Broadcasting Committee

Evidence from Wales Council for Deaf People

Inquiry into Public Service Broadcasting

It has been reported in Hansard that around 17% of the population have a hearing disability of varying degrees. This equates to almost half a million people in Wales. The vast majority are over 50 years of age and around 50% of people over 60 years of age are included in this category.

One of the main methods of access to broadcasting for people who are deaf or hard of hearing is via subtitles. All terrestrial broadcasters of television programmes must provide a legally determined percentage of their output with subtitles. This is quite high at around 80%and although it does not fall within the legislation the BBC aims to subtitle 100% of its output this year.

Obviously therefore subtitles are well recognised as an everyday way of access to broadcasting for a large section of the community. Indeed their rights to this are protected under the Disability Discrimination Act 1995/2005 Part 3.

This brings us to the question of quality, there is little point in using subtitles if they do not actually provide full access to the programme to which they are attached. Most programmes are pre-recorded and the subtitles are added later. These subtitles are usually of high quality.

However, with news programmes subtitles are frequently "live", that is , they are added as the programme is broadcasted by one of several methods. This means the subtitles will be slightly behind the actual picture to which they relate. This in itself does not pose too much of a problem as it is possible to "read" the news and one is still able to receive the same information as one who is not deaf or hard of hearing.

The problem arises when subtitles are incomplete, broken or missing altogether. In this case the viewer is robbed of their right to equal access to the programme. These problems are caused either by the equipment not being satisfactory or the inability of the subtitler or possibly a combination of both.

Different broadcasting companies have differing levels of success with "live" subtitles, some are very good for example Sky News and BBC News 24 are both quite competent. The situation with ITV Wales is quite different, the quality is very poor and one is frequently left completely in the dark about what is happening in Wales.

This is surprising as the ITV general news for the UK does not normally suffer from this problem. One would have thought that ITV (Wales) as part of the ITV network would have access to similar service equipment allowing them to produce better subtitles.

There have been, in the past, representation to ITV (Wales) when it was HTV (Wales) to improve things. This was promised but today 3 years later there has been no improvement. Ofcom point out that the Broadcasting Act does not commit to a particular quality standard for subtitles thus ITV (Wales) is not breaking the law with regards to this Act.

Investigation regarding the DDA 1995/2005 part 3 has indicated that it may be possible to prosecute under this Act as disabled people (deaf/hard of hearing) are not receiving equal service as non disabled people. The now defunct Disability Rights Commission concluded that it may not be in the public interest to prosecute and thus no action was taken by them.

This means ITV (Wales) is continuing with an inferior service to deaf and hard of hearing people indicating a lack of respect for the rights of this section of the community.

Norman B Moore
Director
Wales Council for Deaf People