TB/122

TRAVELINE

DISABILITY DISCRIMINATION ACT (DDA)

POLICY

Version 1.3

1. Purpose

1.1 The purpose of this document is to state the approach traveline Board intends to take to meet the requirements of the Disability Discrimination Act (DDA).

2. Traveline

• The purpose of traveline is to provide timetable information from all stops for public transport (bus, coach, metro, tram and train) both through a single telephone call and the regional internet service in accord with the appropriate aims in the Transport White Papers and to meet the specific requirements on local authorities and bus operators for bus information in the Transport Act 2000.
• The traveline service started operation in 2000 with call centres in England, Scotland and Wales.
• Calls are directed automatically to the relevant local (generally regional) enquiry centre; these are funded and run by partnerships of transport operators and local authorities. However, if the caller requires just rail or coach information, they can choose to be routed to either National Rail Enquiries or National Express. In Scotland, calls are put straight to the call-centre with no menu. If the local centre cannot give the detailed information for the distant end of a long-distance journey, the call will be transferred to the centre with that information.
• The present organisation is that a number of stakeholders are working together, through a traveline Board chaired by the Chief Executive of Transport Direct, to manage and develop traveline. To manage the service nationally, there is a Director based at CPT. There are 8 Regions, plus Transport for London, engaged in delivering the service in England, together with equivalent organisations in Wales and Scotland. There are 22 traveline call-centres operational in Scotland, Wales and England although one call-centre (Plymouth) serves two regions (albeit through two independent regional systems).

3.1 The Disability Discrimination Act (Part III) applies to travel information services. Under the terms of the Act, the requirements are generic and require the provider of information services to make them available to a comparable standard to all members of public at large: subject to the test of "reasonableness". The definition of what is "reasonable" will emerge over time, as and when cases are brought to Court and tested. The specific requirements that arise from this general statement will also vary according to the content and mode(s) of presentation of the information service in question.

3.2 Part III of the Disability Discrimination Act (DDA) deals with discrimination in relation to goods, facilities and services. Section 19(1) states that it is unlawful for a provider of services to discriminate against a disabled person by refusing or deliberately not providing any service which is or can be provided to members of the public; or by having any "practice, policy or procedure" which makes it impossible or unreasonably difficult for a disabled person to use the service, or by adopting standards and/or terms of service that differ (in effect are poorer) than those that apply to members of the public.

3.3 Research has been undertaken by Transport & Travel Research Ltd (TTR) on traveline information provision for disabled customers. Version 1.0 of the final report was issued in July 2004.

3.4 The report advised that the prominence given to the concept of "reasonableness" acknowledges the future role of Case Law in defining precisely what types of information traveline will be expected to provide. A conclusion of a report on the transport information needs of disabled people - after an examination of the requirements of the Disability Discrimination Act - is that transport operators and information providers should at least have the strategic objective of providing certain items of information of particular importance to disabled people; these include:

• The availability of (accessible) toilets
• The availability of assistance for disabled people from staff at stops and stations
• The accessibility of individual stops, stations, airports and ferry terminals
• The accessibility of vehicles normally used on a route
• Contact details of taxi companies serving major stops, stations, airports and ferry terminals
• Contact details of specialist organisations that might help disabled people with requirements that are beyond the scope of traveline

3.5 The report identifies as an immediate priority, that traveline call centres should be able to give out information that is deemed to be "essential" for disabled people when they plan to undertake a journey, provided that it can be readily collected, and at a reasonable cost. Such information includes the general availability of assistance, and the general accessibility of vehicles and infrastructure, at defined stations and on defined routes, and the availability of accessible taxis.

3.6 The report proposes an equal priority, that efforts be made to provide better publicity for the existence of traveline. The research has demonstrated a consistent lack of awareness of traveline among disabled members of the public. Such low awareness is not exclusive to disabled people, as previous research undertaken by TTR found similarly low levels amongst the wider population.

3.7 The main recommendations from the research, in an approximate order of priority, are:

• The providers of traveline should raise awareness of the services through national and local organisations representing disabled people
• Call centre staff should be trained to expect that some callers might take longer to make their request for information clear, take longer to note down information that is given and/or have problems understanding the details given to them
• Transport operators and information providers should strive to provide information on the items (listed above in 3.4) that disabled people consider to be essential, subject to this being achievable at reasonable cost.
• traveline should comply with guidelines relating to the accessibility of internet-based information provision. For example, printed information from the internet should be available in large print format.
• All transport operators and information providers should have some means to handle an enquiry from a deaf or hard of hearing caller using assistive technology (such as email, text messaging, fax, Type Talk or Minicom)
• Disabled people who have a requirement for information that lies beyond the scope of traveline should have access to information through a specialist national agency, such as TRIPSCOPE and/or a network of local agencies
• Providers of information should recognise the importance of the completeness of information for disabled travellers
• traveline call centres should provide information on request, using media such as email, text messaging and fax
• Transport operators and information providers should ensure that they meet their duties under the Disability Discrimination Act by drawing up a Disability Policy, so that they do not undertake practices which discriminate against disabled people. They should take into account:
  • What they already do under the DDA
  • What more they need to do
  • What is reasonable to do
  • What is beyond the scope of reasonableness
  • The needs of the different types of disability on their own account (physical and sensory)

4. Policy Statements

4.1 The traveline DDA policy statements are:

• Policy Statement 1 - traveline will seek to comply with the duties under the Disabilities Discrimination Act 1995 (Part 3)
• Policy Statement 2 - traveline will encourage all participants to make available to traveline high quality and accurate information about the accessibility of transport services and infrastructure for disabled people
• Policy Statement 3 - The traveline internet services will strive to be made accessible to different mediums (PC internet, mobile devices & other public access terminals) where a business case can be made for such provision
• Policy Statement 4 - traveline phone and internet services will make available information about the accessibility of transport services and infrastructure for disabled people where it is available

5. Actions being Implemented

1. Textphone/Minicom

   traveline already maintains a minicom service for the deaf or hard of hearing caller on 0870 241 2 216 covering all regions

   Useful Numbers

   traveline call centres should already have the TRIPSCOPE number (08457 58 56 41), Dial-a-Ride numbers for the region, community transport numbers and relevant local authority numbers.

   Internet

   Where feasible and reasonable, we aim to remove all barriers to accessibility of the traveline websites. To satisfy this objective, we plan to ensure that the web site takes account of RNIB / "Bobby" guidelines.

   RNIB guidelines are contained in their publication "see it right - Websites". "Bobby" is a comprehensive web accessibility software tool designed to help expose and repair barriers to accessibility and encourage compliance with existing accessibility guidelines. "Bobby" tests for compliance with government standards, including the U.S. Government's Section 508. It offers prioritised suggestions based on the Web Content Accessibility Guidelines provided by the World Wide Web Consortium's (W3C) Web Access Initiative. "Bobby" allows development staff to test web pages and generate summary reports highlighting critical accessibility issues before posting content to live servers

   The approach being taken is:

   • PTI Website Ltd and the traveline regions should confirm by 28 February, 2005 whether their sites take account of RNIB / "Bobby" guidelines.
   • If the sites are not compliant with RNIB / "Bobby" guidelines, costs and timescales for this work should be obtained and presented to the traveline Board on 23 March 2005

   Rail

   The website www.nationalrail.co.uk includes under "stations" what facilities a station has. This includes how accessible the station is and whether there are accessible toilets.

   Details of three or four taxi companies or hire cars serving a station can be found on www.traintaxi.co.uk The Department for Transport is investigating how this data can be improved to include the names of taxi firms supplying accessible taxis.

   Air

   The disabled facilities available at all airports can easily be found though www.tripscope.org.uk by selecting "Links" and then "Airports"

   Regional Actions

   Each traveline region should determine for their region:

   • The availability of accessible toilets at bus stations and interchanges
   • The availability of assistance for disabled people from staff at stops and stations (see Note 1)
   • The accessibility of individual stops, stations, airports and ferry terminals (see Note 1)
   • The accessibility of vehicles normally used on all routes.
   • The willingness to provide taxi information on request
   • Whether they are able to provide information on request by post, e-mail and fax using large print if necessary.
   • Whether they are able to record an audio tape of a journey so that this can be posted to a visually impaired customer if required
   • If the list of specialist organisations that might help disabled people with requirements that are beyond the scope of traveline is comprehensive.
   • Whether their regional internet sites takes account of RNIB / "Bobby" guidelines.

   Note 1: It is accepted that existing records may not be available and that some tasks, notably the determining of both the availability of assistance and accessibility at individual stops may be extensive and take a considerable period of time to collect.

   By the 28 Ferbruary, each region is to provide to the traveline Director the dates by which it would expect be able to give information on the general availability of assistance, and the general accessibility of vehicles and infrastructure, at defined stations and on defined routes, and the availability of accessible taxis.

   Central Actions

   A list of transfer numbers for rail companies will be provided so that travel assistance can be booked by the customer from the station of departure.

   Discussions will be held with TRIPSCOPE to determine how we can better work together.

   Discussions will be held with DfT and TRIPSCOPE as to how the specialist organisation can be made an integral part of the national system of information provision, and operate as a member of the traveline / Transport Direct family.

   The status of the DfT efforts to assemble a database of accessible taxis will be monitored so that traveline use of this database can be arranged when possible.

   Investigations will be made as to how to raise the awareness of traveline through national and local organisations representing disabled people.

   Investigations will be made as to how journey enquiries could be put into Braille through either an external contract or the purchase of appropriate software and a Braille printer.

6. Timescales

At the traveline Board meeting on 26 January 2005, it was agreed that all traveline regions would confirm their intentions towards meeting the recommendations in para 5.6 above by 28 February 2005..

7. Regional Policies

The National traveline Board has advised its regional organisations that they need to formulate their own DDA policies.

8. Status of Policy

The traveline Board agreed Version 1.3 of this policy at the Board meeting on 23 March 2005

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© traveline 2005, Last updated: 20 July 2005