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Independent Monitoring Mechanism Online Forum, 29-30 March and 5-6 April 2022, Disability Convention: How is New Zealand Doing?

Independent Monitoring Mechanism Online Forum

March 29th-30th and April 5th-6th, 2022

Disability Convention: How is New Zealand Doing?

An online forum to find out about how the government is progressing on implementing the United Nations Convention of the Rights of Persons with Disabilities (the Disability Convention) will be held Tuesday 29 and Wednesday 30 March, and Tuesday 5 and Wednesday 6 April.

The Forum – ‘The Disability Convention: How is New Zealand doing?’ –  is being hosted by the Independent Monitoring Mechanism (IMM) made up of the Human Rights Commission, the Ombudsman and the Disabled People’s Organisations Coalition (Blind Citizens NZ is a member of the DPO Coalition).

The Forum is being held ahead of New Zealand’s second examination by the United Nations Committee on the Rights of Persons with Disabilities. A subsequent IMM Forum Report will inform the Committee on the status of disability rights here in Aotearoa.

Government ministers and officials are attending the forum and members of the public are invited to observe proceedings. 

The Forum will examine issues raised in monitoring reports published by the IMM over the past two years. Making Disability Rights Real in New Zealand and Making Disability Rights Real in a Pandemic. 

The review will centre on New Zealand’s commitment to Te Tiriti o Waitangi, how poverty is addressed, the integrity of the person, equity and access during humanitarian crises, equality, non-discrimination, access to justice, accessibility, and independence.

Observers will be able to send questions for consideration by a moderation panel at the beginning of each session. Instructions for accessing the Forum are available here in Large Print, Audio and Braille. All alternate formats including Easy Read and New Zealand Sign Language, as well as updates can be located at the following link…
https://www.hrc.co.nz/our-work/people-disabilities/disability-convention-how-new-zealand-doing/

You can locate each of the IMM’s two reports as follows:

1. Making Disability Rights Real in a Pandemic 

2. Making Disability Rights Real
https://www.ombudsman.parliament.nz/resources/making-disability-rights-real-2014-2019-0

Ngā mihi
Independent Monitoring Mechanism Team

Draft 111 Contact Code

Blind Citizens NZ’s submission on the Draft Copper Withdrawal Code cross-references the Draft Copper Withdrawal Code. Our submission identifies areas the Draft 111 Contact Code should in our view, be strengthened to meet the informational needs of blind people, where failure to do so may contribute to breaches of a person’s human rights.

Submission to RUB Consultation

This submission responds to the Requirements for Urban Buses in New Zealand (RUB), for consistent urban bus quality (2020) Draft for consultation. Our submission identifies areas the RUB 2020 Draft for consultation should in our view be strengthened to recognise (and meet) the diverse needs of users of public transport, which includes blind people. We suggest oversights may contribute to a breach of human rights, and/or a failure to implement the “gradual realisation of the United Nations Convention on the Rights of Persons with Disabilities”, ratified by New Zealand in September 2008.

Inquiry into the 2020 General Election and Referendums

Blind Citizens NZ provides feedback to the Inquiry into the 2020 General Election – our response focuses primarily on achieving outcomes that enable blind people to cast their vote independently, with dignity and confidence. 

Submission to RNZFB Board Strategic Plan 2020

Interim feedback to consultation by the RNZFB and Blind Foundation in relation to its Strategic Plan.  

Access Alliance – Accessibility Legislation

Framework to accelerate progress towards accessibility in Aotearoa New Zealand

Here is news of the framework to accelerate progress towards accessibility in Aotearoa New Zealand. You can read the full Cabinet Paper from the Chair of the Cabinet Social Wellbeing Committee Hon Carmel Sepuloni, Minister for Disability Issues – there is an MS Word file (note, an audio file will shortly be available).

Or you can read the Executive Summary and Recommendations – there is MS Word as well as an MP3 file to choose from. 

Petition re E-Scooters

Before we get to the crux of this communication, please note there is a pictogram and then content that explains why we are seeking support for this petition.

Here first is a description of the pictogram. The top two thirds of the oblong are bright gold with black lettering and symbols, towards the left are the words “Keep footpaths for feet and mobility devices”. To the right there are two stick-type representations – one of a person walking, and another of a wheelchair user. The bottom third is black, and written in white, are the words “Sign the petition”

Read on for content below the pictogram…

Footpaths4Feet has come together to support members of the community who use footpaths to get around. Organised through Living Streets Aotearoa, Blind Citizens NZ along with several other organisations is part of Footpaths4Feet. We have all been working hard to convince Government that footpaths must remain safe spaces for our members and the public by not allowing e-scooters, bicycles and other personal transport devices to be used on them. Blind Citizens NZ has been part of delegations that have met with Ministers and officials, but we need more support for our work.

The Government is bringing in a regulatory package called the Accessible Streets Package. Although there are some good things in it, this package also seems to permanently allow personal transport devices such as e-scooters to be used on our footpaths. In our view, this will make footpaths less safe, and feel less safe for pedestrians (including those in pushchairs, wheelchairs and anyone using a mobility aid). For many people, such as for blind, deafblind, vision impaired, Deaf, hard-of-hearing etc., using the footpath is a necessity and is the main connection to their community. If e-scooters and other personal transport devices are allowed on footpaths, these people, as well as able-bodied pedestrians, will be put at higher risk of injury and feel less safe

Additionally, if Government adopts these regulations, local councils may feel they no longer need to invest in making spaces safe by, for example, installing bike paths and bike lanes or lowering speed limits.

This is why we are asking for your assistance with this petition to Government. You can sign the petition on-line, or you can download a hardcopy submission form. Your support will help create safer streets for our community! It will help us keep footpaths for feet and mobility device users by getting a ban on e-scooters, bikes and other personal transport devices being used on footpaths.

Sign the petition online here. Download a printable version of the petition here. Please return to Footpaths4Feet, 37 Oxford St, Palmerston North 4410 by 6 December 2019.

Download a printable version of the petition

Sign the petition online now

International White Cane Day

Blind Citizens NZ urges, Central and Local Government to support International White Cane Day and to better meet the needs of everyone. Additionally, for everyone to acknowledge where there are obstacles and remove them, and support White Cane Day awareness activities happening around the country today.

Here now, is our media release…

Employment Animation

Visual

Blind Bob, a yellow circle with stick arms and legs, wearing sunglasses and with a white cane slung across his back, aims a grey grappling hook upwards. He fires the hook in a diagonal direction and rapidly shoots skyward, landing on a small ledge at the top of a tall pole.

Audio

Even if they manage to hook a job interview, many workplaces leave our blind citizens out on a limb.

Visual

Blind Bob lets go of the grappling hook and, with his arms outstretched, he balances precariously on one leg, then the other.

Audio

But there are lots of ways we can all make a blind bit of difference. Check them out at blindcitizensnz.org.nz.

Visual

Blind Bob leaps off the ledge, morphing into a plain yellow circle with the words ‘a blind bit of difference’ in the middle of it. Text reads: Blind Citizens NZ. White braille on a black background appears next to the circle.

Blind Citizens NZ Accessibility Campaign – Transport Animation

Visual

Blind Bob, a yellow circle with stick arms and legs, wearing sunglasses and with a white cane slung across his back, zooms diagonally downwards while holding on to grappling hook. The wire extends as far as a bus stop sign mounted on a pole. Bob lets go of the hook and drops down on to the narrow tip of the pole. With his arms outstretched, he balances precariously on one leg, then the other.

Audio

Just getting on the right bus can be a tricky balancing act for our blind citizens.

Visual

Blind Bob manages to awkwardly remain upright with both legs on top of the pole.

Audio

But there are lots of ways we can all make a blind bit of difference. Check them out at blindcitizensnz.org.nz.

Visual

Blind Bob leaps off the pole, morphing into a plain yellow circle with the words ‘a blind bit of difference’ in the middle of it. Text reads: Blind Citizens NZ. White braille on a black background appears next to the circle.

Blind Citizens NZ Accessibility Campaign – Entertainment Animation

Visual

Blind Bob, a yellow circle with stick arms and legs, wearing sunglasses and with a white cane slung across his back, stands on a small ledge at the top of a tall pole. He leaps into the air and freefalls, his outstretched arms rippling in the wind.

Audio

Accessibility is key for our blind citizens to participate in all kinds of activities.

Visual

Blind Bob reaches behind his back to pull a ripcord, and a parachute opens, immediately slowing his rapid descent. Bob sways gently as he drifts towards the ground.

Audio

There are lots of ways we can all make a blind bit of difference. Check them out at blindcitizensnz.org.nz.

Visual

The parachute disappears, and Blind Bob morphs into a plain yellow circle with the words ‘a blind bit of difference’ in the middle of it. Text reads: Blind Citizens NZ. White braille on a black background appears next to the circle.

Blind Citizens NZ Accessibility Campaign – Voting Animation

Visual

Blind Bob, a yellow circle with stick arms and legs, wearing sunglasses and with a white cane slung across his back, freefalls rapidly through the air, his outstretched arms rippling in the wind. He reaches behind his back to pull a ripcord, and a parachute opens, immediately slowing his descent.

Audio

Just trying to cast a private vote can leave a blind citizen feeling totally in the dark.

Visual

As Blind Bob lands on the ground next to a sign reading ‘voting’ with an arrow, the parachute completely covers him, leaving only the tips of his stick legs visible. He struggles underneath the material, eventually managing to cast it off with the aid of his white cane.

Audio

But there are lots of ways we can all make a blind bit of difference. Check them out at blindcitizensnz.org.nz.

Visual

Blind Bob leaps upwards, morphing into a plain yellow circle with the words ‘a blind bit of difference’ in the middle of it. Text reads: Blind Citizens NZ. White braille on a black background appears next to the circle.

Blind Citizens NZ Accessibility Campaign – Banking Animation

Visual

Blind Bob, a yellow circle with stick arms and legs and wearing sunglasses, scales a grey brick wall. With his white cane slung across his back, he propels himself upwards with effort to pass an ATM with a screen and number pad on the wall.

Audio

Banking can be like climbing up a brick wall for our blind citizens, but there are lots of ways we can all make a blind bit of difference. Check them out at blindcitizensnz.org.nz.

Visual

Blind Bob leaps towards the ATM, morphing into a plain yellow circle with the words ‘a blind bit of difference’ in the middle of it.

Text reads: Blind Citizens NZ. White braille on a black background appears next to the circle.

Strategic Framework for the Provision of Braille Services

Launched on 6 October 2018 at Blind Citizens NZ AGM and Conference, this Strategic Framework for the Provision of Braille Services is a huge achievement and milestone for braille in New Zealand. We recognise and thank our stakeholder partners: Blind and Low Vision Education Network NZ, Blind Foundation, and The Braille Authority of Aotearoa Trust.

Strategic Framework for the Provision of Braille

Provided in MS Word and PDF, the Strategic Framework for the Provision of Braille Services is a long term Strategic Framework that will drive an integrated approach toward achieving results for braille providers and users. The Strategic Framework is centred on essential priorities that raises awareness amongst the blind community i.e. people who are blind, vision impaired, deafblind or have low vision, of the primacy of braille, and the provision of braille services.

Marrakesh Treaty Submission

Submission in Response to
Exposure Draft: Copyright (Marrakesh Treaty Implementation) Amendment Bill
Emailed to: MarrakeshTreaty@mbie.govt.nz

The Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) appreciates the opportunity to make a submission on the Exposure Draft: Copyright (Marrakesh Treaty Implementation) Amendment Bill.

Blind Citizens NZ is a disabled people’s organisation (DPO). Our members are blind, vision impaired or deafblind. We have commented in past submissions that historically, New Zealand has championed international conventions. New Zealand played a lead role in the drafting, development and subsequent ratification of the United Nations Convention on the Rights of Persons with Disabilities (the Convention). Blind Citizens NZ applauds Government for making steady progress to accede to the Marrakesh Treaty, a multilateral treaty concluded by the World Intellectual Property Organisation (WIPO) in 2013 in the Moroccan city of Marrakesh.

Our support for the Amendment Bill is evidenced in this submission which we consent to being available on the Ministry of Business Innovation and Employment’s (MBIE) website.

We welcome an invitation to speak to and elaborate on the extent of feedback provided in our submission. To arrange this, please contact the Executive Officer Rose Wilkinson via either of the following options:
▪ Phone: 021 222 6940;
▪ Email: rwilkinson@abcnz.org.nz

Blind Citizens NZ’s submission to the Amendment Bill follows.

Rose Wilkinson
Executive Officer

Blind Citizens NZ: Submission in Response to
Exposure Draft: Copyright (Marrakesh Treaty Implementation) Amendment Bill
Legislative Changes proposed in the Exposure Draft

1.​Updating Section 69 of the existing Copyright Act 1994 (the Act) is the primary purpose of this Bill. Replacing the concept of ‘prescribed bodies’ with the concept of ‘authorised entities’, and identifying respective provisions for ‘authorised entities’ is paramount when realising the difference that changes to the Act will make for people with a print disability. Ultimately though, updating Section 69 will bring the Act into line so that it is consistent with the Marrakesh Treaty.

Additionally, the Bill provides a much-awaited and welcome opportunity to update terminology and other facets of the Act with current practice and modern-day language.

2.​The Bill brings to an end uncertainty that currently exists with respect to rights-holders and producers of accessible formats currently recognised under this exception to the Act. In our view, this is paramount when considering provisions in the Bill identify:
▪ who can make, reproduce and distribute accessible format copies i.e. authorised entities;
▪ what is meant by an accessible format;
▪ the extent to which an authorised entity must satisfy a ‘commercial availability test’;
▪ what activities an accessible format producer may carry out in its authorised entity capacity;
▪ which beneficiaries are provided for under the exception to the Act; and
▪ extending the definition of ‘works’ to include artistic works.

Blind Citizens NZ unreservedly supports all amendments and transitional provisions in the Bill.

3.​Recognising amendments to the Act and acceding to the Marrakesh Treaty will increase access to cross boarder material, people with a print disability here in New Zealand look forward to having greater choice and increased access to local publications. In our view there is potential for there to be an increase in authorised entities that produce quality alternate format copies such as braille. Outcomes such as this will go some way towards opening up choice for people with a print disability.

4.​Blind Citizens NZ recognises the need for the Bill to set out requirements for authorised entities and duties with regard to record keeping and the fees they may charge when producing accessible format copies. In this regard, previous submission opportunities and discussions with officials highlighted, at least from Blind Citizens NZ’s perspective, a preference for procedures and administrative requirements not to be onerous. Our rationale being that many authorised entities are not large in size or capacity, and imposing onerous administrative requirements would be a disincentive and potentially detract from gains that acceding to the Marrakesh Treaty should bring.

We believe a record keeping system that satisfies the needs of all parties should be speedily achieved for implementation, and we encourage due consideration of this requirement when planning for implementation of the Marrakesh Treaty and Act occurs.
Amendments beyond the minimum required for New Zealand to accede to the Marrakesh Treaty

5.​There is no doubt, as stated in the commentary document, that the collective of amendments create a more cohesive approach to the exception for making accessible format copies. Blind Citizens NZ applauds Government’s approach and exceeding the minimum amendments required for accession to the Marrakesh Treaty.
Conclusion

6.​Blind Citizens NZ unreservedly supports the Exposure Draft: Copyright (Marrakesh Treaty Implementation) Amendment Bill which implements the Marrakesh Treaty.

7.​Every step New Zealand takes towards increasing access to alternate format copies for people with a print disability complements global efforts such as the Right to Read Campaign that supports inclusive publishing initiatives so that materials are born accessible.

8.​We urge Government’s speedy adoption of the Bill and implementation of the Marrakesh Treaty which will:
▪ contribute towards ending the “book famine” that print disabled people continue to experience;
▪ benefit an estimated 168,000 New Zealanders who have a print disability;
▪ expedite the creation and implementation of copyright exceptions;
▪ enable repositories of accessible books to be shared and minimise duplication of effort and cost when more than one organisation in different countries, but sharing the same language, make the same book accessible;
▪ improve timely access for persons with a print disability to access a greater variety of accessible format works leading to greater access to education, employment opportunities, improved health outcomes, and greater autonomy and independence.
About Blind Citizens NZ

Founded in 1945, the Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) is New Zealand’s leading blindness consumer organisation and one of the country’s largest organisations of disabled consumers. Blind Citizens NZ’s aim is to heighten awareness of the rights of blind and vision impaired people and to remove the barriers that impact upon their ability to live in an accessible, equitable and inclusive society.

Electoral Matters Bill

Submission in response to the Local Electoral Matters Bill

Emailed to Justice Committee Secretariat at: ju@parliament.govt.nz

Introduction

The Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) is pleased to have this opportunity to provide comment in response to the Local Electoral Matters Bill.

Blind Citizens NZ is a disabled people’s organisation (DPO). Our members are blind, vision impaired or deafblind, hereafter referred to as blind. Our response to the Bill will predominantly be from a blindness perspective.

In our submission, we use the term “alternate formats”. This refers to the various means by which blind people access information other than through standard print, i.e. large print, braille, audio, electronic devices, email and the telephone.

We agree to the release of any comments made in our submission.

We welcome an invitation to speak to and elaborate on the extent of feedback provided in our submission. To arrange this, please contact the Executive Officer Rose Wilkinson via either of the following options:
Phone: 021 222 6940
Email: rwilkinson@abcnz.org.nz
Blind Citizens NZ’s Position in a Nutshell

1.​Support: Blind Citizens NZ supports all amendments proposed in the Local Electoral Matters Bill. Ideally implemented for the 2019 Local Authority Elections, these amendments will introduce flexibility and recognition of the diverse needs of New Zealand’s population. For blind people, their rights to independently cast a vote with dignity and confidence is paramount.

Having signalled our support for all amendments, our submission addresses the needs of blind voters and the benefits that will accrue once these are implemented. We cannot emphasise strongly enough how crucial these amendments are to recognising blind people have rights and are citizens too!

This omnibus Bill (as explained in the Bill’s explanatory note) provides greater flexibility to enable local electoral arrangements to adapt to changing circumstances by:
▪ Amending the Location Elector 2001 to support trials of novel voting methods;
▪ Amending the Electoral Act 1993 to enable the design of future voting methods to utilise date of birth information (but not publicise it); and
▪ Amending the Electoral Act 1993 to ensure that analysis of voter participation in local elections (including trials) can utilise age group information.

2.​Call to Action: Blind Citizens NZ calls on Local and Central Government:
▪ to make all election materials issued to the public available to blind people in alternate formats as of right; and to
▪ introduce mechanisms that will enable blind people to independently cast their vote, whether in a polling booth or from home.
Background

Blind Citizens NZ is proud to have played significant roles historically, in securing the rights of blind people to cast votes as they choose. We were instrumental in securing the rights of blind people having the right to select someone of their choice to accompany them into the polling booth and assist them cast their vote as required, when voting in elections within New Zealand.

Telephone Dictation Voting is further evidence of Blind Citizens NZ’s influence where we secured a commitment from the Government of the day for an independent and confidential voting option for blind people. The introduction of telephone dictation voting means that blind voters experience independence, secrecy and confidentiality around their vote. Staff who mark the ballot papers over the phone have no idea who they are talking to because voters identify themselves by an assigned number and prearranged password. One staff person marks the ballot paper and another reads it back to the voter to validate the ballot paper has been correctly marked. Telephone Dictation Voting is an essential option for voters who do not have technology and/or internet access. As evidenced with the 2018 Census, the lack of uptake with online form-filling identified a digital divide which reinforces the need for telephone dictation voting. While the outcomes to which we refer have been advantageous, and dictation voting remains as relevant as ever, technological advances mean more can be achieved to enable blind people with technology and internet access, to independently cast their vote with confidence and dignity.

For blind voters, independence and well-informed participation is often compromised because much of the material distributed as part of Local Authority and General elections is in print, which they cannot read. This includes candidate biographies, election issues, postal voting forms and ballot papers in polling booths.

Voting Method for elections and polls (Section 36)

In support of the amendments in Section 36, and referring to our experience and efforts with the Electoral Commission and the introduction of Telephone Dictation Voting, we encourage Local and Central Government to include blind people in trials. In particular we emphasise two areas that will benefit blind voters (and many others) i.e. telephone dictation and online voting.

We expand a little more… Blind people continue to be marginalised in local authority elections which moved from polling booths to the postal system some time ago. While it may be advantageous for some to complete the ballot paper at home, it is not the case for blind people. In our view, postal voting has introduced a genuine step backwards for our population of people.

While some local authorities in 2016 such as Auckland Council for example, put measures in place to provide assistance, the fact remains that blind people still cannot, in local authority elections, cast a secret vote. This has an impact on approximately 12,000 registered blind voters turning up and voting at elections. The reality for blind people currently is they are required to place their trust in too many elements of the electoral process. From reliance on a postal service and knowing when their ballot papers have arrived, to placing trust in someone else to cast their vote for them. For some this will be family or friends, while for many, trust will often be placed in someone they do not know. Therefore when a blind person does vote, they can only hope their trust is not misguided, and that their directions are carried out. This is why we need legislation in place that recognises the diversity of New Zealand’s voting population. For blind people, there needs to be the flexibility to cast a paper-based vote (standard and large print), telephone dictation voting for those without technology and/or internet access, and on-line voting for those who can use this option.

Although proposed amendments are silent on the need for vitally important candidate information that informs voters, to be available in a range of alternate formats, Blind Citizens NZ takes this opportunity to bring this issue forward. In the 2016 local authority election, Wellington City Council and Auckland Council for example, had web-based information that was both accessible and usable by blind people who had the technology to take advantage of this online option. Our expectation therefore, is that all local authorities should be required to have candidate and election information available, accessible for, and usable by everyone. For blind people this means providing the full range of alternate format options. While we give kudos to Councils that in 2016 had online options that voters with technology could easily look up, blind people without technology were often left bereft of information to inform their vote.

Blind Citizens NZ firmly believes all local authorities have a responsibility to serve all the public. In this context, websites, and the information on them, needs to be available to everyone, including blind people who use blindness technology such as screen readers, to access that information. Introducing consistency in the way local authorities conduct elections, and building on good examples will go a long way towards meeting the diverse needs of New Zealand’s voters, and improving their experience. It is imperative that information is available in a range of alternate formats.

As voting methods are developed to include for example, Telephone Dictation, and Online Voting, Blind Citizens NZ looks forward to local authorities including blind people in those trials, and engaging with us as these are scoped and rolled out.
Accessing Candidate Information

We mentioned previously about the importance of blind voters being able to access electoral and candidate information. Constraints imposed upon blind people limits the extent to which this community of New Zealand’s population can fully participate in local politics. This includes standing for candidacy, making a nomination, and generally being able to read the range of information so readily available to the sighted public.

All too often information about the process to stand as a candidate, and about a candidate standing for election, is available only in print (pamphlets and hand-outs), via bill-boards and hoardings, or on the internet. With respect to election material and ballot papers, these often utilise small, italicised fonts, embrace poor colour contrast and lack consistency in terms of presentation. Consequently, the information is inaccessible to someone with low or limited vision. Large print election material and ballots would offer some benefit in terms of vision impaired voters being able to independently participate in and cast their vote in the electoral process. Of significance is that blind people unable to read printed matter, will still be disadvantaged and therefore, continue to be discriminated against.
International Conventions

New Zealand led the way internationally in the adoption of the United Nations Convention on the Rights of Persons with Disabilities (the Convention). A rights-based convention, New Zealand ratified this in September 2008 Currently, while local government does not have to comply with the Convention, we congratulate those working towards ensuring their communities, information etc., are accessible to disabled people.

Article 9 – Accessibility, recognises the responsibility of Governments to take measures on several accounts. One of these being to ensure disabled people access, on an equal basis with others, information and communications, including information and communications technologies and systems. Barriers to accessibility are to be removed!

Article 29 – Participation in Political and Public Life recognises the entitlement of people with disabilities to be represented or to participate in government and other civic activities.

Blind Citizens NZ congratulates Government on the proposed amendments to the Local Electoral Act 2001, and the Electoral Act 1993. These amendments go some way towards recognising the rights of all disabled people, including blind people, and mirroring these in local authority legislation.

Conclusion

As we conclude our feedback, and mindful of the importance of increasing voter turnout, Blind Citizens NZ urges Government to both support and adopt proposed amendments brought forward in the Local Electoral Matters Bill in readiness for the 2019 Local Authority Elections. Blind people look forward to online voting because, for those who have the technology, they will be able to vote like anyone else without being marked out as different.

Blind Citizens NZ advocated strongly in the lead-up to the 2016 Local Authority Elections, for the introduction of online voting. While this did not proceed for 2016, we nevertheless applause those Councils that stepped and were prepared to support online voting. Now, in response to this Bill, it is pleasing to see Councils such as Wellington, Selwyn Districts and Auckland for example, publicly declaring their support for online voting.

Blind Citizens NZ has a set of “briefs” that identify specific requirements across a range of areas. In relation to the issues raised in our submission. We include for your reference and guidance, briefs that address access to public information (published 2017), websites (published 2011) and The Great Barrier Brief (2nd Edition/published 2017).
About Blind Citizens NZ

Founded in 1945, the Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) is New Zealand’s leading blindness consumer organisation and one of the country’s largest organisations of disabled consumers. Blind Citizens NZ’s aim is to heighten awareness of the rights of blind and vision impaired people and to remove the barriers that impact upon their ability to live in an accessible, equitable and inclusive society.

“Extra Touch Award” presented to Darryl Wilson, Chief Executive, Abel Tasman National Park Ltd

During our 2015 70th anniversary celebratory event, October 2015, Blind Citizens NZ presented the Extra Touch Award to Darryl Wilson, Chief Executive of Wilsons Abel Tasman National Park Ltd, recognizing the outstanding contribution providing access to both travel and recreational opportunities for blind and vision impaired patrons.

Read on to find out more…

Disabled People in Employment: Prioritised Actions for the Way Forward – September 2011

A paper arising from the Disability Employment Summit, held on 14 June 2011 to plan actions arising from the Disability Employment Forum held November 2010.

Draft Code of Banking Practice

Submission in response to the Code of Banking Practice Review
Emailed to New Zealand Bankers Association at: nzba@nzba.org.nz

Introduction

The Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) is pleased to take advantage of the opportunity to participate in the Code of Banking Practice (Code) Review, and comment on the proposed draft Code.

Blind Citizens NZ is a disabled people’s organisation (DPO). Our members are blind, vision impaired or deafblind, hereafter referred to as blind. Our response to the draft Code will predominantly be from a blindness perspective.

We are pleased to advise this submission has the support of Kāpō Māori Aotearoa NZ (refer https://www.kapomaori.com/)

In our submission, we use the term “alternative formats”. This refers to the various means by which blind people access information other than through standard print, i.e. large print, braille, audio, audio description, electronic devices, email and the telephone. For Deaf or hard of hearing this may be captions or sign language, and for people with a learning disability, this may be easy read.

We agree to the release of any comments made in our submission.

In the event an opportunity to speak to and, elaborate on the extent of feedback provided in our submission is available, we would welcome this. Please contact the Executive Officer Rose Wilkinson via either of the following options:
Phone: 021 222 6940
Email: rwilkinson@abcnz.org.nz
About the Code of Banking Practice

Blind Citizens NZ supports the high-level, less prescriptive approach taken in the draft Code. We support the five principles of good banking practice should be regarded as the minimum standard that banks have with customers. However, we believe banks should be encouraged to do more than be seen to “observe” good banking practice as a minimum.

Additionally, words that encourage banks to aspire to do more than meet the minimum standard would strengthen the statement to which we refer.

Blind Citizens NZ recognises the Banking Ombudsman plays a significant role when it comes to customers needing to raise a complaint or concern. However, for anyone in this position and needing to find out more about banking issues, the only reference made at this initial point, is to a website. Although at the end of the Code, there is a full set of contact details, customers without internet access, may feel information is lacking if led to believe at this early stage of the document, that there is but one option available to them, that is out of their reach.

Blind Citizens NZ encourages an amendment to the last statement in this section so that it is clear the Code is available from more than one source. While it is helpful to know where the Code can be located on line, we prefer the document to identify it is available in a range of alternate formats for blind people, and from where they might obtain them.
What we will do for you

We restate our support for each of these five principles, which set the threshold and expectations for customers, about how banks will interact with them.

Blind Citizens NZ believes a further principle that both recognises and honours pertinent international conventions and domestic elements that embody commitments to disabled and older customers will enhance and strengthen the Code and stated commitment to each of these communities. Referring to disabled people for example, New Zealand has ratified the United Nations Convention on the Rights of Persons with Disabilities, and Government implemented in 2016, its New Zealand Disability Strategy to 2026. Compliance with domestic legislation and standards such as the Building Code and NZS4121, and Website standards that contribute towards accessibility of access in both a sensory and physical context. In our view, introducing and recognising compliance requirements in the principles will strengthen the Code.

Additionally, we believe the voluntary guidelines for banks (we refer to these later in our submission), should be formally introduced into the Code.
We will treat you fairly and reasonably

From our perspective, we need clarification about what element of banking this principle addresses. In the belief this principle intends to talk about banking behaviours as opposed to conduct and behaviours of bank personnel and customers, the principle in our view, should include pertinent terminology that ensures clarity of purpose. We draw to your attention an area we believe highlights where confusion or misunderstanding might occur: “What may be fair and reasonable in any case will depend on the circumstances, including our conduct and yours, what our terms and conditions say, what the law says, and good banking practice.”

Blind Citizens NZ applauds the statement thus commitment towards “…making reasonable efforts to assist and accommodate the needs of all customers, including older and disabled.”
However, we suggest that the statement we refer to would be stronger and carry more weight by ending the statement as follows “…older and disabled people are customers too.” We explain why…

Whilst accepting footnote 1 refers to voluntary guidelines for banks to assist them meet the needs of disabled and older customers, in today’s environment we believe that much of what is included in the guidelines should be mandatory and not voluntary.

Advances in technology influence changes in the way we do things, including banking. The voluntary guidelines recognise this by encouraging banks to keep pace with changing technologies involving ATMs, electronic and internet banking. They also ask banks to consider for example, use of international W3C web accessibility best practice standard, accessibility-related New Zealand e-government web standards, etc. The voluntary guidelines also suggest that banks should “…consider the provision of alternative banking services to those older and disabled customers who may be unable to use technological innovations.” In our view however, the voluntary guidelines fall short of banks being required (as opposed to considering), the need to incorporate accessibility features so they are designed, implemented and usable, from the outset.

Much as we identified earlier in this submission, the Code must require banks to ensure that information and technology is available, usable, and accessible to everyone. ATMs, websites, kiosks, smartphone apps and EFTPOS terminals to name a few, must be designed and built with accessibility features that are functional from the outset. For example, the introduction of technology with audio capability but which is not functioning, and EFPTOS terminals with screen displays that do not incorporate use of corresponding function keys and the number pad, prevent blind customers using these technologies independently and may be discriminatory. Designing accessibility features and incorporating these for implementation and usability from the outset, is far more cost-effective and avoids the much greater expense of retrospectively upgrading technology to meet accessibility requirements.

Moving along to print requirements, the voluntary guidelines identify fundamental elements Blind Citizens NZ supports as these meet the needs of customers who are vision-impaired. We take this opportunity to refer to the Roundtable on Information Access for People with Print Disabilities Inc where guidelines for a range of alternate formats can be located, including for the production of clear print. Resources such as these are invaluable and can be located via the following web-link https://printdisability.org/guidelines/guidelines-for-producing-clear-print-2011/

It appears the guidelines were last updated in 2009 – if these are to remain in some form, in our view they must be pertinent, fit for purpose and reviewed once every three years at a minimum. We urge the New Zealand Bankers Association to remain mindful of the Convention, and to refer to Article 1 Purpose, Article 3 General Principles, and Article 9 Accessibility (refer appendix 1). Collectively these articles identify fundamental requirements for disabled people, and parameters for meeting accessibility requirements.
We will communicate with you clearly and effectively

Blind Citizens NZ agrees and supports the need for information to be available in plain language.

However, we propose an amendment to numbers one and two of this section to recognise customers have differing access needs, some of whom may require information in an alternate format. Taking this approach will in our view, reinforce the commitment of the Code to meet the diverse needs of customers.
We will respect your privacy and confidentiality and keep our banking systems secure

Blind Citizens NZ supports the set of statements that sit within this principle.
We will act responsibly if we offer or provide you with credit

Blind Citizens NZ supports the set of statements that sit within this principle.
We will deal effectively with your concerns and complaints

Recognising this set of statements includes references to information being easily available, we refer to earlier comments we have made on this topic i.e. there is a need for the Code to recognise the diversity of alternate formats, and from where these can be obtained. Additionally, technology that facilitates access to information must be accessible to, and usable by anyone who may chose this option.
Conclusion

Blind Citizens NZ has working relationships with a number of banks, which we value. The influence we have had over time is evident and there is no doubt these make a blind bit of difference because when information and technology such as ATMs and EFTPOS terminals are accessible, they ensure blind people too, can carry out their banking requirements, safely, confidently, and independently.

As we conclude our feedback, we urge again, the need for the Code to reflect high-level values and compliance elements currently set out in the voluntary guidelines for banks. The expectations of blind people, disabled people and older people, and anyone else with specific needs is not to be reliant on the goodwill of others to receive a committed, dedicated service. We take this opportunity to highlight that internationally people are living longer and that disability-related conditions such as loss-of sight, hearing, and mobility occurs in an aging population. Ensuring accessibility (and usability) of information and technology for disabled people will go a long way towards delivering on the commitment for all customers to be treated fairly and reasonably.

Blind Citizens NZ has a set of “briefs” that identify specific requirements across a range of areas. In relation to the issues raised in our submission, we include for your reference and guidance, briefs that address access to public information (published 2017), banking (published 2011), websites (published 2011) and The Great Barrier Brief (2nd Edition/published 2017).

About Blind Citizens NZ

Founded in 1945, the Association of Blind Citizens of New Zealand Inc (Blind Citizens NZ) is New Zealand’s leading blindness consumer organisation and one of the country’s largest organisations of disabled consumers. Blind Citizens NZ’s aim is to heighten awareness of the rights of blind and vision impaired people and to remove the barriers that impact upon their ability to live in an accessible, equitable and inclusive society.

Appendix 1: Excerpt from the United Nations Convention on the Rights of Persons with Disabilities

Article 1: Purpose

The purpose of the present Convention is to promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity.

Persons with disabilities include those who have long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others.

Article 3: General principles

The principles of the present Convention shall be:

(a) Respect for inherent dignity, individual autonomy including the freedom to make one’s own choices, and independence of persons;

(b) Non-discrimination;

(c) Full and effective participation and inclusion in society;

(d) Respect for difference and acceptance of persons with disabilities as part of human diversity and humanity;

(e) Equality of opportunity;

(f) Accessibility;

(g) Equality between men and women;

(h) Respect for the evolving capacities of children with disabilities and respect for the right of children with disabilities to preserve their identities.

Article 9 Accessibility

1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:

(a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces;

(b) Information, communications and other services, including electronic services and emergency services.

2. States Parties shall also take appropriate measures to:

(a) Develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public;

(b) Ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities;

(c) Provide training for stakeholders on accessibility issues facing persons with disabilities;

(d) Provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms;

(e) Provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public;

(f) Promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information;

(g) Promote access for persons with disabilities to new information and communications technologies and systems, including the Internet;

(h) Promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.

Blind Citizens NZ’s Position on Cyclists on Footpaths

The 2016 Annual General Meeting sought to have Blind Citizens NZ clarify its position regarding cyclists and other wheeled or motorised vehicles that are regularly encountered on our footpaths. Currently, it is legal for vehicles below a certain wheel size, even with low-powered motors, and also motorised mobility vehicles to be used on footpaths.

Concern had arisen due to a petition having been presented to Parliament on which a committee was about to hear submissions. The petition had recommended a change to the road rules to allow children under 14, seniors over the age of 65 and people with mental and physical disabilities to cycle on the footpath.

Blind Citizens NZ’s position is quite clear. It is that no one, even young children, should be able to cycle on footpaths except where there is a designated cycle lane. Apart from our right to feel safe on the footpath, we can also argue that the benefits of being able to cycle there can often be overrated and even misleading. Some points to note are:

1.​Footpaths should be a safe place for people who prefer to walk or have no alternative other than to do so. If footpaths were to become an unsafe environment, even simply through fear of an incident, this would affect not only the blind and vision-impaired, but also the elderly, pram-pushers, wheelchair users, the physically disabled, and those with hearing loss.

2.​Moving a group of cyclists from the road to the footpath would just replace one set of vulnerable road users while at the same time creating another set of vulnerable pedestrians. If it is unsafe to cycle on the roads, why should it be made less safe for those on the footpath?

3.​Mobility scooter users are warned against travelling faster than surrounding pedestrians, but cyclists can’t travel at walking speed. Furthermore, any age and speed limits that may be imposed would be impossible to enforce, or even to monitor.

4.​The very fact that some cyclists may currently be aware that cycling on footpaths is illegal, may cause them to refrain from the practice or at least to take more care than they might if their position was sanctioned under the law.

5.​Most road accidents involving cyclists do not involve motor vehicles. Cyclists injure themselves most often by falling off and hitting things, and there are far more things to hit on footpaths, both moving and stationary.

6.​The very developmental factors that make child cyclists unsafe on roads such as immature motor skills, immature vision and balance, difficulty judging speed and distance; also make them unsafe on footpaths. These factors may not only make them a danger to themselves, but even more so to those they collide with.

7.​Because there is less time to react, vehicles exiting driveways are even more of a hazard to cyclists than they are to pedestrians. Then there is the reality that, whether they’re on the road or on the footpath, cyclists still have to cross intersections, and that’s where most collisions between cyclists and motor vehicles occur.

8.​Many footpaths in suburban areas in New Zealand are narrow and often not well maintained. Even if cyclists acknowledge that pedestrians do have the right of way, such avoidance manoeuvers may not always be successful, placing both parties at risk of injury.

Adopted April 2017

Taking charge of our money – Banknote gauges facilitate independence and confidence for blind and vision impaired people

Blind Citizens NZ has worked alongside the Reserve Bank of New Zealand for many years, contributing to, and influencing, the design of New Zealand’s currency so that people who are blind or vision impaired, can more easily identify their money.

You can learn more about our work, from our media release at this link: Here

Blind Citizens NZ has worked alongside the Reserve Bank of New Zealand for many years, contributing to, and influencing, the design of New Zealand’s currency so that people who are blind or vision impaired, can more easily identify their money.

You can learn more about our work, from our media release at this link: Here

To find more out, about the banknote gauge, and its use, check the short video put together by the Reserve Bank of New Zealand: https://www.rbnz.govt.nz/research-and-publications/videos/note-gauges

Or, the Reserve Bank of New Zealand’s media release at: Here

No to Online Voting a Major Blow for Disabled People

Blind and vision impaired people value the idea of a fully confidential vote. But imagine if you could only vote by telling someone else and having them cast your vote for you. That is what it is like for blind people and many others with disabilities who cannot fill in the voting forms for ourselves.

You can read more about the benefits of on-line voting, and the opportunities this creates for our community…

Support our right to have equitable access to books

Support our right to have equitable access to books

“Blind people have the same right to read published works as everyone else” says Clive Lansink, National President of Blind Citizens NZ. “But right now, we often have no way to read what everyone else takes for granted, because it is not published in formats we can use”.

You will find more information about the Marrakesh Treaty, and the importance of New Zealand ratifying this, in our media release…

Taking charge of our money – Banknote gauges facilitate independence and confidence for blind and vision impaired people

The Association of Blind Citizens of New Zealand (Blind Citizens NZ), congratulates the Reserve Bank of New Zealand for providing banknote gauges that will support people who are blind and vision impaired, to independently identify with confidence, the denomination of their bank notes.

Clive Lansink, National President of Blind Citizens NZ says “I regularly use the banknote gauge to sort out my money. I am totally blind, and when I purchase something over the counter, I want to know that the money I am handing over is correct – I don’t want to have to ask sighted people what I have in my hand…”

Read more about the Reserve Bank’s work with the blind community, and the new banknote gauges…

Focus December 2015