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Submission to CRTC - Notice of Consultation CRTC 2015-105: Television Service Provider Code of Conduct

Monday, May 25, 2015

Dear Secretary General,

Sent by fax on May 25, 2015

Re: Broadcasting Notice of Consultation CRTC 2015-105: Television Service Provider Code of Conduct

Background: About The Alliance for Equality of Blind Canadians

1. The Alliance for Equality of Blind Canadians (AEBC) is a national, not-for-profit charitable organization that works with and for blind, deaf-blind, and partially sighted Canadians across the country. We work to encourage the full participation of our constituents in all aspects of society: at work, in play, with the family, in business and commerce, in politics, in the arts, and in entertainment.

Our work consists of

  • Public education, to better inform the public and other stakeholders of the rights, responsibilities, and capabilities of blind, deaf-blind, and partially sighted Canadians.
  • Peer support and training, providing opportunities for individuals to share their knowledge and to teach one another skills and technology that help them to fully participate in everyday life.
  • Advocacy support, assisting individuals and groups in achieving equitable access to programs and services.


A long-standing concern for the blind and low vision community continues to be access to telecommunications and broadcasting services. We have been successful over the years in securing some mandatory descriptive video ("DVS") programming requirements, and certainly the availability of descriptive video across the broadcasting networks, particularly for Canadian programming, has expanded greatly over the past five to ten years.

However, anecdotally, problems remain:

  • Individual consumers lack the knowledge or accessible tools to access the description even if it is available.
  • Inaccessible set-top boxes (which nowadays are the primary gateway to most broadcasting undertakings) present accessibility challenges and limit the ability of blind and low vision consumers to access broadcast media.

Please find below AEBC’s comments on the Commission’s proposed Television Service Provider Code of Conduct, which we consider a welcomed development in Canada.


2. The introduction to this Public Notice states in part:

“TVSPs include cable, Internet Protocol television (IPTV), and national satellite direct-to-home (DTH) service providers."

We fully support the Code covering all of these service providers.

Communicating in Plain Language

3. The draft Code of Conduct states in part:

The Draft Code contains provisions that address matters such as use of clear language, setting out all charges, promotion of packaging options, promptness of service calls and rebates during service outages. It also contains provisions that require a clear summary of critical information setting out the channels selected by a customer, all charges, and information about how to complain and seek recourse.

Providing information in plain language is important for all customers, but particularly, for some members of the disabled community (those with visual impairments due to blindness and low vision; other print disabilities due to learning/cognitive and motor impairments). And including specifics on areas that must be offered is useful.

Provision of Documents in Alternative Formats

4. The Draft Code states in part:

  1. A TVSP must provide a customer with a copy of the agreement in an alternative format for people with disabilities upon request, at no charge, in a timely manner.”

This is an important provision, but the current wording needs expansion. It should emphasize that “an alternative format” means and should include the customer’s preferred alternative format, including electronic, large print and Braille, and in either English or French.

Service Calls

5. If you are blind, getting assistance from technical staff is often frustrating and less than satisfactory, as technical staff have no understanding of a screen reader and that a blind person cannot see and uses key strokes and not a mouse to navigate the keyboard! Frequently, one is asked to “look” at a section of the screen, or move the mouse to a particular point or numerous other inappropriate responses.

To remedy this glaring, ongoing systemic barrier, major service providers need to train a number of their technical staff to develop an understanding of how a screen reader works and how blind customers navigate a keyboard with key strokes and not a mouse

Cooling Off Period

6. The Code should add an additional provision covering a cooling off period after the purchase of a new product or service for a period of at least 10 business days. Sometimes a customer is convinced into purchasing a product or service that, upon a bit more reflection, the customer neither needs or wants. In addition, in the case of customers who have a disability, the customer may determine after the new product or service is installed that it isn’t as accessible or usable as expected, or doesn’t fit his/her needs as much as expected. Device trial periods for evaluation and training need to be long enough so that potential users are able to ensure they can use their equipment effectively. It should be noted that traditional rehabilitation centres serving the visually impaired will not take on the training task.


7. The proposed Code of Conduct is an important development for all Canadians, and AEBC hopes its provisions can be enhanced to offer even greater clarity to both service providers and customers.

*** End of Document

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