RNIB is the largest organisation of blind and partially sighted people in the UK and welcomes this opportunity to respond to the consultation.
With blind and partially sighted people at the heart of everything we do, our community of over 33,000 people brings together anyone affected by sight loss. More than three quarters of our Board of Trustees are blind or partially sighted. We support, empower and involve thousands of people affected by sight loss to improve lives and challenge inequalities. We engage with a wide range of politicians, organisations and professionals to achieve full inclusion through improvements to services, incomes, rights and opportunities.
We campaign for the rights of blind and partially sighted people in each of the UK’s countries. Our priorities are to:
RNIB welcomes the opportunity to respond to this consultation. Blind and partially sighted people have expressed a great deal of interest in IoT technology and its potential benefits for them.
Public Service Broadcasters (PSBs) have played a big part in driving accessibility in the UK broadcasting industry. BBC pioneered accessibility on video on demand services when the broadcaster launched audio description (AD) on the iPlayer in 2009. Channel 4 has made great efforts to change perceptions of disability with their “Meet the Superhumans” advertising campaign during the London Paralympics and the spin-off comedy show “The Last Leg”. ITV have worked with RNIB to pilot different methods of audio description for reality TV formats.
In addition. all three broadcasters have made a voluntary commitment to audio describing 20% of their content, despite the legal quota only going up to 10%, and routinely exceeding this.
RNIB regularly meets BBC, ITV and Channel 4 to discuss the accessibility of their services and have found them to be actively engaged in the meetings and keen to continue improving accessibility.
PSBs account for the majority of UK TV viewing. According to the 2019 BARB report over 70% of TV viewing was on PSB channels and PSBs also filled 4 of the top 5 positions [[i]]. The only non-PSB in the top 5 was Sky (also committed to audio describing 20% of their content) coming in 4th at 8.2%. The audience share is likely to be even higher for blind and partially sighted people due to the higher expectation of audio description
This is also true for PSB delivered catch-up services. Catch-up apps from PSBs are more likely to have audio description and are more likely to be usable by people with sight loss (either due to screenreader compatibility or good contrast). There is still work to be done on this front however. Video on demand services including broadcaster catchup services can be found on smartphones, smart TVs, set-top boxes, games consoles and built into webpages. PSBs have the highest coverage in terms of accessibility but the same catchup service will have accessibility on some platforms but not on others.
If any changes are made to the way PSBs are run (such as becoming wholly internet-based) then the level of accessibility achieved on broadcast TV in the UK must be translated across to the new service delivery model.
BBC and Channel 4 are covered by the Public Sector Equality duty which confers a responsibility to “advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it”. This requirement is important and must be kept and potentially extended to other Public Sector Broadcasters. Regardless of whether a PSB is bound by the Public Sector Equality Duty any move to a solely IP-based delivery must be predicated on the accessibility of the services across at least the most used platforms including smart phones, smart TVs and websites.
Public Sector Broadcasting makes up the majority of TV viewing in the UK today but is even more important as a driver for accessibility. PSB channels lead the way in the provision and evolution of audio description. On demand services from PSBs are more likely to be usable without sight and to have audio description. Any proposed change to the PSB model must recognise this value and safeguard this progress.
John Paton
Innovation and Technology Officer
RNIB
13/05/2020
[i] https://www.barb.co.uk/download/?file=/wp-content/uploads/2019/05/Barb-Viewing-Report-2019_32pp_FINAL-1.pdf Last checked 05/05/2020