Archives for the 21st Century Response from Share The Vision 1. Share The Vision [STV] welcomes this consultation on developing a new national strategy for publicly funded archives to replace the existing 1999 government policy. STV was established in 1989 as a UK-wide partnership of the main voluntary sector organisations which produce and lend alternative format materials which meet the reading and information needs of visually impaired and other print disabled people and the main bodies for publicly funded libraries. Our objective is to enhance co-operative working within and between the sectors in order to enhance access to content for visually impaired citizens. 2. Whilst our original efforts were concerned with increasing the availability of and access to materials in the traditional alternative formats of Braille, Moon, Audio and Large Print, the technological developments in the last 10 years or more have revolutionised our work. Whilst traditional alternative formats remain crucial for accessibility, the digital age has transformed the production of alternative formats; assistive technology has presented new opportunities for visually impaired people to access content in different ways that suit their needs and skills and the amount of content which is now potentially available to them has grown exponentially. STV’s role has therefore evolved to address these new opportunities and challenges by ensuring that a basic national online catalogue of alternative formats is freely available ensuring that staff have online access to best practice guidance encouraging the provision of assistive technology in libraries campaigning to ensure that websites and digital content meet accessibility guidelines urging the Legal Deposit Advisory Panel to ensure that it takes full account of the needs of disabled people in developing its recommendations to the Secretary of State on formulating regulations to implement the Legal Deposit Libraries Act, 2003 campaigning with other bodies nationally and internationally to ensure copyright law at the national, European and international levels assists rather than prevents access to content by disabled people. 1 3. It has always been difficult for archive services to make manuscript and print contents available to blind and partially sighted users, although much can be done using magnification equipment and by producing accessible transcripts of documents as required. The digital age presents new challenges but also new opportunities to ensure that unique primary sources are accessible to blind and partially sighted people, and other disabled people. Share the Vision believes that it is essential that these challenges and opportunities are addressed in the strategy. 4. In general terms, we believe that this consultation document is a well drafted, clear and admirably brief exposition of the current position and the challenges faced by archives in ensuring they are fit for purpose in the digital age. We also agree with your recommendations to ensure that they are better organised to achieve this. Unfortunately, the vision for the future set out in section 2.1 states “Access to publicly funded archives should be available to every citizen” and goes on to mention the needs of young people and old people but not disabled people. Elsewhere in the document there are rightly references to ethnic minority communities but nowhere are disabled people mentioned. 5. It is important to remember that all publicly funded archives have a statutory Disability Equality Duty to promote “equality of opportunity between disabled persons and other people” and to “take steps to meet disabled people’s needs, even if this requires more favourable treatment.” Furthermore, on 8 June 2009 the UK ratified the UN Convention on the Rights of Persons with Disabilities. Article 21[a] of the Convention requires the provision of “information for the general public to persons with disabilities in accessible formats and technologies appropriate to different kinds of disabilities in a timely manner and without additional cost.” Digital technology - if used effectively - will help the archive profession to meet these requirements. In doing so they will extend their customer base to the more than 3 million UK citizens who are estimated to be print disabled, and many more worldwide. 6. Therefore, we would recommend that the final policy document makes explicit the duty, and the tools available, to ensure that archive materials are made accessible to all disabled people, including blind, partially sighted and print disabled people. We suggest that services would be made much more accessible by ensuring that: 2 a. All archive websites comply with the Web Accessibility Guidelines, as required by the Government’s instructions for public websites. b. Online catalogues of holdings conform to the metadata standards developed by UKOLN which take account of the resource finding needs of visually impaired people. c. Guidelines are developed to ensure that all online catalogues include sufficient, searchable, data on the physical characteristics and technical requirements of records, and the existence of location of copies, to meet the requirements of blind, partially sighted and print disabled people. We would be pleased to work with the archival community to identify the data necessary to allow blind, partially sighted and print disabled users to search for material which is already available in an appropriate format or which can be viewed in an accessible format through the use of assistive technology. d. Archive digitisation projects, whether in-house or in partnership with outside collaborators, are designed to ensure that access by disabled people is enhanced rather than prevented, as is often the case with commercial productions. e. All publicly funded archive repositories review the provision of assistive technologies available for use in search rooms to ensure the best possible access for disabled people, including blind, partially sighted and print disabled people. f. All such accessible services, online and in-house, are effectively marketed to disabled people, who may otherwise continue to assume that access to archives remains very limited. g. The archives profession seeks to work with record creators to ensure that records are created, from the outset, in formats accessible to disabled people, to ensure the increasing accessibility of the archives of the future. Whilst it may not be possible to include all these points in the Strategy itself, we would hope that they will be addressed in the Implementation Plans to follow. 7. The weakness of this document in terms of addressing the needs of disabled people is confirmed by the “Equality Impact Assessment” which is appended. The response to Question 4, “Will the policy have an impact on national or local people/staff?” refers to the impact on ethnic minority groups, socially excluded groups and older citizens but not disabled people. 3 Similarly, the response to Question 11 regarding the potential impact on the 7 Equality Target Areas provides the same response for disability as for 5 other target areas; race, gender, gender identity, religion and belief and sexual orientation, and only varies for age. No reasons or comments are given. Nowhere in the document is there any recognition of disabled people's need for accessible information and communication formats, or the exclusion which disabled people experience when they cannot access information. This is a significant differential impact which should have been identified in the equality impact assessment. We suggest that a suitable statement for the Equality Impact Assessment would be that: "It has always been difficult for archive services to make manuscript and print contents available to blind and partially sighted users although much can be done using magnification equipment and by producing accessible transcripts of documents as required. The digital age presents new challenges but also new opportunities to ensure that unique primary sources are accessible to blind and partially sighted people, and other disabled people". NOTES 8. The membership of STV comprises: Calibre Audio Library ClearVision Project RNIB British Library Chartered Institute of Library and Information Professionals [CILIP] Library and Information Services Council: Northern Ireland Scottish Library and Information Council Society of Chief [Public] Librarians Society of College, National and University Libraries Museums, Libraries and Archives Council [Observer] CyMAL: Museums, Archives and Libraries Wales, a division of the Welsh Assembly Government [Observer] The School Libraries Group [CILIP] 9. STV is content for this response to be made publicly available and is willing to assist further in the development of the strategy, if required. 4 Mark Freeman Chair, Share the Vision mark.freeman@southtyneside.gov.uk Helen Brazier Co-ordinator, Share the Vision helen.brazier@rnib.org.uk 3 August 2009 5