Stakeholder Position: RNIB

1) Attending the Registration/Enrolment Centre

Many disabled people will be unable to travel independently to registration centres if they are not nearby. This could be because they are blind, have a mobility impairment, or need assistance when moving around.

 

Inaccessible public transport, lack of regular services, or insufficient mobility training around the pedestrian environment will all impact on people’s ability to travel and must be recognised as barriers.

 

Some people will incur disproportionate costs by having to travel by taxi to and from Registration Centres. In these cases we believe that the Government should meet the costs of travel and provide advice and assistance to people who are unable to travel independently to the Centre.

 

It would be unacceptable to introduce a system whereby disabled people are expected, once given a notification requiring them to register, to travel to Registration Centres without assistance, or risk a fine for non-attendance.

 

The Bill does in section 36 give the Secretary of State powers to establish a Code of Practice on penalties that might waive fines in these circumstances.

 

However, a system that failed to provide transport support for disabled people and then sought to fine them for failing to register would cause huge anxiety and distress and would be unacceptable, even if a fine were then waived due to the transport problems being acknowledged as grounds for failure to register.

 

In addition, the design and layout of these centres must take account of the needs of disabled people and be fully accessible.

 

Question: Can the Minister confirm that the Government will be providing assistance with transport to and from Registration Centres for disabled people unable to make the journey, or assistance with costs, such as taxis, for those people who are able to travel independently, but who can least afford extra transport costs.

 

2) Accessible information

Disabled people need to be able to access every single piece of public information produced by the Government about the ID Card Scheme.  In addition, the application process needs to be fully accessible. The forms that people complete must be provided in accessible formats, such as large print, audiotape, Braille, or easyread.

 

Notifying changes to National Register data

The process by which individuals notify changes to data held about them on the National Register must take account of the information needs of disabled people.  Consideration should be given to the extent to which people unable to use standard print can submit information in other ways, whether that is on audio tape, by phone or by email.

 

Correspondence from the Secretary of State

Any notifications issued by the Secretary of State to individuals must be sent in a format they can read.  Where individuals are required to check the information held about them, it is clear that sending a print letter to someone who cannot read it has confidentiality implications, if a friend or neighbour has to read it for them. 

 

The Government must undertake to ensure that disabled people are sent official notifications in the appropriate format that they can read and that they can respond in whatever way is easiest for them.

 

Question: How will the Minister ensure that disabled people get information about the scheme in a format they can read and understand?

 

3) Problems with biometric data for some disabled people

We understand that people who are unable to provide biometric data, such as iris scans (due to sight problems) or finger-prints will not be regarded as having failed to provide a biometric.

 

Those people who have problems giving certain biometric data will have that failure taken as a biometric identifier and it will be registered on the National Register as part of their biometric identifiers.

 

However, we still have some remaining concerns:

• people with some sight conditions may provide data that subsequently becomes invalid due to a change in sight condition or changes to the iris caused by surgery. What process will be put in place to allow for changes to biometrics?

• people who begin work in the construction industry and work with cement may lose their ability to provide a fingerprint biometric.

 

Medical proof of exemption from providing biometric data

We welcome inclusion in the Bill published after the General Election of clarification regarding the refunding of expenses incurred by disabled people, who have had to get medical certificates proving that they are unable to provide certain biometric data.

 

For example, a doctor’s certificate proving that someone is unable to provide a retina scan may cost £15 or more. We are pleased that in 37 (3) (d) and (f) the Secretary of State is able to consider ‘expenses that will be or have been incurred by any person in connection with applications for, and the issue of, designated documents’.

 

This is a significant recognition of the impact that extra costs, such as obtaining doctor’s certificates would have on disabled people, especially those people who are reliant on benefits for their income.

 

We believe that should the Government require proof of medical exemption in order to not provide an iris scan or other biometric data then it should meet the costs of an individual being required to furnish documents or proof of medical exemption.

 

Disability Awareness training

Staff working at the registration centres must have comprehensive disability awareness training.  It is vital that staff are able to deal sensitively and confidently with disabled people throughout the application process, in particular the collection of biometric data.

 

Private/Public sector use of ID Cards

The Government should require that private and public sector companies and organisations who use ID cards to verify identity have comprehensively trained their staff in Disability Awareness issues.

 

5) Future expansion in the means of verification PIN (Personal Identification Numbers)

 

In Schedule 1 of the Bill, provision is made for the inclusion of a PIN on the ID Card (Security information, paragraph 8 (a)).  The PIN would be used as an additional non-biometric means of verifying identification of the card holder.  We welcome the additional means of personal identification set out in (b) and (c), giving the additional options of a password and questions and answers to establish identity.

 

Chip and PIN has caused significant access difficulties for blind and partially sighted people, people with manual dexterity problems and people who find it difficult to remember PIN numbers.

 

We are therefore reassured that the Bill gives two additional means of identity verification.

 

However, we would like an assurance from the Minister that these alternatives to PIN numbers will be maintained and implemented to ensure the accessibility of the verification system for disabled people.