The CSSD Shocker

A few weeks ago, I wrote an editorial on the matter of the Canadian Society for Social Development, the CSSD. In my editorial, I gave details as to how this organization is presently misleading Canadians through its mission statement and how in reality; whereas it states through its mission statement that its courses is opened to all Canadians with disabilities, this is not the case. The sad truth is that this organization has deliberately chosen to bar blind and visually impaired Canadians from one of its courses, the IBDE course,(Internet Business Development for Entrepreneurs ) sighting the following reasons:

• It is much too costly for them to offer their course to persons with greater than 30% loss of vision.
• Access technology for the blind and visually impaired is not compatible with the software and technology that they presently use.
• It would be much too costly for them to accommodate blind and visually impaired students.

Shocker or shaker? A shocker and a huge disgrace. Above all, a gross insult to the dignity of blind and visually impaired Canadians.

Over the past two months, I along with other stakeholders and accessibility experts have spent many hours trying to understand the logic of this organization's criteria. We have examined the contents of their course, their mission statement, and letters have been written to them by Elizabeth Lalonde of the Canadian Federation for the blind and John Rae of the Alliance for the equality of blind Canadians. I am not going to take up your precious time with publishing the exchange of correspondence between the various letter writers but what I am going to do is: 1 Share with you a blurb from the latest Abilities electronic newsletter 2 Share with you the letter that was written to Elizabeth Lalonde by Kay Ryan, the executive director of the CSSD in response to Elizabeth's letter 3 Point out some bewildering statements made in the Abilities electronic newsletter by the CSSD 4 Share with you some comments and analysis by stakeholders.

This is the blurb that appears in the Abilities electronic newsletter. Canadian Society for Social Development (CSSD) is promoting two online national training programs designed especially for persons with disabilities and others facing barriers to employment. The CSSD programs Business Abilities and Internet Business Development for Entrepreneurs (IBDE) deliver challenge, camaraderie and learning enjoyment while bringing hope and the opportunity for a better future.

Business Abilities is the online business management program which is currently only available to PWD. Enrollment is ongoing, and clients can apply anytime at www.businessabilities.ca/?q=signup Tuition for this program is generously provided by Human Resources and Social Development Canada (HRSDC).

IBDE is a program where students learn web design. The course is a six-month 30 hours per week program and is accredited by Selkirk College. The next intake for IBDE is fall 2008, clients can access the registration page at www.ibde.ca/signup

Students are responsible for their own tuition, which is usually available locally. CSSD staff is available to assist students in finding this funding. --------------------------------------------------------------------------------

When Elizabeth Lalonde wrote to Kay Ryan, executive director, outlining the CFB's concerns, Ms Ryan responded with the following:

Dear Ms. Lalonde In reply to a letter we received today from your office, signed by a D. Belusoz, we would like to take this opportunity to give you a bit more information about us.

CSSD is a small non-profit society that offers two online programs across Canada for persons with disabilities, and just recently we have opened up our IBDE web design program to individuals facing other barriers to employment.

We are a virtual organization with employees working from home offices, so you can see that we are a very small organization trying to provide a service on a very tight budget. Our Business Abilities program does receive federal funding. It is fully accessible and has been audited by a WC-3 expert. Our IBDE web design program did receive some federal funding to allow us to promote the program nationally. However, we are now trying to conduct our next intake solely from student tuition that qualifying students can usually access from their local Service Canada offices.

We have only been in existence for three years, and we are trying our best to perfect our programs as we grow. We have learned a lot over the past few years, and we have made great strides in trying to accommodate as many disabilities as possible. We have also learned that there are hundreds of disabilities that people can have that require many special considerations, so we do recognize that we cannot be everything to everyone. You will note, though, that we do have a disclaimer on our IBDE website that states:

( http://www.ibde.ca/about) (Please note that CSSD strives to support all persons with disabilities, however due to the nature of our curriculum some disability types cannot currently be accommodated but we are looking at ways to improve this).

A student without at least 30 percent vision would not be able to participate in our IBDE course. The reason for this is because our curriculum is integrated with third party web authoring software from Microsoft and Adobe, which include toolbox fly-out menus and drop down menu options that are not accessible with screen readers.

I totally understand that websites can be created using only HTML and XHTML. However, we teach with third party software, because our course is only six months long and we find that by using web authoring software we can teach basic web design in this timeframe.

When we first started out we were using textbooks to supplement our online IBDE curriculum, but we found that students who were quadriplegic and others with dexterity issues could not turn the pages and those with visual impairments could not see the words. So last year we managed to find CD text books to solve that problem.

However, we are now discovering that this will not work with our participants who have hearing loss, so we are now trying to locate text copies of these CDs from the publishers. As you can appreciate, the obstacles we face are many, but we are trying our best to accommodate as many people as possible on our limited budget.

We have investigated what would be involved to accommodate students with no sight in the IBDE course. The result of our investigation leads us to conclude that the following accommodation measures would have to be taken, requiring the society to:

• a. Totally rewrite our curriculum so it eliminates third party web authoring software (a very lengthy and costly undertaking)
• b. Extend the length of our course (we find now that most people do not want a course longer than six months)
• c. Discontinue the use of visual examples and instead use all written descriptions (which would not be as effective for students with vision)
• d. Eliminate the graphic design segment of the program (which our instructors feel is an essential component of web design today)
• e. Hire more instructors in order to work full time with the visually impaired students

Regrettably, it would not be feasible for the society to bear the cost associated with implementing these accommodation measures.

We honestly have tried our best with our limited resources to make the IBDE course available to as many people with disabilities as possible, and we hope to be able to continue to make improvements each year so we can accommodate more participants. We hope you understand that, because we do not have an unlimited budget, there will always be some people that we will not be able to offer our training to. I would like you to know though that we do interview each applicant individually and are as honest as possible with them in regards to any limitations they could experience. This is only fair, as we want to be sure that their tuition dollars are not wasted.

I will certainly pass along your concerns regarding the captcha validation code to our web master and if he needs any assistance with correcting this problem I will have him either contact the web accessible expert that audited our site or I will have him contact you. Did you happen to check out our other online program at www.businessabilities.ca to see if we have the same issue there? We would appreciate hearing back from you on that matter as we believe that site is totally accessible to all persons with disabilities Thank you for sharing your concerns with us. We always appreciate feedback from other agencies.

Kay Ryan
Executive Director
Canadian Society for Social Development
3069 Miller Rd.
Nelson BC V1L 6Z8
kryan@cssd-web.org
250-825-9433 (direct line)
Check out: http://www.cssd-web.org
http://www.businessabilities.ca
http://www.ibde.ca
http://www.virtualmall.ca

Sign-up for our free "Successabilities" newsletter at: http://www.cssd-web.org

So now you are probably asking yourselves what is wrong with this entire picture? Why am I so angry, furious, and totally blown away by Ms Ryan's response? Well, here goes!

This letter is probably one of the most insulting and condescending that I have ever seen in my life. Whereas Ms Ryan has gone to great lengths to expound on the descriptions of her organization's courses, it should not be lost on the reader that she has stated in other words:

• 1 It is much too costly to accommodate blind and visually impaired students. Too costly to hire instructors to teach us, and too costly to implement the changes that she outlines despite the generous funding that has been alluded to in the Abilities electronic newsletter.
• 2 She goes to great lengths to state that due to third party software, it is practically impossible to make changes to accommodate blind and visually impaired students.
• 3 She emphatically states that most persons prefer a six months course and that if the CSSD were to change its course to accommodate blind and visually impaired students, the course would have to run for a longer period of time.
• 4 Ms Ryan states that a web accessible expert audited their website for accessibility and that it was found to be acceptable.
• 5 The CSSD talks about helping to bring hope and opportunity for a better future to its students but how does this statement apply to blind and visually impaired persons when they are being deliberately prevented from taking the IBDE course?
• 6 The CSSD talks about offering their courses to those facing barriers to employment but somehow they do not seem to think that blind and visually impaired persons also face barriers to employment.

I would now like to address my comments directly to Ms Ryan's attention as follows:
Dear Ms Ryan, It appears from your response to Ms Lalonde, that you seem to have conveniently forgotten that when it comes to persons with disabilities, blind and visually impaired persons are definitely included in this group. You have stated that you have learned a lot since your inception as an organization three years ago but I beg to differ. You have unwittingly insulted and condescended to us as a community. Your organization is bold enough to release a mission statement which says that your IBDE course is open to all Canadians with disabilities but this is not so. It is not open to the blind and visually impaired and what I have a very hard time comprehending is this: How did your organization come up with the criteria for accepting students with no more than 30% loss of vision? In using this measurement you have effectively shut out all legally blind Canadians from your IBDE program. You have stated that you are being funded by HRDC but what you may have conveniently forgotten is that if you are being funded by the Federal government then you are obligated to accept all Canadians into your program.

With regard to having been audited by a WC-3 expert, I find it difficult to understand how your web master was allowed to implement a CAPTCHA feature that is totally inaccessible to blind and visually impaired persons. There a specific guidelines for implementing this feature and any WC-3 expert would have known this. In addition, I do have some glaring points to bring to your attention as follows:

• First, the correct terminology is W3C and not WC-3 as you stated above.
• Second, here are a few points that we found with regard to inaccessibility of your websites. http://www.ibde.ca/about/access, it is your Accessibility Statement. We found the following:
• • 1) Invalid code is being used
  • 2) There is improper nesting of headings
  • 3) There is a link that made no sense when read out of context and did not warn that it opened a pdf file
  • 4) There is no way to customize the colors of the site, even though you made this statement, "Color Contrast = We have carefully measured the contrast of color combinations used on the site to ensure those with low vision can easily read all content." This isn't true, it is difficult to read black text on white background.
  • 5) On this home page new windos are opened without warning
  • 6) PDF content is not an alternate format for blind and visually impaired Canadians as they are unable to read PDF content
  • 7) A check of one of your other student sites revealed that it is not very accessible

Ms Ryan, I think that you need to take responsibility for this very embarrassing situation. You have pointed to such things as third party software, immense costs for accommodations, a limited budget, plus more for your inability to accommodate blind and visually impaired applicants. However, I think that both you and your organization need to take full responsibility for the total lack of understanding and an unwillingness to work with the blind and visually impaired community in order to make this course accessible to the blind and visually impaired. You have in essence stated to Ms Lalonde that you do not have any intension of changing your policy because of the reasons that you gave. This to me speaks to arrogance and it is very sad to see that an organization such as yours can hope to do this without being noticed.

I would like to close in making the following suggestions to you:

• 1 If you honestly feel that you are truly unable to accommodate blind and visually impaired applicants, then you need to change your mission statement to reflect that blind and visually impaired persons are not included in your course offerings.
• 2 If you wish to continue serving all Canadians with disabilities, then you should make it a priority to obtain the necessary funding to do so. As I mentioned above, whenever the Federal government funds a project, it means that the project must be made available to all Canadians.
• 3 I would like to suggest that your staff take the time to thoroughly investigate how and where they can make this course accessible to blind and visually impaired Canadians.
• 4 You should probably revisit your criteria when it comes to the no > 30 % loss of vision. I would like you to tell us how you came to adopt this measure of vision as part of your requirements.
• 5 You should probably ask your web access expert to re-audit your websites as they are glaring inaccessibilities on them. These include the CAPTCHA function and points outlined above.
• 6 I would like to know if you plan to offer a component in your IBDE course to teach web accessibility to your students.
• Finally, I would like to suggest that you take the opportunity to consult with organizations that can help you to make your course accessible to blind and visually impaired Canadians. Organizations such as the Canadian Federation for the Blind and the Alliance for the Equality of Blind Canadians. A letter such as the one that you wrote to Ms Lalonde is simply unacceptable and gives the impression that you are not prepared to work to right a wrong.

As I see it, you have only two choices. The first is that you live up to the promise of your mission statement by taking the necessary steps to include blind and visually impaired students in your course. The second is you do nothing and you will affectively be discriminating against us as a community.

If you choose this path then you should be responsible enough to change your mission statement to reflect that you do not offer your course to blind and visually impaired applicants. The choice is yours Ms Ryan! Do the right thing or face the consequences of being the head of an organization that openly discriminates against blind and visually impaired Canadians.

I'm Donna J Jodhan your free lance writer and reporterwishing you a terrific day.

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