IGF 2022 Day 2 Town Hall #36 Accessibility Standards a catalyst to Inclusivity

The following are the outputs of the captioning taken during an IGF intervention. Although it is largely accurate, in some cases it may be incomplete or inaccurate due to inaudible passages or transcription errors. It is posted as an aid, but should not be treated as an authoritative record.



>> MODERATOR: Can you guys hear me?  Fantastic. 

     Good morning, everyone.  My name is Irene Kirika, and I'm the founder and Executive Director of inABLE.  And I'm here today with several accessibility standards development experts.  And we will be sharing with you the work we have done in the last one year. 

     I want to start by acknowledging the German Development Corporation for the support they offered through the whole process because if it were not for them we would not be here today.

     So I will start off by introducing my colleagues so that at least we can begin the conversation.  So I will start to my right, and I will give Lukorito a chance to introduce himself as we go all the way to the left.

     >> ZACHARIA LUKORITO: Thank you very much.  Good morning.  My name is Zacharia Lukorito, and I'm the chief manager in charge of standards development and trade at the Kenya Bureau of Standards.  We oversee the development of standards both at national level, regional, and international level from different sectors of the economy.  Thank you.

     >> ASHURA MICHAEL:  Good morning, everyone.  My name is Ashura Michael. I'm representing National Council for Persons with Disabilities. I'm happy to be here and I hope we'll have an interactive session.  Thank you.

     >> DERICK KHAMALI: I'm Derick Khamali from Communications Authority of Kenya.  I'm the manager in charge of telecommunications compliance and quality of service. Thank you.

     >> JAMES WAFULA: Good morning, everyone.  My names is James Wafula from the ICT Authority, representing the Ministry of ICT in Kenya.  Basically we are in charge of spearheading ICT initiatives in government. I'm the head of ICT standards specific to the public sector, and great to have us.  Thank you.

     >> MODERATOR: Fantastic.  Thank you so much. 

     So first off, I will start by staying that some of us have been working in the disability space for a long time.  So to be sitting here today at the Internet Governance Forum and sharing about some of the work we are is doing is a very humbling experience.  As you can all imagine, disability has not been part of the agenda with emerging technology or other spaces. 

     But now we are working towards a more inclusive Africa, a more inclusive world.  And we are happy to be here today and or the opportunity to share some of our experiences.

     So let me start by saying that the whole journey for digital accessibility began with some of the work that inABLE does.  What we do is that we work with young children, youth who are blind or low vision and we teach them simple digital skills.  Because without digital skills most of them graduate with Braille skills meaning that they join a world that is complete oblivious to Braille meaning you can't hire them, pursuing higher education is a struggle. 

     But if they have the right digital skills, they can use their mobile phone just like everybody else.  They can use a laptop just like everybody else and you don't have to have anything special for them.

     So through the process we realized that even when they have the digital skills, what is happening is that the products and services that are out in the market are not accessible. 

     What does accessibility mean?  Accessibility means simply giving access to the same information for people with or without disabilities at the same time.  Whether it is products and services, whether I'm using a mobile application, I should be able to use it just like someone without a disability.  And because we work with people who are blind, this has been a huge challenge. 

     And as you can see, especially the whole global arena including Africa there is a whole digital boon.  All of the solutions we are coming up with are all based on technology.  But technology has proven to be the biggest digital divide. 

     So that's why we are here today to discuss how can we create an enabling environment in all of our countries to make sure that the 15% of the global population which is about three million people are not left behind. 

     So I will hand over to James who will share with us because we did develop a digital accessibility standard for Kenya.  That is the process that we went through.  But I want James to share with us what legal framework was in place before we started the journey.  Go ahead, James.

     >> JAMES WAFULA: Thank you, Irene.  And thank you to the IGF for giving us this platform to speak about inclusivity with relation to the standards. 

     In Kenya we started the journey of inclusivity in 2003 with the establishment of National Council for Persons with Disabilities which established the (?).  And then we signed up to the UN Convention on the Rights of Persons with Disabilities. 

     That helps us to focus on issues of mobility, access to activities, physical environment and most importantly information technology.  So it basically is a human rights approach to inclusivity.  So that permitted into our constitution of Kenya through 2010 because we actually undertook our review of our constitution which had initially been totally independence. 

     And so they added the human rights perspectives to the Persons with Disabilities.  And so the chapter -- there is a whole chapter in the Kenya constitution that focuses on the human rights.  Specifically Article 54 that is specifically regarding focus on the rights for Persons with Disabilities including the right to be treated with dignity and respect.

     So as the Ministry Judge of ICT we took the job, we developed the National ICT Policy of 2019.  And this again was the second policy.  The initial one had been developed in 2006.  So in response to the demands of the new constitution in respect to human rights, we therefore had a whole section on accessibility which then speaks to commitments of the government in regards to availing ICT information and services to the public in alternative accessible formats for Persons with Disabilities. 

     We also committed to promote the design, production and distribution of accessible ICTs at an early stage.  So basically speaking to the availability of accessibility in the education system and digital literacy.  And we committed to ensure that websites of government departments and agencies comply with the accessibility standards and are accessible to Persons with Disabilities. 

     So basically we are supposed to, an example the government websites, these are the avenues through which our public citizens access the services provided by the government, so they need to be accessible.

     We also committed to provide incentives. Oh, okay.  So just finish up.

     >> MODERATOR: Thank you, James.  I will come back to you.  I know we've moved pretty quickly. 

     I think what is critical to note is that James has said that before we started this process first our constitution is very inclusive, it's very clear on inclusion.  It is -- SDGs are very clear about not leaving anyone behind. 

     And most importantly, the ICT policy for 2019 for Kenya has a whole chapter on accessibility.  So this created an enabling environment for us to be able to start the standards development process. 

     And for us as inABLE we were speaking to businesses and government officials.  And what we were hearing from them was what does the government want us to do.  What is the standard?  What is the requirement?  What does digital accessibility even mean? 

     And from that perspective we knew that to be able to create a solid foundation we needed a standard that could be able to jump start the whole digital accessibility process.

     And also make -- remembering that there is a huge digital divide, then that is when we approached the Kenya Bureau of Standards.  And from there we were able to collaborate and begin the process. 

     So let me -- before I get to the Kenya Bureau of Standards, I want to give Ashura an opportunity to share with us, one, how are Persons with Disabilities in Africa leveraging ICT to access products and services? 

     The reason why this question is important is sometimes when you tell someone that a blind person uses technology, they get confused, they don't even understand the how.  So Ashura has lived experiences and she can share how technology is really an important tool for her.  Over to you, Ashura.

     >> ASHURA MICHAEL: Thank you so much, Irene, for this opportunity. 

     First of all, if you look at disability and poverty, they are married, it goes along.  And when you talk about technology, as I've said before, poverty is a major -- the major cause when it comes to disability.

     Now, when Persons with Disabilities have a lot of opportunity, for example, like now as we speak.  Recently we had COVID with the COVID pandemic.  It really changed the perspective of the world and the way we do our work.

     So if we have improved technology in Africa, then we will have a wide opportunity for Persons with Disabilities to contribute and also to reduce the poverty level.

     We cannot achieve our goal without inclusivity on the digital sector for Persons with Disabilities.  Thank you.

     >> MODERATOR: So maybe I can do a follow-up question for you.  Maybe you can share with us some of the challenges that Persons with Disabilities face when using digital products and services. 

     Can you give some specifics? 

     >> ASHURA MICHAEL: The major challenge we have, like, for example, we are in a meeting now.  We have hard of hearing.  You can imagine if we have hard of hearing in this meeting, we don't have captions, so we leave them out from this information.  Information is a powerful weapon that can improve or make a person contribute to developmental of a country.

     For this person, for example, I'll give an example where I'm sleeping at the hotel.  Their phones, if I have any challenge or I become sick or I have any emergency, how do I call the reception?  How do I contact the reception?  If there is fire, how am I notified?

     So it means we are left behind.  For our brothers and sisters who are blind, accessing to mobile money sometimes become difficult because they have to use a pad buddy to assist them.

     Without -- as we talk of technology, we need to consider, we need to consider our brothers and sisters who are disabled.  You can imagine the ATM machines for short stature and a person in wheelchair.  Some of the machines are too high for them.  So they also need a third party to make them access. 

     And sometimes we have these products are very expensive, so we really need to regulate on the prices.  For example, if you have a laptop for a blind person, it is more costly than the normal laptop.

     So we aren't being fair.  So we really need to give them opportunity.  There is a lot that we really need to do to -- I'm so happy that we are here, and we are on the way to success. 

     So, for example, how can a blind person know that this is water?  When we talk about -- we just don't talk about phones accessing phones and apps on their phones, but we have so many challenges that we go through, and many things need to be done.  Thank you.

     >> MODERATOR: Ashura, thank you so much.  I think one thing that's important is for us to note that 70% of disabilities are hidden.  We might be sitting here, and we are thinking Ashura is the only one with a disability, and we don't know about anybody else. 

     So stuff like captions are critical to any meeting regardless.  And what we have even found with captions, it actually even works better for people without disabilities.  So issues for Persons with Disabilities can address everybody. 

     Part of this is I think, Ashura, also what you are experiencing is that conferences are slowly beginning to realize that they need to accommodate People with Disabilities.  But what happens is that sometimes as you come into the conference your needs are not catered to.  But also we are assuming that nobody else has a disability. 

     So my biggest encouragement to a lot of organizations that are sitting here today is understand the needs of the people who are participating and be able to provide just the basic accessibility needs like captions and stuff like that will go such a long way.  Thank you so much for sharing that. 

     I know money mobile applications is a great problem.  And really it is an intrusion on privacy because if I'm going to use my mobile money application by getting somebody else to do the process for me to transfer the money for me, then what are we doing?  Thank you so much. 

     Let me move on with one question to Lukorito who led the standards development process.  Please give us an overview of the Kenya standard on accessibility of products and services, the one we developed, it would be great. 

     And what -- what is the process of standards development in Kenya and how is it similar to other countries?  And how was the proposal received by KEBS, Kenya Bureau of Standards?

     If there are too many questions in one, please let me know, I'm happy to repeat.

     >> ZACHARIA LUKORITO: Okay, I got all the questions.  First of all, let me say this forum comes at a time when we just concluded the development of the Kenya standard on ICT accessibility for products and services. 

     Therefore we are talking across products and services.  What happened is we developed the KS, Kenya Standard 2952, Part 1 and Part 2. 

     Part 1 basically specifies functional accessibility requirements that are applicable to ICT products and services.  And then Part 2 checks those requirements that are actually conforming for that product to be certified to be complying to the standards that we have set. 

     Now, these standards are very important for us.  It's KS2952, Part 1 and Part 2.  And what we are looking at is having these standards used as a basis and to support what my colleagues have mentioned about the constitution, the ICT policy that specifically mentions about use of standards for accessibility.

     And then we are looking for that time when these are fully implemented that the costs will considerably come down.  As you mentioned, Ashura, the costs are still high.  But by using these standards, we wanted to have more manufacturers coming onboard because there is a basis for the development of the products and services that we responsibly bring them because of the products and those become also available when they are required by all of us. 

     And Irene has mentioned about accessibility.  We are not looking at those people who are only disabled, but we are looking at how can it be accessible to all people across the board.

     Therefore we are looking at how wide can these products be used.  And in this we laid out the requirements including low vision and including hearing impairment and including physical impairments as well.  Therefore they cover across the board.

     And as I -- as we move forward what we have done through this process is that there is a standard -- we are developing standards.  And globally Kenya Bureau of Standard being part of the global international standardization community and follow the same processes.  And there are about five processes that our standard has to go through. 

     The first process is the proposal, receive the proposal from the leader or stakeholder or we identify that there is a need for a specific standard to be developed, either economic, social or even scientifically.  And then once we receive that proposal, we look at it and analyze properly to see what specification was mentioned about social requirement, economic as well as environment protection. 

     And then we move to the next step where we take this document to the committee, it's called technical committee.  And then KEBS currently have slightly over 200 technical committees dealing with different products and services.  And accessibility is there with the KEBS technical committee that is specifically with the products for Persons with Disabilities and accessibility across.

     Therefore after that document is considered where the various stakeholders have commented, then they capture all of the requirements and agree this is what we have agreed to, and we can move to the next level. 

     And then we move to the next level which is part of the constitution that we need to involve the stakeholder that have not been participating.  Public review and public participation.  And this is a requirement.  We involve stakeholder that has not directly been involved to give their comments and their views and their input as well.  That process takes 60 days. 

     We hope to segregate, we hope to separate the disability requirement to talks to the segment because they affect in one way or another.  And then once we receive the comments they are taken back to the committee for discussion.  They can either accept the comments in the document, they can also reject with reasons, or they can also accept with modification of those comments that have been received. 

     Then the next step would be that once they have disposed of the comments, this is what you call piloting.  Piloting is approaching those who are developing the standard basically go to them and say this is the document that we have developed, and we are in acceptance with the covenants of this document. 

     And then the final stage is to take to the National Standards Council, which is a board of the national Kenya board to approve the standards.  And once they are approved -- [distorted audio].

     >> MODERATOR: Hold on.  It's gone.

     >> ZACHARIA LUKORITO: Okay.  I will quickly mention about the proposal. 

     I say their proposal can come from any stakeholder.  And that is when the ICT policy was formed and the work that they were doing they formed those in order to involve the standard. 

     We receive the proposal from inABLE to consider developing the standards for accessibility.  And that is how we formed the justification around that based on the social inclusion, looking at the economic value of it, and also the environment.  And then that is how we received that proposal and we have taken it through the stages that I have mentioned.

     >> MODERATOR: Thank you so much, Lukorito.  Actually, I have to say that thanks to KEBS -- Kenya Bureau of Standard is also called KEBS -- for the lessons we have learned about the standards development process. 

     It's a very intense process.  Some of us had zero experience, but I believe right now you guys with the expertise and knowledge that you shared really meant a lot.  So we do appreciate that. 

     And maybe one more question for you.  How did you engage stakeholders?  We know they are different groups, and it is very complicated.  And what is the importance of stakeholder involvement in the whole process?

     >> ZACHARIA LUKORITO: I'll go back from where I stopped that the standards are developed by the technical committees.  And then the technical committees we have different categories of stakeholders.  We have government agencies, we have academia, we have users as well as regulators coming across to agree on the requirements that we have adopted in the standard. 

     Therefore, for us, standards development is a stakeholder-led process.  And without involvement of stakeholders there would be no buy-in in the standard that we've developed. 

     We want to involve the stakeholder from the word go so that once the standard is developed it becomes permission to take place.  Having said that, when we formulated this technical committee we looked across different categories of stakeholders and we found that they were not balanced.  Therefore, we had to issue a call to involve more stakeholders to come onboard so we developed the standard together. 

     Most important, this was a unique process that required even reaching out to the specific identified stakeholders to be involved so that we have the real persons who use these improvements involved in the development of the standard.  And we have really involved the National Council of Persons with Disabilities and the decision of Persons with Disabilities in these categories so that we involve them in the development of the standard, we capture the requirement.  Because it will be difficult for a certain group to sit somewhere and pretend to be developing standards for Persons with Disabilities and those persons are not involved in the development. 

     Therefore, we have to bring them onboard so that we capture their requirements.  What are their needs?  What are their challenges?  From the word go, as soon as we develop the standards, their requirements are captured in the standards.

     Then moving forward we had to bring also onboard the government agencies that were implementing these standards.  And that is the importance of us developing the standards and what are we addressing so we can move to the next step, and it is easier for the government to assist to bringing this standard.

     >> MODERATOR: That is really, really a critical point.  Because, bottom line, if you are going to succeed in standards development there has to be very deep stakeholder engagement.  And I think that is one thing we worked together, and we did very well. 

     I think for me from my experience what was really interesting is the debates we were having between different stakeholders because how Kenya standards looks at the development process versus how someone with a disability who is blind or someone who is deaf was looking at it are totally different. 

     But bottom line is when you have experts, and you have stakeholders then you are able to come up with a more conclusive standard that really addresses the needs that you want to address.

     So that was a very, very intense process.  And it wasn't easy.  It wasn't easy.  So we really do appreciate the guidance and your expertise in the process. 

     So I want to move forward to our implementers.  As Lukorito said, implementers also had to get involved in standards development so that you are not just handing over a document to them, and they have no clue what is going on.  Their feedback was very critical to the whole process. 

     So I will move on to Derick.  Derick, welcome.  And the first question I have for you is what is the role in the development of this standard?

     >> DERICK KHAMALI: Thank you so much, Irene, and Lukorito, for the earlier question. 

     Communication Authority, CA, is ICT Regulatory in the Republic of Kenya.  And as James introduced, when the ICT policy was developed it was forwarded to us to implement with the clauses on accessibility for all.

     And our motto in Communication Authority is opening your world.  So it became apparent that we were responsible for something.  But in terms of opening your world, we discovered that our skills and competence to open the world for persons living with disabilities was really compromised. 

     So when inABLE came about and they told us they have the expertise in addressing matters of accessibility to People with Disabilities, we embraced it.  And when we got the invite to participate in the technical committee by Kenya Bureau of Standards, we were happy for it. 

     So, as I said, CA or communication Authority is the ICT regulator in Kenya.  Our job is therefore to set rules to the players in the ICT sector and also to monitor their compliance.  Once you issue a license, it comes with conditions.  And the people who have been licensed are required to ensure they comply with every clause.  And these licenses for that matter now had to adopt a clause on accessibility. 

     So we've developed this standard as an agency.  We were very keen to see what is coming up so that when we go to our license entities, people in the private sector who offer communication services we will know what it is, and we will enforce it.

     So that's our commitment and that's what we are up to do.  We are monitoring adoption and activation of the standard as the lead agency on this side.

     >> MODERATOR: Fantastic.  And can you share with us who are your customers or consumers or target for the standard?

     >> DERICK KHAMALI: Yeah, the regulatory bodies normally provide an opportunity for investors in the communication sector to come in.

     When an investor looks at their competence, they look at their resources, they make a business case of what they think they can do.  They come to us to get their license.  And once they get that license, we expect them to go out to the public and serve them in very specific terms and applications.

     So our main customers are vendors of equipment, people who bring in mobile phones, computers and all that.  They are licensed.

     So to develop and apply this standard these vendors must comply.  The products they bring in Kenya must be accessible.  So those are some of the people that we work with. 

     The others are contractors or installers, those who are going to do cabling, who are going to install machines.  Are they installing in a manner that will enable People with Disabilities access them or not.  Those are also licensed.  And we make them our stakeholders or our customers.

     The others are internet service providers, the people that provide the content that puts people online.  We want to ensure that they also adhere to the requirements of the standard.  So all ISPs are our candidates. 

     The other companies are infrastructure and data center operators, people who install large facilities.  We want to ensure in their development of this work as they do their installations, as they lay their infrastructure, as they operate their data centers, they must comply with the standard on accessibility.

     And then finally we have these mobile networks.  People who are running all forms of applications on their mobile platform.  Mobile broadband, voice and other SMS services. 

     Are they accessible to People with Disabilities or not?  So these are the entities that we look at.  These are the focus point for Communication Authority.  Thank you.

     >> MODERATOR: Fantastic.  Maybe one last question for you. 

     I like the way the type of consumers you have are large scale, so they have a huge impact in the country in Kenya.  And we are bound to make a difference because accessibility starts with leadership, it starts with the big companies and then everyone else is able to follow. 

     What are the next steps in terms of implementation of this standard when it comes to Communications Authority?

     >> DERICK KHAMALI: After the launch of the standard, Communications Authority was one of the entities that was handed a hard copy, not just a soft copy, we were given a hard copy to go implement. 

     So for that matter we got the responsibility to adopt and apply the standard in-house within the Communication Authority processes and procedures.  An even the way of thinking.  So what we have done is that we have presented this to our management.  They have accepted it.  And all departments have received the standard and have been required to comply by ensuring that we adjust our website, our forms, our customer care portions.  And every department within the Communication Authority to align with the provisions of the standard.

     As Zacharias reported, that standard comes with requirements, and it also comes with conformance. So you look at the requirement and conform.  So we have practiced it on our own.  It is an ongoing process and we have formed a committee for this. 

     Then we also go out to the stakeholders or licensees that I have mentioned.  The first job we have done is to inform them that this standard is up, and they need to familiarize with it and adopt it.  Now we have planned a series of workshops and regulatory notices that are coming up to ensure that our stakeholders are onboarded.

     >> MODERATOR: Thank you so much for that. 

     I think we'll try and move on to James again.  And the critical -- maybe one thing I can share is that we work a lot with other disabilities including those who are blind. 

     But one experience that touches on the blind and the importance of the standard is that you find in Kenya the citizens are required to file their taxes online on the Kenyan government website every year and there is a deadline. 

     But what happens if you are blind, you can't do it by yourself.  Every other Kenyan can do it.  Why?  Because the website is not accessible.  It was not developed with People with Disabilities in mind.  So it doesn't cater to them.

     And what happens when you speak to blind people, they complain and say hey, and when I don't file my taxes on time I'm penalized for not filing, but it is not my fault. 

     So what we are trying to address, just to bring this home, are those specific services that we provide -- whether it is private sector, whether it is in healthcare, whether it is in education, whether it is in employment -- to make sure that all of the applications that you are using, the devices you are using are inclusive. 

     And this means that if I'm using assistive technology.  Assistive technology can be a screen reader.  Blind people use screen readers to be able to read content on a website.  That my screen reader can read that content without any problem.  But that also depends on the development of that website, the development of that application.

     So to take this home because I want to learn more from James.  James, can you please tell us who are your consumers at the ICT Authority of Kenya?  Because ICT Authority of Kenya is at the Ministry of ICT.  So who are your consumers?

     >> JAMES WAFULA: Thank you.  Thank you, Irene, for that question.  The ICT Authority plays a two-fold role.  One regulatory and the other one is implementation.

     On the implementation aspects we basically provide common shared platforms for government agencies that includes data center platforms for them to host their applications and provide internet connectivity to the government agencies.  That is ministries and departments, agencies and counties, governments.  And we also host for them websites as you have seen.  So that is basically the permission aspect of it. 

     On the regulatory aspect of it, we work with the ICT managers, ICT professionals within the government agencies.  That is the ministries, counties partners and IGCs to ensure that they comply with the standards.  And therefore ensure that the government is moving towards a common goal in terms of digitalization.  So in this aspect we require them to build and comply with the standards in the process of the development.

     We require them to, and we have standards in terms of website development.  How they are positioned.  So in this regard we are talking about having devices that are accessible to Persons with Disabilities. 

     We require them to ensure that they have programs in place to bring capacity internally to ensure that they are conforming to these standards.  So those are the two initiatives of our responsibility as the ICT Authority.

     We as well regulate ICT firms, ICT businesses that are doing business with the government who basically have to have accreditation of the same.  There are requirements to meet certain requirements whenever they are engaging with government agencies to comply with the regulatory standards that we've set to ensure that we are having an ICT investment that responds to the needs and requirements of the government.  Thank you.

     >> MODERATOR: Thank you for that.  And as we know, government services are very hard to reach for People with Disabilities. 

     So can you maybe tell us what is your commitment as ICT Authority?  Because it seems like you police a lot of government agencies.  So what is your commitment to ensuring that this standard is actually implemented?

     >> JAMES WAFULA: Thank you for that question. 

     We as well participated quite well in the development of the standards.  We were well represented.  We understand the requirements of the same. 

     And we have already hit the ground running in respect to the implementation of the standard.  Because that is quite a big up in terms of the public sector and in terms of also for developers and designers. 

     We have made training.  It comes with basically enhancing the platforms we already have to ensure that they are accessible to Persons with Disabilities on our pilot list. 

     Secondly, we have embarked on basically the aspect of (?) for these at the county level to ensure that we meet the requirements.  So those requirements are, first of all, initial steps. 

     But nonetheless, we tend to work through the whole cycle of the implementation of the standards.  First of all, by ensuring that we conducted audits in the NDAs to ensure that there is compliance. 

     And ultimately the issue of monitoring and regulation at each end of the national layers to ensure that NCDAs or ministries, counties, departments and IGSCs are complying with the standard.  Thank you.

     >> MODERATOR: Thank you so much, James.  I think you raised a very important point, and it is about capacity building.

     Digital accessibility is a very new concept.  Especially in the African continent.  The west, most people have been engaging in the accessibility discussions for over 25 years, so they are pretty advanced. 

     But when it comes to Africa, we are still at the foundational stage.  So we do believe capacity building, training, all that is very, very critical to make sure that we understand what is digital accessibility.  And when it comes to the technical aspect of this, how do we implement this standard in a way that we actually succeed where we provide very inclusive digital products and services.  So that's an area that really, really needs investments long term as we continue to evolve and invest in digital products and services. 

     So maybe I will come next to Derick here right next to me.  My last question for you is are there any regulatory tools that Communications Authority of Kenya has put in place or any formal processes to support the implementation of this standard?

     >> DERICK KHAMALI: Yes, Irene, there are quite a number of initiatives that we have put in place. 

     One of them is to change the reporting mechanism.  So we have prepared compliance return forms which will assist the stakeholders that we work with to ensure that they keep us updated on their progress of adoption of the standard.

     So we have prepared compliance return forms that will be used on annual basis for reporting about accessibility of their services and products by people living with disabilities.  So that is the first one. 

     And then the next one that we have done is that we have also put it into our regulations that every one of our licensed entities as they come in and even those with existing licenses that you already submit a commitment that you will be able to develop and include persons living with disability in your considerations and designs. 

     Even as you import products, you will need to include a submission on your compliance at the time of approval level.  When you want to introduce maybe a new Samsung mobile device to sell in the Kenyan market, we will want you to confirm the content about accessibility on it as part of our procedures.

     The next thing is that we have also developed an implementation framework for this standard KS2952.  This implementation framework is an overall assessment where you do self-assessment to know whether you are complying or not. 

     Because it is easy to determine yourself and say I think I'm doing well.  But this framework has clarified and put steps one by one that will help you audit yourself. 

     And in the initial government analysis when we tried it on our own website at Communication Authority, we thought we were very inclusive, but we found ourselves below 50% when this assessment was done.

     So we've put this as the initial step.  You have to go through a self-assessment, look at the implementation framework.  Identify the gaps and share with us a plan on how you are going to narrow the gap until the standard is fully implemented.  That is why we are doing a continuous compliance monitoring.

     And at some point in time after the basics have been done, we expect to run workshops or train people, but we will now go into enforcement.  As I told you earlier, we are at regulatory edges.  Therefore we apply all rules up to the end including enforcement.  So we will list anybody who will not be compliant and perhaps they will not make business.  Thank you.

     >> MODERATOR: Thank you so much, Derick. 

     I think the one important point to note from Derick's conversation is that the standards development and implementation process is an ongoing process.  As much as we developed the standard, it did not end there.  And it is a very long-term project. 

     So a good example -- and I know Lukorito and the inABLE team have been watching heavily in the background and part of is to make changes to some of after the standards development what issues came up, what did we have to handle.  So maybe, Lukorito, you can briefly tell us what is the cost of the new standards? What was it or what is it?  And what has Kenya done to make it available to the general public?

     >> ZACHARIA LUKORITO: Thank you, Irene.  You have rightly mentioned that standards are a living document, and that standardization is an ongoing process. 

     Basically it involves administration, and it is that part of the government which incorporate it and then the final part in the phase of standardization is, of course, implementation of these correctly. 

     Then having said that, when we started making the standards available to the people who require it, of course standards are solved globally.  It is an international practice that standards caused many to develop.  And then you have to recover some cost to set up those standard.  And that is one of the things that we do across the board not only for the standards for accessibility but all of the sectors.  And this is a global practice. 

     Having said that, when you develop these standards, standards are costed based on the work involved and based on  a number of pages and the work that has gone into that document.  Therefore, in that total analysis was done by our economists we had to see how we can recover some of the costs that have gone into the development of the standard.

     One of the standards were costing 50 USD, that's the part one.  The part two costs about 60, and that brings the total cost to 120 to get the new standard.  During that phase we realized that applicants is quite low simply because some of them who are required this cannot afford to pay for the cost, it is bit expensive. 

     Therefore, we discussed internally as management with KEBS on how can we facilitate the people who need the standard to have it accessible and then also affordable.

     One of the decisions that have been made specifically for this category of standards is that we are going to be make them available for free.  And that has already been implemented.  They can be accessed by those that require them for free at no cost.  They can download the soft copy.  Perhaps when they require hard copy, perhaps then then meet some cost to print it.  But the soft copy is available online free.  It is a unique practice in KEBS. 

     If you take a look across practice in KEBS it is not available.  This is second -- the first that we are implementing to see that these standards are available for those people who require it at no cost.

     That is one of the support that we are providing as international standards but to see that actually the standards are implemented.

     >> MODERATOR: Thank you so much, Lukorito, for that.  We truly, truly and deeply appreciate the support we've received from the government of Kenya and Kenya Bureau of Standards and your entire team throughout this process. 

     As we see as we continue with the process, we will continue to engage you.  But most importantly, thank you for making it even more accessible to everyone.  Because with or without a disability, whether you are a small company or a large company, you can go online and download the document and get to understand what are the technical requirements for you to be able to develop an inclusive product.  So we do appreciate that. 

     And this is something we discuss when we were having these meetings about if we need to make any changes to the standard, it is an open door.  Do you want to say something about that?

     >> ZACHARIA LUKORITO: Thank you.  Standards are living documents, they can be reversed, reviewed, amended at a given point.  Therefore if during the implementation we find that some of the process or provisions in the requirements are not implementable, then we can always sit down as a technical committee and look at the document and review those requirements and capture them so that they are also implemented. 

     Because we can develop a requirement, but we need implementation when we find the data requirements was overly ambitious and cannot be implemented, therefore we have to review it.  And we are open to receiving comments as we implement the standard.  And we should incorporate and facilitate all of those comments.  And then we call the technical committee again, the same stakeholders that were involved including those ones that will be new so that they can look at those requirements and review their standards appropriately.

     >> MODERATOR: Fantastic.  Thank you so much. 

     I think one critical piece that you've talked about is about stakeholder engagement.  And there was a 60-day period for public review.

     And I loved that period because we got so much feedback globally.  It was open to everyone.  The document was shared globally.  And we got a lot of feedback about the document.  And we did get together, debated a lot of the changes.  Some of them passed.  Some did not. 

     But what was also impressive that for every feedback that we received, actually Kenya Bureau of Standards had to document the feedback that they got.

     So if we wanted to go back and see what did the public say about this document, we actually have more than enough feedback for that.  Thank you so much, Lukorito. 

     So I'll move on to Ashura to give us from your experience.  We spent quite a bit of time together debating about this standard.  But most importantly, since you participated in the development of this standard, what was your experience and how are you going to monitor this as National Council for Persons with Disabilities going forward?

     >> ASHURA MICHAEL: Thank you so much.  As Lukorito said, it is very important to have inclusion of stakeholders in the process.  My experience, it has given me the energy to be innovative so that we can make sure our people benefit.

     As a person with disability, nobody knows, nobody knows the pain we are going through.  But thanks to KEBS for that support.  It involves a lot of money. 

     And it is not about me as Ashura.  It is about all Persons with Disabilities in Africa.  Thank you for our -- thank you for actually supporting inABLE to make sure that this was actualized.

     And remember that the National Council is a government entity, and its role is to monitor the implementation for all private and public sector to make sure that at least they comply with the standard.

     As a National Council, we always -- every year we have the NDA which is used for assessment of performance of all of the private and public sector.  I hope going forward we come up with one that will monitor the standard implementation and the service provision.

     We know we cannot do this alone without the public and private sector support.  We can better the services when we include all Persons with Disabilities to make sure that it's accessible to and make life easy for most of us.  Not just in Kenya alone, but also in Africa.  Thank you.

     >> MODERATOR: Fantastic.  That's very, very good feedback.  I think it important we note that People with Disabilities have to be at the center of design. 

     Anything you are doing, do not make assumptions.  And the fact that someone is blind does not mean they understand the needs of someone who is deaf.  So you have to have everyone sitting at the table. 

     We have about five minutes before we wrap up, and I want to see if there are any questions.  We have about 10 minutes.  Any questions from our audience?

     >> AUDIENCE: Thank you.  My name is (?) working on disability policy in Kenya and Africa. 

     First I will say thank you for panelists for highlighting and also the great work you are doing.  For me, I understand accessibility in two terms. That is usability and reachability. 

     Usability is the ease of use and also having the skills to use.  And that's where the issue of capacity building comes in.  And the reachability is the availability of the technology, of the techniques of using, say, let's say of assistive devices as the panelist related that People with Disabilities have a great challenge in accessing the assistive devices. 

     My question, my first question is that what are the regulations doing to help ease the cost of most important assistive devices and other technologies for Persons with Disabilities so that to ensure equality in access of all government platforms and also offline.

     Another question is on the Communication Authority.  You have said implementation you have put in place to ensure that the standards of ICT development systems and programs are met.  But I'm worried that usually the issue of inclusivity and accessibility comes as an afterthought.

     You say that the company must have an application that is inclusive, but they only include the accessibility bit when they hear that it is a requirement.  What are the regulations you have put in place to ensure that it's -- accessibility is part of the development and also the system being developed covers all but not as an afterthought?

     >> AUDIENCE: My name is Christian (?).  I'm a professor for law, science, and technology, Technical University Munich.  And I have to applaud you for your work.  It was really interesting how you draw this up and also implemented it.  So it was a very interesting to hear. 

     My question would go to the kind of knowledge governance that comes with it.  Because I fear that implementing these standards many organizations will kind of answer the same questions. 

     So have you already experienced that or thought about how to translate the knowledge between organizations which is sometimes a tricky issue because it is also business secrets.  And maybe they don't want to give away certain things. 

     But on the other hand, they all have to find solutions for accessibility and inclusion.  And maybe in some instances it might be easier for them if they would all share how they kind of answered specific questions. 

     So this was my question, the standard across this topic of knowledge governance and knowledge sharing in this space.

     >> MODERATOR: Really quick.  Yes.  Okay.  Okay.  Yeah, go ahead.  You have like 10 seconds. Please proceed.

     >> AUDIENCE: Thank you very much.  My name is Judy Okita.  I wear many hats, but right now I will wear the Kenya ICT Action Network.  KITNet.  I'm consulting with them on the accessibility and inclusivity project.

     So my -- I appreciate the conversation that is going on here.  I have a quick question.  One to Lukorito.  When you say that the standard is accessible, do you mean accessible format or accessible available?  Because sometimes we interchange these words when we're talking about accessibility.  When it comes to disability it means something different.

     And just a comment to the regulator and the ICT authority.  We would appreciate if you could share with the public from time to time what is happening.  I'm surprised that I'm hearing from here that the ICT Authority is the one implementing these accessibility matters.

     So thank you.  Thank you, Irene.

     >> MODERATOR: I will answer one question to save time.  Yes, the document is available and accessible.  It is in an accessible digital format.  So just to be able to save time.  We have like two minutes.  Lukorito.

     >> ZACHARIA LUKORITO: Thank you.  I will be brief on the issue of making ICT products and services affordable. 

     I think my colleagues in ICT Ministry can address that one together with the revenue authority that collects tax on those imports. 

     But quickly mentioning about the regulations.  One of the regulations as we mentioned about the ICT policy.  Moving forward, I think it is important that we have developed this standard.  Looking at this standard as it was asked into that pressing the various aspect, actually if you look at the specific standard there are functional requirements.  And there are certain principles for usage with the -- without vision, limited vision.  There is also perception of color, limited perception or no perception at all.  Then there is also hearing or limited hearing.  And there is vocal or no vocal at all. 

     Those are the requirements that have been captured in the different products and services in the standard.  Just to address your question quickly.

     >> DERICK KHAMALI: Okay.  On my front I will want to address -- Thank you for your question. 

     Indeed, the usability and reachability is a concern for the standards.  And the main aim is that we want to begin from where we are.  There are some regrets because of what was never done earlier.  But now that we know we want to begin where we are. 

     That is why we've developed a framework that helps us to assess ourselves.  Even the stakeholder to check where are they.  So that now beginning from now into the future any new decision, any new product, you now incorporate usability and reachability from that point.  That's why the framework is progressing.

     And we want to work with the stakeholders through workshops training them so that they can be able to start incorporating and mature into a better platform. 

     As I said, we began maybe checking with about 50%, but we intend to take the standard to 100% but with time.  We expect to speed up this now that it is clear, this is how the standard looks like.  This is how the conformance can be checked.  And I believe that we will get better. 

     We are incorporating factor as this.  So before a company like Safari Company imports its products, now it will be giving this standard requirement to its manufacturers to tell them for you to bring me a product in Kenya these are the requirements.  So the products will come when it is already accepted at the design level to be reachable or accessible. 

     Then the professor from Munich, the issue of knowledge sharing.  We have looked at this.  First, we've tried to ensure that this standard is shared among all of the stakeholders. 

     And we intend to run workshops so that we also train the people and see what are the common areas and what are the experiences that can be shared.  In Communication Authority we have a department that deals with knowledge management and knowledge sharing.  So we will want to build on that capacity and take it to the next level. 

     I'm glad I have Dr. Mugengi (phonetic) here who is leading that part and we expect to make progress. 

     And Judy, we will try to go public.  As you are aware, this standard was launched in May.  And first of all, we had to check inside and see whether we are ready.  As I said, now we have formed committees and we want now to go full throttle.  And I believe that the Kenyan public will hear more about KS2952 and perhaps the communities including Ethiopia will be able to listen to this. Thank you.

     >> MODERATOR: I know we are out of time, but I just want to follow up on what Derick is talking about. 

     We are where we are with the standard as a country.  We start with baby steps, and we keep up and we keep going.  It's to take years.  Not one, not two, not three, may take us ten years.  But if we look at ten years back, where are we after developing the standards?  What changes have we made whether it's private sector, whether it's in the health sector or even in government as well.  That is really important. 

     Something else that is critical to note is that initially it starts as a very competitive process where this company is developing this product.  This one is developing this product.  Not sharing knowledge.  But what happens over time, everyone discovers digital accessibility is very complex but it's also a very collaborative effort. 

     So if you share knowledge even with your competitors you actually make more progress together. 

     The other point that is very critical is that accessibility begins with leadership.  If the leadership does not get the buy-in of the standards to make sure it is implemented in the different companies or government, then we are going to drag for a very long time.  So I think the key thing is being able to make a business case so that business leaders understand that accessibility covers People with Disabilities to bring them into the pool of the market that you want to tap into, but it also covers the needs of the elderly.  Think about elderly using mobile applications all the time.

     Think about people in low bandwidth areas and also think about people with low literacy level.  If the product is fully accessible, everyone tends to enjoy using the product.  So I want to end there.  And I want to really, really thank the German Development Corporation for the support you worked with us over the last one year.  I want to say a special thank you to Kenya Bureau of Standards for the many lessons we learned, and we continue to learn together.  National council for Persons with Disabilities for all of your support.  As we've said, People with Disabilities have to be at the center of this conversation.  Let's debate about it because their input is very valid. 

     Communications Authority of Kenya.  We are relying on you and counting on you to help make private sector, your consumers in the private sector more inclusive. 

     And for ICT Authority of Kenya, we need government website accessible so that Kenyans can have access to government services. 

     So we are here to work together. If you have any questions, please feel free to reach out.  And thank you all so much for your time and for even making an effort to come and listen to us.  Thank you.