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CNIB Response: Ontario's Data Strategy

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CNIB welcomes the introduction of an Ontario Data Strategy and the opportunity to respond to the government's consultation to ensure the proposed solutions will benefit more than 680,000 Ontarians living with sight loss. Historically, interactions with essential government services have relied heavily on lengthy paperwork processes, which are often inaccessible to people who are blind or partially sighted. With accessibility software (e.g. magnifiers/screen readers), Ontarians living with sight loss should be able to fully access and engage with the Ontario government's digital platforms. We want to work together to ensure online government services are fully accessible for everyone.

Our response focuses on three areas:

  1. Accessibility of Digital Data 
  2. "Once Only" principle
  3. Accessible Open Source Data

Accessibility of Digital Data

Accessibility and universal design benefit all Ontarians. When website information and processes (e.g. application forms or appointment booking portals) are accessible, it's easier for everyone, regardless of ability. When someone can complete a task online, such as renewing a health card, it is more efficient – it reduces wait times, provides good customer service and eliminates unnecessary red tape. Unless there's an issue with the system, there's no reason to contact a government call centre or go to a government office.

  • As a minimum, all systems must be fully accessible to the end user and meet WCAG 2.0 AA/AAA and AODA Information and Communications Standards. When CNIB has attempted to engage in previous online consultations under the current and previous governments, we have found parts of the Ontario government website to be inaccessible. This creates unnecessary barriers for people trying to access and engage with the Ontario government's services.
  • With the Ontario government's focus on being Open for Business, the province must be able to attract and retain employment talent from the disability community. Therefore, all back-end government applications must be fully accessible to employees. With this in place, the Ontario Public Service would become a role model in hiring, accommodating and supporting people with disabilities. As highlighted in CNIB's recent Re-Vision ADP Report, there are administration processes within the Assistive Devices Program (ADP) that are inaccessible. As a result, it's difficult for applicants to access the program, and many of the ADP authorizers with sight loss are unable to carry out their jobs effectively. This is unacceptable for a program that is designed to serve people with disabilities.
  • In response to the provincial government's proposed Optimized Procurement Spending, the government should ensure that taxpayer money is not spent on purchasing inaccessible digital systems. All companies should demonstrate that their software or platforms are fully accessible, meeting the legal standards outlined above as an absolute minimum. And, any physical devices that are procured (e.g. electronic check-in kiosks that contain software) should be fully accessible – the USA uses Section 508 standards to ensure kiosk accessibility. The provincial government should incorporate end-user testing with Ontarians with disabilities before a system is launched – this would be efficient and cost-effective.
  • In response to Data Talent and Skills Within Government, we are in support of building data skills within government. Anyone who is working on digital or data-related work must be trained on job-specific digital accessibility, from basic to expert knowledge, depending on their job function and level. This could be delivered through existing training programs that exist within the Ontario Digital Service and the Employment and Training Division of the Ontario Ministry of Training, Colleges and Universities.  

Once Only Principle

We are a strong supporter of the Once Only principle and linking data across all government platforms. If this is put into practice, someone with a disability would only need to tell government their accessibility requirements once. As a result, any system- generated letters would be automatically distributed in the preferred format.

In 2018, Cancer Care Ontario issued a system-generated letter campaign that encouraged Cervical Screening Program recipients to get tested. Unfortunately, this letter was sent to individuals in print only. At the end of the letter, recipients were advised to contact the agency if they needed the letter in an accessible format, but there's no guarantee that the recipient would be able to see that note. This puts the health of Ontarians who are blind or partially sighted at risk. If someone can inform the government once of their preferred format (e.g. braille, large print or email, etc.), they would have seamless access to their own health information, and they wouldn't have to jump through unnecessary hoops and red tape to get the same information that other Ontarians receive. The NHS in England has been trying to achieve a similar goal through their Accessible Information Standard.

Accessible Open Source Data 

Many people don't realize the tremendous impact modern smartphones have in the lives of individuals who are blind or partially sighted. Today, accessible smartphone apps make it possible for people with sight loss to do all kinds of things that may have seemed challenging before. 

Providing standardized, purposeful and open source data has the potential to provide up-to-date and accurate data that can be used through various third-party accessibility apps. But, in order to achieve this through API (application programming interfaces) data sharing, the data must be fully accessible, so it can be shared with everyone, including Ontarians who are blind or partially sighted. 

For example, someone with sight loss may learn about an upcoming sidewalk closure via their accessibility app of choice and decide how they wish to proceed. As part of the development of API standards, only accessible-ready data should be accepted in the Developer Resource Area. 

Kat Clarke
Manager, Advocacy and Government Affairs 
CNIB Foundation (Ontario & Quebec)
1525 Yonge Street, Toronto, ON M4T 1Z2
E: kat.clarke@cnib.ca 
T: 416-486-2500 ext. 7651
C: 647-641-4683

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