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.  

Public Consultation on DZ 8134: Health and Disability Services Standard

Our submission to Standards New Zealand responds to the Draft Amended Health and Disability Services Standard (Draft Standard), bringing a blindness lens / perspective.

Blind Citizens NZ Submission on the Copyright (Marrakesh Treaty Implementation) Amendment Bill

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.

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.

Case for Review of Website Accessibility

Blind Citizens NZ submitted its paper “The Case for a Comprehensive Review of Website Accessibility for People with Disabilities” to the Human Rights Commission in April 2014. The case we believe, is well-presented, with examples, details and supporting evidence set out.

Submission – More Effective Social Services Issues Paper

Have a read of Blind Citizens NZ’s December 2014 response to the Productivity Commission’s More Effective Social Services Issues’ Paper…

Employment, Participation and Inclusion Services: Draft Proposals for Change

Read on for Blind Citizens NZ’s response to the Ministry of Social Development’s Draft Proposals for Change with respect to Employment, Participation and Inclusion Services…

Human Rights Amendment Bill

Our submission responds to proposed changes to the role and structure of the Commission arising from the Bill and with respect to specific changes this would have on the Human Rights Act 1993.

Review of the Health and Disability Commissioner Act 1994 and Code of Health and Disability Consumers’ Rights

Blind Citizens NZ’s submission comments on the:
1. Review of the Act and Code (first bullet-point from 2009 Review): timelines identified with sections 18 Review of operation of the Act and Review of Code should remain unaltered;
2. Increase maximum fine for an offence under the Act (second bullet-point from 2009 Review): we support this being increased to $10,000 from $3,000;
3. Director of Proceedings (last bullet-point from 2009 Review): we support this proposed amendment.

Submission-Inquiry into the 2013 Local Authority Elections

Blind people continue to be marginalised in local authority elections, and still cannot cast their vote independently with confidence and dignity. They are required to place their trust in family or friends, and for many, often in someone they do not know, to cast their vote for them. So when they do vote, they can only hope that their trust is not misguided, and that their directions are carried out. Blind Citizens NZ acknowledges there are steps afoot to introduce one mechanism that may address this deficit, but that one option will benefit only a small percentage of New Zealand’s blind population, therefore more are needed. Read on…

Submission – Inquiry into the Accessibility of Services to Parliament

Submission – Proposed Changes to the Universal Service Obligation for Postal Services

Submission on Social Securtiy Amendment Bill November 2012

Submission to Discussion Paper “The Wider Journey: The Rights of Disabled People”, Human Rights Commission, March 2012

This is a submission to the Human Rights Commission in response to their discussion paper “The Wider Journey: The Rights of Disabled People”. Our comments correspond to areas that impact upon the ability of blind, deafblind and vision impaired people living in New Zealand to access the built environment safely and independently, to have access to information and to independently vote in local and general elections.

This is a submission to the Human Rights Commission in response to their discussion paper “The Wider Journey: The Rights of Disabled People”. Our comments correspond to areas that impact upon the ability of blind, deafblind and vision impaired people living in New Zealand to access the built environment safely and independently, to have access to information and to independently vote in local and general elections.

Submission in Response to Review of New Zealand Code of Banking Practice December 2010

Submission on Proposed Changes to Building Code Requirements and Acceptable Solution for Signs

Submission on Proposed Changes to the Acceptable Solution for Building Code Clause F7 (Warning Systems)

Submission on Consultation Document “Improving Access to the 2011 General Election and Referendum for Disabled People”

Submission in Response To Review of Special Education Discussion Document March 2010

The Association and seven other organisations from the blindness sector combined efforts to produce a joint submission to the Ministry of Education’s discussion document. This individual submission reinforces all aspects of the joint submission.

Blindness Sector Submission in Response to Review of Special Education Discussion Document March 2010

This is the combined submission from the blindness sector to the Ministry of Education’s review of special education.

Disability Sector Collective Response to Review of Special Education Discussion Document March 2010

This is the collective submission from the disability sector to the Ministry of Education’s review of special education.

Submission in Response to the inquiry into the 2007 local authority elections

Submission to Copyright (New Technologies and Performers’ Rights) Amendment Bill

Submission to the Social Security Amendment Bill

Submission to the Building Bill 2003