Consumer Initiatives
Disabilities Forum
Forum on Electronic Communications Services for People with Disabilities (“The Forum”) was established in furtherance of ComReg’s statutory objectives to promote competition and to promote the interests of users. The Communications Regulation Act 2002 envisages that ComReg takes specific measures in relation to those objectives including the following measures:
• Ensuring that users, including users with disabilities, derive maximum benefit in terms of choice, price and quality
• Promoting the provision of clear information
• Addressing the needs of specific social groups, in particular users with disabilities
Forum goals
The Forum was established in March 2006 and the Forum held its first meeting on September 27 2006. Its functions include the following:
• The identification of services provided by electronic communications service providers that are relevant to the needs of users with disabilities
• The identification of accessibility issues for people with disabilities in relation to electronic communications services.
• The promotion of good practice by electronic communications service providers in relation to the accessibility of customer service
• The promotion of accessible information provision by electronic communications service providers to users with disabilities so that such users can exercise choice in respect of services and service provider
• The promotion of the needs of users with disabilities through a review of the effectiveness of existing services in meeting the needs of users with disabilities and recommending improvements and/or new services
Membership of the Forum
• Representatives of the disability sector in Ireland to include the National Disability Authority (NDA); People with Disabilities in Ireland (PWDI); the Disability Federation of Ireland (DFI); the Not for Profit Business Association; the Irish Mental Health Coalition, and the Federation of Voluntary Bodies,
• Representatives of the electronic communications sector, both fixed and mobile service providers
• The Department of Communications, Energy and Natural Resources (DCENR)
The following sections set out a number of key initiatives which have been developed and implemented by the Forum to date, including:
Survey of users with disabilities
One of the Forums goals was to find out what issues people with disabilities have regarding electronic communications services. As a result, ComReg agreed to undertake a user survey which would aim to gather information from approximately 1000 people with disabilities in Ireland. The initial design of the survey was taken on by a selected Forum subgroup consisting of representatives from fixed line providers, mobile providers and members from various disability organisations.
In conjunction with the survey, a questionnaire was designed by a dedicated subgroup of the Forum so as to retrieve information about services which are currently available from service providers.
The findings of the survey were published by ComReg in the following link: ComReg Document No 07/78 - Research on the experiences of electronic communications services by users with disabilities
A second survey of electronic communications issues for people with disabilities was conducted during April and May 2010, using a representative sample of approximately 2000 registered people with disabilities. The findings of the survey are linked - 2010 Survey of Users with Disabilities
Key Findings from the 2010 Survey:
• Compared to the general population, consumers with disabilities are more dependent on fixed lines and are marginally less likely to use mobile or the internet
• Consumers with disabilities have shopped around for better prices for fixed and mobile services, and have switched provider • Price and customer service are the most important aspects when choosing both fixed and mobile services – probably no different to the general population
• There is high agreement that fixed and mobile being reliable is vital, and there is also high agreement that all services (fixed, mobile and internet) are easy to use. There appears to be issues however around getting and understanding information about the different services
• There is clearly a need specifically for increasing awareness of access to (and funding of) special equipment and services for people with disabilities, and a need for more information generally about the various ICT services on offer
• The incidence of approaching operators for special equipment or services to make fixed and mobile services easy to use, while is very low, there is high dissatisfaction among those who did make contact for this purpose
Consumer guide for people with disabilities and older people
One of the Forum decisions was to publish a consumer guide which would inform people with disabilities and older people about various phone features, phone service, billing information and help with costs.
The guide ‘Phones and Broadband – a guide for people with disabilities and older people’ was published in October 2007 jointly by the NDA and ComReg in the following formats:
• Regular print
• Large print
• Braille
• Audio
• Online version
• Easy to read
Electronic communications service providers are working on developing accessible disability sections for their websites which should provide more information about the services which are generalised in the guide.
The following are links to the published online versions:
• Phones and Broadband - a guide for people with disabilities and older people - Easy To Read Version
Hosting of the CEOs Breakfast Briefing and Workshop for electronic communications service providers
ComReg, in conjunction with Forum membership, hosted a breakfast briefing session in October 2008 for CEOs of electronic communications service providers to raise awareness at industry level of the benefits of universal design and its benefits for all aspects of business (product design, marketing and customer services). A workshop event was subsequently organised to raise awareness for electronic communications service providers staff that were directly involved in marketing, product design and customer service departments. Both events received very positive feedback in relation to content and presentation.
Quality Standard for Bill Presentation Standard
ComReg, in conjunction with Excellence Ireland Quality Association (EIQA), developed a quality standard for bill presentation (“Bill Presentation Standard”) by electronic service providers in November 2008. The Bill Presentation Standard is a voluntary standard and electronic service providers were invited to present bills for accreditation by EIQA. Electronic communications services/packages which meet the agreed accreditation levels against the Bill Presentation Standard will be noted on the ComReg website: www.callcosts.ie. Accreditation/compliance with the Bill Presentation Standard criteria will be denoted by the “Q” symbol. In addition, the level of compliance achieved will be graded by the number of stars listed in brackets, i.e., (5 stars), (4 stars), (3 stars) directly after the Q mark.
A specific section of the Bill Presentation Standard is focused on Accessibility. The Accessibility section sets out a minimum set of principles to be adhered to; ensuring that the bill is clear and easy to read. Specifically, attention is directed to the application of the following: language, fonts, colour, availability of other formats upon request, standardisation of billing terminology and consistency of language used in the bill with that used in sales information and contract documents. Electronic communications services/packages which meet the agreed accreditation levels against the Accessibility criteria of the Bill Presentation Standard will be noted on the ComReg website: www.callcosts.ie. Accreditation/compliance with the Accessibility criteria will be denoted by “Yes/No” response to the Accessibility statement.
ComReg plans to review the Bill Presentation Standard at a suitable interval and where issues arise in relation to the Accessibility section, the Forum will be invited to provide valuable input.
Please click on the following link to view the full text: Bill Presentation Standard
One Click Initiative
One of the issues established at the outset of the Forum’s establishment was the difficulty users with disabilities had with finding information on electronic service providers’ websites. It was agreed at the Forum that a link from the homepage should be available so that users with disabilities need only click one link and all the services and products provided by the electronic service provider would be available for viewing. A set of criteria to meet the one click initiative was agreed by the Forum to assist electronic service providers’ implementation of the initiative.
The following is a list of fixed line and mobile service providers who have implemented this initiative:
• Eircom
• Meteor
• O2
• 3
• Vodafone
Directory Enquiry Services
Currently Eircom, as universal service provider, provides registered customers with free access to directory inquiry services. The Forum has successfully facilitated the extension of this service to other fixed line and mobile service providers, and by doing so, providing greater choice of electronic service provider for customers with disabilities.
To view a complete list of fixed line and mobile service providers providing this service, please click on the following link: Free special directory enquiry service for registered users
Article 23(a) - Ensuring equivalence in access and choice for disabled end-users
Directive 2002/22/EC of the European Parliament was amended by Directive 2009/136/EC (“Amending Directive”) and notified in the Official Journal on 18 December 2009. 1 The Amending Directive must be transposed into Irish law by 25 May 2011.
Article 23 (a) of the Amending Directive paves the way for consumers with disabilities to be able to access and choose from the range of electronic communication services available to all consumers. In implementing the provisions of this new article, ComReg proposes to continue its work in this area on the Forum and it considers that the Forum represents a pragmatic and effective initiative to address the needs of consumers of electronic communications services with disabilities.
BEREC (Body of European Regulators for Electronic Communications) published a report in February 2011 regarding Article 23a of Directive 2009/136/EC. The purpose of the report is specifically to assist NRA’s as relevant in implementing Article 23a. T
he objectives of the Report are as follows:
a) To present information collated from NRAs regarding the current measures in place in MS,
b) To present the preliminary views of NRAs with respect to assessing and implementing equivalent access and choice, and
c) To incorporate the views, as relevant, of interested parties that responded to the public consultation and participated in BEREC’s public hearing
The following is a link to the published report: BEREC Report 2011
1 Directive 2002/22/EC of the European Parliament and of the Council of 7 March 2002 on universal service and users' rights relating to electronic communications networks and services (Universal Service Directive) as amended by Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009
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