June 26, 2025 • 15 mins
Sam speaks to Intopia's principal digital accessibility consultant, Andrew Arch, about the work Intopia have recently been doing with the Australian Human Rights Commission.
They've produced a new set of guidelines around digital access for users with disabilities including blindness or low vision which you can find here.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
S1 (00:04):
In recent weeks and months, the Australian Human Rights Commission
have updated their series of guidelines regarding best practices for
digital accessibility, often aligning with the Web Content Accessibility Guidelines.
But they go further than that. They also focus on
making digital content and experiences perceivable, operable, understandable and robust
(00:29):
for all users, including those with disabilities. And one of
the organisations that was central to giving their feedback and
insights on how to make the guidelines as effective as possible,
was Intopia, and it's my great pleasure to welcome Andrew
Arch from Intopia, their principal digital accessibility consultant, to Talking Vision. Andrew,
(00:55):
welcome to Talking Vision. Thank you very much for your time.
S2 (00:59):
Thank you for inviting us.
S1 (01:01):
Now firstly, Andrew, let's go to the heart of things
and have a bit of a chat about the guidelines themselves.
So tell us about the guidelines.
S2 (01:11):
Guidelines have been updated by the Australian Human Rights Commission
because it was recognised that the previous version and we
were up to version 4.1, I think it was, um,
we're ten years, 11 years old now and their title
gives that away. They were called, um, access for under
the World Wide Web. We don't even call it the
(01:31):
World Wide Web anymore, just the web. But digital accessibility
has become all pervasive, or digital access has become all pervasive.
You know, we've got apps, we've got software, we've got
all sorts of social media platforms. Everything you do requires
you to have some sort of nearly everything you do
requires you to have some sort of digital access these days.
(01:53):
And so it was in recognition of that all pervasive
requirement for digital access that the commission look at. It's
time to update this from just the World Wide Web, um,
which is sort of where we got started with digital
stuff in many respects, some decades ago to digital is everywhere.
That was the driver for putting this update together, and
(02:14):
the commission approached us in late 2023. Well, they put
it out to tender and we were the people who
were selected to do that in late 2023 to develop
this update, which was released in April this year. So
it took about an 18 month time frame to write
those and go through all the consultation processes and review processes.
S1 (02:37):
Tell us a bit about those processes, Andrew, and specifically
your and Netapp's involvement with the composers of the guidelines
and with the Commission and your feedback and insights.
S2 (02:52):
A couple of us in Intopia had been working on
a pro-bono version of this for a couple of years prior, primarily, um,
put together by a group of people, um, being run
by Greg Allchin from Service New South Wales. Some of
you listeners may know of Greg Olsen, and in fact,
he'll be an interesting person for you to get on
(03:13):
board in terms of all the work he's done inside
the New South Wales government to drive digital accessibility there.
Be worth a chat at some stage if you get
that opportunity. But the commission had said we haven't got
a formal process here. We need to create a formal
process for updating the note rather than this piecemeal. Yes,
it might get done. Process. So we we had a
(03:33):
draft that we'd been participating in, um, to work with
when the commission decided it needed to go to market
to formalise the whole process. And Intopia was engaged to
write the document, basically. So we had a starting point
with that material that Greg Allchin had put together. But
we also worked with the commission to say, okay, what
did they want to see in it and how should
(03:55):
it be structured? So we were in fact, we ended
up drafting some of the earlier legal stuff as well,
but that went through a lot of internal review and
rewriting inside the commission, and we took responsibility to write
the more technical side, the more standard side, the more
how should organizations do this? So that process, um, took, uh,
(04:17):
as I said, 18 months overall. And so, you know,
one of the things that we did was we set
up some advisory groups to two different advisory groups, one
looking at the technology side and one looking at the
impact on the user. So we had a some representative
user representatives, people who relied on technology and having it accessible,
as well as some organizations, um, you know, that represented
(04:39):
people with disability. So we had people who sort of
do the technical stuff and people who rely on on
the outcome of that. Um, as two different technical advisory,
two different advisory groups. The commission was also inputting into
the process, particularly, as I said, on the legal side,
but they were relying on us and the advisory groups
to sort of write the what should be included, when
should it be considered? We also went out for a
(05:02):
public comment at one point and got quite some quite
good feedback on that. Interestingly, some of the comment that
came back in the public feedback was tell us exactly
what to do. Well, these are guidelines and we can't
tell everybody exactly what to do. They need to make
that decision by themselves. But you know that that was
one of the bits of feedback that was interesting but
(05:23):
not surprising to get. We went through probably 6 or
7 drafts overall throughout that process and some restructuring, as
we worked out better ways to present a better order
to present it. The commission had quite a bit of
input into that, and so we ended up breaking it
up into three different chapters. You know, one that's more
looking at the legal stuff, one that was looking at
(05:44):
the more broadly how to and then one that final
chapter that was looking at, okay, what are the standards um,
from Standards Australia, from government, from industry and other things
that people should be looking at to adhere to the
idea of breaking it up into those three sections was
that we hope as a modular set of guidance, it
(06:04):
can be updated more frequently. And, you know, that's that's
the problem with the law. Now, the law doesn't mention
because it's 1992, pre-digital pre-web, unless you happen to be
working in CSIRO or in university at the time, it's
very hard to update the law. It's much easier to
update guidance under the law. So the Commission is hopeful
that it'll be able to keep this more up to date.
(06:25):
The way that we structured this set of guidelines versus
the way that the previous notes about the World Wide
Web accessibility had been written, that's sort of the process
that we went through.
S1 (06:34):
Fair enough. And Andrew, what's been the biggest advantages from
enterprise point of view that have come out of the
new iteration of the guidelines? What's been the most pleasing aspect?
S2 (06:48):
I think the way that we've called it out, because
a lot of people talk about the web content accessibility guidelines,
which are sort of the international standard that we all
start with and say, yeah, but that only applies to
online services to our websites and our web services. I
think the big thing here is that through this, the
commissioner has called out that you know, this applies not
just to anything online, with a browser interface, but to
(07:11):
digital books, learning materials, emails, games, mobile applications, even. You know,
we call that things like, you know, two factor authentication,
that type of issue. Um, virtual reality, you know, extended reality,
augmented reality, as we call it, digital wallets, anything that
touches digital and has a digital interface of some sort
(07:32):
to it through a screen is in scope of the
DDA and calling that out so that people can't say, oh,
the Web Content Accessibility guidelines are just about web. Yep. Okay.
We don't need to worry about them for this. So,
you know, we're also getting, you know, organizations saying, you know,
we also need to look at the stuff we've got
internally in our organization to support our staff, like the
HR system, the payroll system, and so on. So that's
(07:55):
that's some of the changes that we see being a
big win across the board.
S1 (07:59):
Andrew, I'd love to focus on a bit of a
blindness and low vision aspect. In particular. I want to
talk about the advances in things like jaws, things like
zoom text, things like Nvda, all those sort of magnification
screen readers, and also guidelines around alt text and image descriptions.
(08:20):
What's been the big things from that side of thing
that people can look forward to reading about more in
the guidelines, given the advances in 11 years with all
those sort of little bits and pieces.
S2 (08:33):
A lot of that software has come a long way,
and some of it's starting to use AI now, artificial
intelligence built into it, which is an advantage but also
a disadvantage. The other flip side of that is the
way that some organizations are using plug ins to try
and solve their accessibility problems that rely on artificial intelligence
and artificial intelligence in that respect isn't mature enough, but
(08:57):
from the assistive technology side of it, one of the
things that we're seeing and that we've emphasized in this
new guidance, is that it's not just about getting it
technically right. It also has to work for users. So
making sure that people or encouraging strongly encouraging people to
undertake usability testing with people with with disability who are
(09:19):
using assistive technologies. I mean, some of the organizations that
we in Ethiopia talk to say, yeah, yeah, we test
our stuff with Nvda, but they know what they can
see on the screen so they know what is happening
and should come out. Whereas if you get somebody who
relies on Nvidia, for instance, to run through as a
new user, if you like, then that experiences can be
(09:40):
quite different from the tech person checking it. And they
wrote it, and they know exactly what's inside it and
what to expect from, you know, how the screens will
put together, how the text was written, how the services
are meant to be interacted with. They've got that inside knowledge.
That means that they're not testing it, even though they
might be running a screen reader over it. They're not
testing it to the extent that means that it's usable
by somebody. They're just testing that. Yeah, I'm getting the
(10:02):
right sort of output here from what I expect, which
is very, very different from doing usability testing. So one
of the things that the guidelines are saying also is
you've got to consider accessibility from the start of a
tech project, and you've got to make sure that after
you've got it technically correct, you've tested it, that it's
actually usable, and then you've got to make sure that
all your maintenance considers accessibility as well, because we've always seen,
(10:25):
you know, over time, you know, little tweaks happen, pages
get rewritten, an image gets changed, and the alt text
is not updated, for instance. Um, you know, it still
talks about on the florist site, the roses for Valentine's Day,
whereas they've changed it over to chrysanthemums for Mums Day,
but didn't change the the alt text saying, you know,
red roses versus white chrysanthemums, that type of thing we're
(10:46):
talking now about in these guidelines about the whole entire
length of the project from conception to maintenance or even retirement.
So that's from the assistive tech perspective. That becomes important
that those considerations are considered early, not just the technical
risk considerations, but then those, um, assistive tech are tested
not just by somebody who knows what the product should do,
(11:08):
but by people who are going to rely on using
that assistive tech to interact with that organization.
S1 (11:13):
I'd love to touch back on that discussion you're having before,
about the increased modularity and the increased flexibility of these
new guidelines in terms of being more receptive and being
able to react in quicker time to advances in digital access,
in assistive technology and technology more broadly, really. So from
(11:38):
your perspective, what's the biggest things for people to be
aware of? Organizations in charge of things like these guidelines
to be aware of in upcoming months and years relating
to these areas of accessibility?
S2 (11:53):
Australia tends not to develop too many standards for accessibility
through standards Australia. What we tend to do, because we're
a small player internationally is adopt some of the international standards.
And so one of the standards that we adopted back
in 2016 for the first time was something called Accessibility
requirements for ICT Products and Services. So that's a standard
(12:15):
that has gone through various iterations under Standards Australia through adoption.
And we've updated that adoption half a dozen times, probably
maybe five times since we first adopted it, because the
Europeans have updated their version. So by having that in
a separate chapter in this document means that we can
refer to the latest versions of this which are going
(12:37):
to stand up, make things more accessible, because rather than
relying on something that might have been hardwired, if you like,
into the guidelines, hopefully, you know, those chapters that are
about best practice can be updated more frequently as practice
changes and expectations change. But then the chapters that refer
to both government standards and international standards that we've adopted,
(13:00):
that should be the underpinning for what people meet, as
a minimum, will also be updated on a regular basis
so that we can make sure that those can be
kept current rather than referring to wcaG two, for instance,
which has gone through wcaG 2.1 and a wcaG 2.2
over the last ten years as well. And, you know,
the note wasn't kept up to date because of the
way it was written. So that modularity, we hope, will
(13:23):
enable the Commission to keep this current.
S1 (13:25):
Now, finally, Andrew, what's the best way for people to
find out more about the guidelines or have a look
through some other resources that are available for people through
intopia around digital accessibility.
S2 (13:41):
So in conjunction with the Commission, we put together a
page of resources, and that page of resources would allow
people to go and actually listen to Rosemary, the Disability
Discrimination Commissioner, talking about the guidelines on the day that
they were released. We ran a webinar. We then ran
a webinar about a month later asking people to come
and ask some questions, because we didn't have the time
(14:03):
in the first webinar to do that. So both of
those are recorded and are available from our resources page
at intopia. That's probably the best starting point, and it
points to the commissioner's press release, as well as to
the guidelines as well as to some other resources. So
that's probably the best place to go and have a look.
But if you go straight to the Human Rights Commission's
homepage and go to disability rights, you'll find the guidelines
(14:27):
themselves there. And they've been published in HTML, in word
and in PDF in an accessible well as accessible as
PDF can be and accessible PDF. So depending on whether
people want to download and have a print copy, or
they want to read them online and how they want
to do that, there's three different formats there for people
to read.
S1 (14:45):
Perfect. Well, I've been speaking today with Andrew Arch, principal
digital accessibility consultant at Intopia, about the guidelines on equal
access to digital goods and services. Andrew, thank you very
much for your time today. It's been great to catch
up with you and have a chat about the guidelines.
S2 (15:07):
Great, and hopefully we can do something similar in the future.
In recent weeks and months, the Australian Human Rights Commission
have updated their series of guidelines regarding best practices for
digital accessibility, often aligning with the Web Content Accessibility Guidelines.
But they go further than that. They also focus on
making digital content and experiences perceivable, operable, understandable and robust
(00:29):
for all users, including those with disabilities. And one of
the organisations that was central to giving their feedback and
insights on how to make the guidelines as effective as possible,
was Intopia, and it's my great pleasure to welcome Andrew
Arch from Intopia, their principal digital accessibility consultant, to Talking Vision. Andrew,
(00:55):
welcome to Talking Vision. Thank you very much for your time.
S2 (00:59):
Thank you for inviting us.
S1 (01:01):
Now firstly, Andrew, let's go to the heart of things
and have a bit of a chat about the guidelines themselves.
So tell us about the guidelines.
S2 (01:11):
Guidelines have been updated by the Australian Human Rights Commission
because it was recognised that the previous version and we
were up to version 4.1, I think it was, um,
we're ten years, 11 years old now and their title
gives that away. They were called, um, access for under
the World Wide Web. We don't even call it the
(01:31):
World Wide Web anymore, just the web. But digital accessibility
has become all pervasive, or digital access has become all pervasive.
You know, we've got apps, we've got software, we've got
all sorts of social media platforms. Everything you do requires
you to have some sort of nearly everything you do
requires you to have some sort of digital access these days.
(01:53):
And so it was in recognition of that all pervasive
requirement for digital access that the commission look at. It's
time to update this from just the World Wide Web, um,
which is sort of where we got started with digital
stuff in many respects, some decades ago to digital is everywhere.
That was the driver for putting this update together, and
(02:14):
the commission approached us in late 2023. Well, they put
it out to tender and we were the people who
were selected to do that in late 2023 to develop
this update, which was released in April this year. So
it took about an 18 month time frame to write
those and go through all the consultation processes and review processes.
S1 (02:37):
Tell us a bit about those processes, Andrew, and specifically
your and Netapp's involvement with the composers of the guidelines
and with the Commission and your feedback and insights.
S2 (02:52):
A couple of us in Intopia had been working on
a pro-bono version of this for a couple of years prior, primarily, um,
put together by a group of people, um, being run
by Greg Allchin from Service New South Wales. Some of
you listeners may know of Greg Olsen, and in fact,
he'll be an interesting person for you to get on
(03:13):
board in terms of all the work he's done inside
the New South Wales government to drive digital accessibility there.
Be worth a chat at some stage if you get
that opportunity. But the commission had said we haven't got
a formal process here. We need to create a formal
process for updating the note rather than this piecemeal. Yes,
it might get done. Process. So we we had a
(03:33):
draft that we'd been participating in, um, to work with
when the commission decided it needed to go to market
to formalise the whole process. And Intopia was engaged to
write the document, basically. So we had a starting point
with that material that Greg Allchin had put together. But
we also worked with the commission to say, okay, what
did they want to see in it and how should
(03:55):
it be structured? So we were in fact, we ended
up drafting some of the earlier legal stuff as well,
but that went through a lot of internal review and
rewriting inside the commission, and we took responsibility to write
the more technical side, the more standard side, the more
how should organizations do this? So that process, um, took, uh,
(04:17):
as I said, 18 months overall. And so, you know,
one of the things that we did was we set
up some advisory groups to two different advisory groups, one
looking at the technology side and one looking at the
impact on the user. So we had a some representative
user representatives, people who relied on technology and having it accessible,
as well as some organizations, um, you know, that represented
(04:39):
people with disability. So we had people who sort of
do the technical stuff and people who rely on on
the outcome of that. Um, as two different technical advisory,
two different advisory groups. The commission was also inputting into
the process, particularly, as I said, on the legal side,
but they were relying on us and the advisory groups
to sort of write the what should be included, when
should it be considered? We also went out for a
(05:02):
public comment at one point and got quite some quite
good feedback on that. Interestingly, some of the comment that
came back in the public feedback was tell us exactly
what to do. Well, these are guidelines and we can't
tell everybody exactly what to do. They need to make
that decision by themselves. But you know that that was
one of the bits of feedback that was interesting but
(05:23):
not surprising to get. We went through probably 6 or
7 drafts overall throughout that process and some restructuring, as
we worked out better ways to present a better order
to present it. The commission had quite a bit of
input into that, and so we ended up breaking it
up into three different chapters. You know, one that's more
looking at the legal stuff, one that was looking at
(05:44):
the more broadly how to and then one that final
chapter that was looking at, okay, what are the standards um,
from Standards Australia, from government, from industry and other things
that people should be looking at to adhere to the
idea of breaking it up into those three sections was
that we hope as a modular set of guidance, it
(06:04):
can be updated more frequently. And, you know, that's that's
the problem with the law. Now, the law doesn't mention
because it's 1992, pre-digital pre-web, unless you happen to be
working in CSIRO or in university at the time, it's
very hard to update the law. It's much easier to
update guidance under the law. So the Commission is hopeful
that it'll be able to keep this more up to date.
(06:25):
The way that we structured this set of guidelines versus
the way that the previous notes about the World Wide
Web accessibility had been written, that's sort of the process
that we went through.
S1 (06:34):
Fair enough. And Andrew, what's been the biggest advantages from
enterprise point of view that have come out of the
new iteration of the guidelines? What's been the most pleasing aspect?
S2 (06:48):
I think the way that we've called it out, because
a lot of people talk about the web content accessibility guidelines,
which are sort of the international standard that we all
start with and say, yeah, but that only applies to
online services to our websites and our web services. I
think the big thing here is that through this, the
commissioner has called out that you know, this applies not
just to anything online, with a browser interface, but to
(07:11):
digital books, learning materials, emails, games, mobile applications, even. You know,
we call that things like, you know, two factor authentication,
that type of issue. Um, virtual reality, you know, extended reality,
augmented reality, as we call it, digital wallets, anything that
touches digital and has a digital interface of some sort
(07:32):
to it through a screen is in scope of the
DDA and calling that out so that people can't say, oh,
the Web Content Accessibility guidelines are just about web. Yep. Okay.
We don't need to worry about them for this. So,
you know, we're also getting, you know, organizations saying, you know,
we also need to look at the stuff we've got
internally in our organization to support our staff, like the
HR system, the payroll system, and so on. So that's
(07:55):
that's some of the changes that we see being a
big win across the board.
S1 (07:59):
Andrew, I'd love to focus on a bit of a
blindness and low vision aspect. In particular. I want to
talk about the advances in things like jaws, things like
zoom text, things like Nvda, all those sort of magnification
screen readers, and also guidelines around alt text and image descriptions.
(08:20):
What's been the big things from that side of thing
that people can look forward to reading about more in
the guidelines, given the advances in 11 years with all
those sort of little bits and pieces.
S2 (08:33):
A lot of that software has come a long way,
and some of it's starting to use AI now, artificial
intelligence built into it, which is an advantage but also
a disadvantage. The other flip side of that is the
way that some organizations are using plug ins to try
and solve their accessibility problems that rely on artificial intelligence
and artificial intelligence in that respect isn't mature enough, but
(08:57):
from the assistive technology side of it, one of the
things that we're seeing and that we've emphasized in this
new guidance, is that it's not just about getting it
technically right. It also has to work for users. So
making sure that people or encouraging strongly encouraging people to
undertake usability testing with people with with disability who are
(09:19):
using assistive technologies. I mean, some of the organizations that
we in Ethiopia talk to say, yeah, yeah, we test
our stuff with Nvda, but they know what they can
see on the screen so they know what is happening
and should come out. Whereas if you get somebody who
relies on Nvidia, for instance, to run through as a
new user, if you like, then that experiences can be
(09:40):
quite different from the tech person checking it. And they
wrote it, and they know exactly what's inside it and
what to expect from, you know, how the screens will
put together, how the text was written, how the services
are meant to be interacted with. They've got that inside knowledge.
That means that they're not testing it, even though they
might be running a screen reader over it. They're not
testing it to the extent that means that it's usable
by somebody. They're just testing that. Yeah, I'm getting the
(10:02):
right sort of output here from what I expect, which
is very, very different from doing usability testing. So one
of the things that the guidelines are saying also is
you've got to consider accessibility from the start of a
tech project, and you've got to make sure that after
you've got it technically correct, you've tested it, that it's
actually usable, and then you've got to make sure that
all your maintenance considers accessibility as well, because we've always seen,
(10:25):
you know, over time, you know, little tweaks happen, pages
get rewritten, an image gets changed, and the alt text
is not updated, for instance. Um, you know, it still
talks about on the florist site, the roses for Valentine's Day,
whereas they've changed it over to chrysanthemums for Mums Day,
but didn't change the the alt text saying, you know,
red roses versus white chrysanthemums, that type of thing we're
(10:46):
talking now about in these guidelines about the whole entire
length of the project from conception to maintenance or even retirement.
So that's from the assistive tech perspective. That becomes important
that those considerations are considered early, not just the technical
risk considerations, but then those, um, assistive tech are tested
not just by somebody who knows what the product should do,
(11:08):
but by people who are going to rely on using
that assistive tech to interact with that organization.
S1 (11:13):
I'd love to touch back on that discussion you're having before,
about the increased modularity and the increased flexibility of these
new guidelines in terms of being more receptive and being
able to react in quicker time to advances in digital access,
in assistive technology and technology more broadly, really. So from
(11:38):
your perspective, what's the biggest things for people to be
aware of? Organizations in charge of things like these guidelines
to be aware of in upcoming months and years relating
to these areas of accessibility?
S2 (11:53):
Australia tends not to develop too many standards for accessibility
through standards Australia. What we tend to do, because we're
a small player internationally is adopt some of the international standards.
And so one of the standards that we adopted back
in 2016 for the first time was something called Accessibility
requirements for ICT Products and Services. So that's a standard
(12:15):
that has gone through various iterations under Standards Australia through adoption.
And we've updated that adoption half a dozen times, probably
maybe five times since we first adopted it, because the
Europeans have updated their version. So by having that in
a separate chapter in this document means that we can
refer to the latest versions of this which are going
(12:37):
to stand up, make things more accessible, because rather than
relying on something that might have been hardwired, if you like,
into the guidelines, hopefully, you know, those chapters that are
about best practice can be updated more frequently as practice
changes and expectations change. But then the chapters that refer
to both government standards and international standards that we've adopted,
(13:00):
that should be the underpinning for what people meet, as
a minimum, will also be updated on a regular basis
so that we can make sure that those can be
kept current rather than referring to wcaG two, for instance,
which has gone through wcaG 2.1 and a wcaG 2.2
over the last ten years as well. And, you know,
the note wasn't kept up to date because of the
way it was written. So that modularity, we hope, will
(13:23):
enable the Commission to keep this current.
S1 (13:25):
Now, finally, Andrew, what's the best way for people to
find out more about the guidelines or have a look
through some other resources that are available for people through
intopia around digital accessibility.
S2 (13:41):
So in conjunction with the Commission, we put together a
page of resources, and that page of resources would allow
people to go and actually listen to Rosemary, the Disability
Discrimination Commissioner, talking about the guidelines on the day that
they were released. We ran a webinar. We then ran
a webinar about a month later asking people to come
and ask some questions, because we didn't have the time
(14:03):
in the first webinar to do that. So both of
those are recorded and are available from our resources page
at intopia. That's probably the best starting point, and it
points to the commissioner's press release, as well as to
the guidelines as well as to some other resources. So
that's probably the best place to go and have a look.
But if you go straight to the Human Rights Commission's
homepage and go to disability rights, you'll find the guidelines
(14:27):
themselves there. And they've been published in HTML, in word
and in PDF in an accessible well as accessible as
PDF can be and accessible PDF. So depending on whether
people want to download and have a print copy, or
they want to read them online and how they want
to do that, there's three different formats there for people
to read.
S1 (14:45):
Perfect. Well, I've been speaking today with Andrew Arch, principal
digital accessibility consultant at Intopia, about the guidelines on equal
access to digital goods and services. Andrew, thank you very
much for your time today. It's been great to catch
up with you and have a chat about the guidelines.
S2 (15:07):
Great, and hopefully we can do something similar in the future.
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