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Memorandum

To: W3C (World Wide Web Consortium) / Web Content Accessibility Working Group

From: Donald L. Moore

Date: 07/31/2001 (This document was updated 11/13/2001 - please refer to the new version)

Re: Accessibility of Online Services and Merchants for Deaf / Hearing-Impaired Consumers


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I would like to bring to your attention about the "Accessibility of Online Services for the Deaf and Hearing-Impaired". Based on my preliminary findings, I think the issue is worth pursuing and bring to the attention of industries and businesses that frequently require interaction and communication with consumers. After reviewing your web site, it seems that there has been little coverage or discussion about ensuring that deaf / hearing-impaired consumers are properly identified, and that the proper method of communication takes place.

I examined how accessible on-line services (such as Internet banking, on-line merchants and financial services) are to the deaf / hearing-impaired population segment. Since companies are increasingly using the Internet for marketing, servicing, and offering of services to consumers, it brings up new problems. Online services accessibility issues warrants further attention due to the increased potential for communication mishaps for financial institutions and on-line merchants not properly or adequately servicing this population segment. This is an issue worth looking into because there are approximately 28 million Americans that fall into this population segment ^{1, 2}. Furthermore, as the U.S. population lives longer and ages, more individuals will fall into this segment.

Two examples of potential communication breakdowns are illustrated below:

Example 1 (On-line Credit and Loan Applications)
Consumer "A", who is deaf / hearing-impaired, goes to BankABC's web site and applies for a loan. The online application requires that they complete the form with personal information such as: name, address, telephone numbers, and if appropriate their credit information. Occasionally (and often) financial institutions need to contact the applicant for more information and / or to follow up on the application. If the financial institution does not know how to appropriately contact and work with the deaf / hearing-impaired applicant, their application may be rejected since they were not able to conduct a follow up. Consequently, it becomes an inconvenience for the consumer, increases operating costs for the bank or business, and potentially places the customer's reputation and credit information at risk.

The culprit: BankABC's web site failed to offer additional fields on their online application to allow Consumer "A" to specify how they should be contacted - whether by TTD, Relay Service, e-mail, or by other means. They also fail to recognize the communication problem and properly address it. This is just one prime example of what could go wrong. Even as online banking and merchants continue to become more popular and mainstream form of everyday consumer services, communication problems with this population segment remains.

Example 2 (Job Applicant)
The Internet has also become a popular way to search and apply for jobs. Job sites such as Monster.com, Hotjobs.com, and organizations allow for on-line filing of resumes and job postings. Thus, applicants are usually required to supply their telephone contact information to allow them to be contacted for further inquiries. However, the organization, recruiter, or search firm may not be aware that the applicant is deaf / hearing-impaired and requires that they utilize other means of communication such as the TTD and/or relay services.

While Internet e-mail is often a popular way to communicate, it is not an entirely secure form of communication, and is not always recommended. In addition, by listing a TTD number on one's web site does not mean that they know how to service deaf / hearing-impaired consumers. On-line web forms fail to help identify the need to use TTDs or other means of communication for deaf / hearing-impaired consumers.

Example of an Web Form That Helps To Identify How The Consumer Should Be Contacted
(On-line version of this form: deafcontactform.htm)

Points to consider

1. Some people within this community may fear that they would be immediately rejected if it is known that they are deaf / hearing-impaired. While others will greatly appreciate improved levels of communication and services.
2. While this recommendation points out deficiencies with web based forms and pages, many organzations still are not familiar with the low cost / free available options for communicating with deaf / hearing-impaired consumers. For instance, many states offer free relay services - which can be used to call deaf / hearing-impaired parties for no charge (cellular and long distance charges, etc. still apply).
3. You may want to consult with other organizations on this recommendation and their views. The National Association of the Deaf (NAD) is a potential starting place. If needed, I could assist in this matter.
   
   
   If you would like to discuss this issue further, have recommendations on how we can proceed, or have any questions or comments, please feel free to contact me via e-mail at [email protected]

   References:

   1. "About N.A.D", National Association of the Deaf (NAD), http://www.nad.org/about/

   2. Carmen, Richard. The Consumer Handbook on Hearing Loss & Hearing Aids: A Bridge to Healing, pg. 21, 2000.
   
   
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