and recent

develops in accessible ICT. The involvement of the disabled community should also be

internal within the company’s workforce. The target market should be represented in the

company to give the company more of a stake developing technology that could possibly

assist its employees in their job performance.

3. Embed accessibility in company culture

Accessibility must become a company value in order to be effective in serving the

customers and genuinely understand their needs. Implementing a staff training program

to raise awareness regarding accessibility and educate employees about specific needs of

the disabled and aging would be effective. Emphasizing the importance of embracing

accessibility at all company levels is critical to understanding how accessibility is

connected to all facets of a company.

4. Include accessibility throughout company value chain


Consideration for accessibility throughout the development of a product or service is vital

to usability for and the reception from the disabled and aging adult community. Early

development stage accessibility focus contributes to cost reduction and effectiveness of a

product as opposed to late stage or post-production retrofitting. Building accessibility

into a product from inception will significantly increase its usability. However,

accessibility cannot stop with the manufacture of a product, it must continue through the

value chain. Disabled and aging adult customers will also need access to accessible

marketing tools to inform of the product’s existence, distribution methods to purchase

and obtain the product and specialized customer service options to have access to

assistance when needed. Accessibility must be a priority end to end on the value chain in

order to create the best access solutions for products and services as well as providing the

best value for the customer.

5. Focus on universal design

Accessibility and universal design are separated by a thin parameter which can cause

some confusion. Universal design is broader principle that includes accessibility. Some

companies that focus on accessibility also incorporate universal design principles into

product development in order to expand the access to their products past disabled users to

consider the widest possible range of people as potential users. Focusing on universal

design has been demonstrated to also result in increased accessibility for the disabled and

aging adult consumers. Making accessibility a priority is a necessary and noble effort,

but expanding the design principles to focus on the widest range of age groups, cultures,

and economic status ensures the development of a product to its fullest usability potential

as possible.


Conclusion

Accessibility for new mobile technology has become a major demand for the disabled and aging

adult population as well as a critical responsibility for the technology industry. Companies do

have some options regarding the manner in which accessibility is approached. Accessibility can

either be seen a compliance obligation or an opportunity. There are examples of companies on

both sides of that choice approaching accessibility with varying degrees. Companies that view

accessibility only as an obligation and a burden seek to satisfy the requirement of policy that

prohibit excluding the disabled from the use of its products and services. However, there are

companies that have recognized the benefits of embracing accessibility and have accepted the

challenge with optimism for how the results will impact their business.

Four companies were analyzed, three for-profit and one non-profit, with the intent of discovering

some commonalities among their individual approaches to accessibility. These companies have

made a full commitment to accessibility throughout each level of their organizations. While

each has a unique approach to serving the disabled and aging adult consumers, there were three

factors that each had in common which are:

Partnering with the disabled and aging community

Integrating accessibility throughout the company value chain

Embedding accessibility into the company culture

These factors are at the core of each initiative these companies took to provide accessible

products and services to its customers. Embracing these three values have made these

companies examples within the industry and allowed them to each develop a set of best practices

to guide future accessibility efforts. There is not currently an industry-wide best practice guide

to set all products and services to a standard of quality for accessibility. In the absence of such

guideline AT&T, NTT DOCOMO, Orange and the Dominic Foundation can easily serve as

examples of how to successfully provide accessibility and becoming a more formidable company

for doing so.


Acronyms

AAPAA-Advisory Panel on Access & Aging

AARP- American Association of Retired Persons

ADA- Americans with Disabilities Act

CVAA- Twenty-First Century Communications and Video Accessibility Act

C.R.P.D.-The Convention on the Rights of Persons with Disabilities

DOI-Digital Opportunity Index

DDA- Disability Discrimination Act of 1995

FCC-Federal Communications Commission

HBCU-Historically Black Colleges and Universities

ICT-Information and Communication Technology

NCCD-National Center for Customers with Disabilities

U.D.-Universal Design

VoIP- Voice over Internet Protocol

WATF-Wireless Access Task Force


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best practices for providing accessibility in the mobile device industry

Technology

accessibility policy

mobile technology

video accessibility

new technology

disabilities access

recruitment practices

disability demographics

measuring disability