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

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

1|Page Mobile Device Industry Accessibility Standards

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 21 st
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):

10 | P a g e Mobile Device Industry Accessibility Standards

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


Bibliography
1. Brault M., “Americans with Disabilities: 2010”, Household Economic Studies, July 2012.
2. Datamonitor, “United States Mobile Device Industry Market Profile, January 3, 2002.
3. The Dominic Foundation, “The Next Generation Technology and e-Services for a
Sustainable and Accessible Digital Inclusion”, LUCY Digital Inclusion, 2011.
4. Extract of <<Customer with Disabilities Mean Business>>, http://www.ada.gov/busstat.htm
5. Extract of <<Nearly 1 in 5 People Have a Disability in the U.S. Census Bureau Reports>>,
http://www.census.gov/newsroom/releases/archives/miscellaneous/cb12-134.html
6. Extract of <<Digital Opportunity Index>>, http://www.itu.int/ITU-D/ict/doi/index.html
7. Extract of <<G3ict United States Country Profile>>,
http://g3ict.org/resource_center/country_profiles/country_profile_-
_United_States_Of_America
8. Extract of <<Twenty First Century Communications and Video Accessibility Act>>,
http://www.fcc.gov/encyclopedia/twenty-first-century-communications-and-video-
accessibility-act
9. Extract of <<21st Century Communications and Video Accessibility Act of 2010>>,
http://www.fcc.gov/guides/21st-century-communications-and-video-accessibility-act-2010
10. Extract of <<Telecommunications Act of 1996>>, http://transition.fcc.gov/telecom.html
11. Extract of <<Center for Universal Design: The Principles of Universal Design>>,
http://www.ncsu.edu/project/design-projects/udi/center-for-universal-design/the-principles-
of-universal-design/
12. Extract of <<Center for Universal Design: Ronald L. Mace>>,
http://www.ncsu.edu/project/design-projects/udi/center-for-universal-design/ron-mace/
13. G3ict Publications and Reports, “Accessibility, Innovation and Sustainability at AT&T”,
March 2011
14. Germain Rene, F., “Orange & Mobile Accessible-Assistive Applications-Services for Senior
Citizens and Persons with Disabilities”, M-Enabling Summit, December 2011.
15. Monique M., “Ethical Considerations & Innovations for Older People”, Ethics and e-
inclusion Workshop, May 12, 2008.
16. “Mobile Industry Good Practice Guide for Service Delivery for Disabled and Elderly
Customers in the UK”, July 2003.


17. Narasimhan, N. e-Accessibility Policy Handbook for Persons with Disabilities, Hemkunt
Publishers Ltd., 2011
18. Nagata R., “NTT DOCOMO’s Mobile Phones for Persons with Disabilities”, August 25,
2009.
19. Orange Accessibility Group, “Ensuring Accessibility by Elderly and Disabled People”,
Providing Digital Access to All
20. United Nations, “Convention of the Rights of Persons with Disabilities”, December 13, 2006.
21. Datamonitor, “Global Technology Hardware and Equipment: Industry Profile”, June 2011.


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Best Practices for Providing Accessibility in the Mobile Device Industry