Digital libraries

EBU Response to the European Union consultation
on the establishment of a European digital library
(COM (2005) 465 FINAL)



1. Introduction

1.1 The European Blind Union (EBU) welcomes the initiative on digital libraries launched by the European Commission within the framework of the i2010 flagship initiative. We appreciate the opportunity to provide input at this early stage of the digitisation process

1.2 EBU is a non-governmental, non profit-making European organisation founded in 1984. We are recognised and supported by the European Commission. One of the six regional bodies of the World Blind Union, it is the only Europe-wide organisation representing the interests of blind and partially sighted people.

1.3 EBU aims to protect and promote the interests of all blind and partially sighted people in Europe. EBU currently has 44 member countries; each represented by a national delegation. Its work is directed by an Executive Board of 11 elected members, which is accountable to a General Assembly held every four years. The detailed work of EBU is carried out by Standing Commissions and Working Groups, whose areas of activity reflect the interests of EBU members. We are affiliated to the European Disability Forum.

1.4 EBU is happy for the Commission to use and disseminate this response and is keen to be further consulted as the digital library project proceeds.


2. Social inclusion

2.1 The Commission has a duty to ensure that the digital library project develops in such a way as to guarantee full accessibility for disabled citizens in general, and those who are blind or partially sighted in particular.

2.2 It is essential that the project develops within the overall context of Europe's e-accessibility programme. It is vital to take these issues into account from the outset, while technical and procedural standards are still being developed. Retrospective work on accessibility for people with disabilities will be much more expensive and much less effective.


2.3 Some thirty million people in the European Union have some form of visual impairment, while a great many others experience difficulty in accessing information as a result of dyslexia or other reading related disabilities. Denying access to the material in question to a significant proportion of the population would undermine the ultimate aim of this initiative, to enhance competitiveness across Europe. It would also be contrary to basic concepts of fairness and social inclusion.

2.4 Digitisation, and the overall spread of information and communications technology (ICT) is potentially hugely promising. . People with a sensory disability have for many years had fewer opportunities to read using traditional and specific reading and writing methods. Documents have been inaccessible not because of their location but because they existed only on paper. Broadening the range of what is available could secure the inclusion of people with a visual impairment in this fundamental process. On the other hand, if the needs of these users are overlooked, a golden opportunity will have been lost.


2.5 To advance the needs and interests of people with visual impairment and safeguard their equal opportunities, we wish to put forward a number of suggestions that will help to guarantee that this group does not suffer discrimination or exclusion from this interesting and necessary European initiative.



3. Involvement of People with Disabilities

3.1 To provide expert opinions and existing expertise on universal accessibility, it will be vital to have at least one representative of people with disabilities on the high level group of experts the Commission intends to set up.

3.2 In addition, it is essential that disabled librarians and other users, including a cross-section of blind and partially sighted people, are involved in testing and evaluating the project at all levels as it develops. We recommend close liaison with bodies such as the Libraries for the Blind Section of the International Federation of Library Associations (IFLA).



4. True Accessibility

4.1 In its Communication the Commission employs the term “accessibility” in a general sense, without specifically mentioning the accessibility of digital libraries to people with disabilities. The fact that information is "accessible" to the public, by virtue of being on a publicly accessible web site, does not mean everyone can "access" or read it.

4.2 Blind, partially sighted and other print disabled people must be able to access material through audio or tactile output or by enlarging or otherwise modifying the visual display. Poor design, inappropriate formats or inept protection measures can render such access impossible.


4.3 Consequently, we believe it is vital to define clearly the concept of “accessibility” by extending it to “universal accessibility”. This concept covers a condition that must be met by all environments, processes, goods, products and services and by all objects and instruments, tools and devices in order for them to be comprehensible, usable and practicable for all people, including people with a disability, in line with the e-Accessibility stream of the i2010 strategy.

4.4 Similarly, we believe future instruments related to this subject, such as the forthcoming Recommendation on digitisation and digital preservation and the Communication on the accessibility of scientific information, should specifically take universal accessibility into account from the outset.



4.5 More broadly, support should be given to initiatives such as horizontal accessibility programmes that, on the one hand, ensure that projects receiving funding are accessible and, on the other, provide additional financial support to those projects that more thoroughly address the issue of accessibility. The seventh Framework programme, the e-Content plus programme, the Culture 2007 programme and structural funds should all be addressed from this perspective.



5. Design and Technical Criteria

5.1 The so-called “on-line accessibility” of material, an expression used many times during the consultation, must be fulfilled in its widest sense. It must enable any European citizen, using any ICT tool, to read any document placed at his or her disposal. If this is not the case, people with disabilities will never be in a position to benefit from digitisation and the creation of a European digital library.


5.2 In all digital library projects, the highest standards of web design must be routinely observed. The guidelines laid down by the Web Access Initiative (www.w3c.org/) must be fully implemented.

5.3 Accessibility is changing rapidly: from an add-on element that was only taken into account at the end of the information production chain, it is fast becoming a driving force for change. New technologies are emerging that enable information producers to structure documents that meet current accessibility legislation. This process opens up new markets and new opportunities for this material. By integrating existing technologies with processing systems it is possible to incorporate actively the different needs of end users, thus widening the range of opportunities to use the same information. At the same time, new and powerful ways to handle information, benefiting all possible users, emerge as the content is structured more clearly.

5.4 Thus there is great potential for building in true accessibility. However, even existing access features are not always used by content authors, ignorant of their existence or their importance.

5.5 At the present time, we can and should benefit from current existing standards concerning the creation and structuring of digital documents that can be handled by blind and partially sighted persons. It is not necessary to use special formats or formats that are difficult to migrate to other standards, nor add yet another process at the end of the digitisation and storage chain. From the outset we should select and apply one of the different document creation standards that fulfil accessibility guidelines. Document creation standards used by a great number of large European printing houses, such as XML (in its widest sense, or the different types that have been developed for specific kinds of documentation) provide important benefits both to those producing the document and those who will later read it.

5.6 We strongly urge the leaders of the digital library project to work closely with the partners in the EUAIN Project (www.euain.org), funded under the Sixth Framework Programme, which is addressing all these issues.

5.7 We also commend to the project team the work of the Daisy Consortium (www.daisy.org).

5.8 We should bear in mind that digitised documents whose end format will be an image or a number of images that show the different pages of the original document are only accessible to fully sighted people. We are, of course, aware of the need to preserve the look and appearance of certain documents due to their historic value, for aesthetic reasons and so on but, regardless of how content is presented, is it equally important to make it known to all European citizens.

5.9 Little will have been gained if accessible web sites lead only to documents and records which are themselves inaccessible because of the way in which they had been digitised.

5.10 There is a particular problem with handwritten documents. We are not aware of any existing programmes which can scan handwriting in such a way as to produce records accessible by non-visual means. To transcribe handwritten material would be very labour-intensive and thus very expensive. We therefore call for resources to be devoted to research into ways of scanning handwriting which result in accessible records. Failing this, resources will have to be devoted to manual transcription if digitised documents are to be truly accessible.



6. Copyright

6.1 The attitude of those who hold copyright in documents in digital format will have a serious impact on the extent to which these works are made available to the general public. It is therefore advisable to separate the two processes of digitisation and access to the digital document. This will secure the digitisation of as much information as possible. Access can then be accorded or denied on the basis of exceptions to copyright for various categories of people.

6.2 The European Copyright Directive (EC/2001/29) allows member states to enact copyright exceptions for the benefit, inter alia, of people with reading related disabilities and of libraries. Unfortunately, it does not require such exceptions, nor does it in any way guarantee consistency amongst the twenty-five legal regimes in the Community. Pending any improvement to this shortcoming in copyright legislation, those who do benefit from exceptions should be able to enjoy them in accessing the riches of digitised library records.



7. Digital Rights Management

7.1 There are now technological methods to protect digital documentation and control access to it. These methods vary in sophistication and effectiveness. They can inadvertently or deliberately exclude people using screen reading technology to access content. Thus extreme care should be exercised in determining what rights management or access protection technologies are deployed.

7.2 We require the same level of services for the proposed digital library as exists for conventional libraries. A digital library should be no different from a “paper” library in terms of the right to read works that are copyrighted as an alternative to acquiring a personal copy of the work. Accessing a document in digital format to read it does not necessarily mean it is downloaded or that a permanent copy is being stored, nor does it imply that it will be used or distributed indiscriminately (as with printed books, which are lent out but are not necessarily copied indiscriminately, although this is possible).

7.3 Technical measures that already exist, or that may be developed, to protect digital documents (Digital Rights Management) enable us to control the reading, download, copying and distribution of documents. In the case of material that may form part of the European digital library archive, it is vitally important that the rights of blind and partially sighted users to access works that are protected by some technical measures are respected.



8. Legal Deposit

8.1 It would also be advisable to enhance the standardisation of rules regarding the legal deposit of material in each Member State.

8.2 One possibility would be to create a European legal deposit for material in digital format or digitised material that can be accessed from different countries and to which certain authorised companies, organisations or public bodies could have access within the limits set down in each case.

8.3 In the same way, it is vital that protected material is handed over to the respective legal deposit bodies without such protection in order to guarantee that people with disabilities may exercise their right to access all protected digital material.



9. Next steps

The European Blind Union would be pleased to remain involved in this project.

 

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