by Gisele Mesnage and Ted McCoskey
Our first editorial is not published with the intent of naming and shaming the Commonwealth Bank of Australia (CBA) or any other business. Our message is that the story of Albert highlights the need for national, compliance-based standards on digital accessibility.
Albert has been available to Australian merchants since March 2015 and the bank is marketing it to retailers, cinemas, restaurants and other businesses and government services that use EFTPOS terminals.
When CBA initially announced the coming of Albert in a media release on 17 July 2012, it proclaimed, “Albert, created using the Android Ver 4.0 operating system, is a first-of-its kind solution in the market. Moving beyond the parameters of traditional, simple payment devices, the human-centric design of Albert has been specifically created to improve customer interaction.”
But that “human-centric design approach”, which the media release, states was “engineered from the ground-up”, does not appear to encompass use by customers of diverse abilities and needs. Accessibility does not appear to have been integrated into the design from the ground-up.
Alice meets Albert
It was an ordinary day for a blind woman from Geelong, Victoria, whom we shall name Alice, when she pulled out her payment card to pay a consultation fee exceeding $100 at a doctor’s surgery. Alice fumbled for the familiar EFTPOS pad to locate the raised dot on the #5 of the keypad so she could orient her fingers to enter her personal identification number (PIN). The receptionist explained this was a new touch screen tablet and the keypad was on the screen. There was no tactile overlay on the smooth glass surface of the screen.
The blind woman asked if the device had audio to guide her through the operation. The receptionist did not know. In the end, trying to be helpful, the receptionist asked the patient to whisper her PIN and she entered the number on her behalf.
The blind woman had met Albert.
Uncomfortable with having had to give out her PIN, she reported the incident to CBA and says the telephone support staff advised her there was no accessibility on the device, and that this was “an oversight”. She then contacted the new blindness and low vision organisation Blind Alliance Victoria, which referred the case to the Digital Gap Initiative.
The Digital Gap Initiative spoke with the blind woman and then contacted the Managing Director, Cash Management & Payment Solutions at CBA, in late August 2015.
The Digital Gap Initiative investigates
On 10 September 2015 President of the Digital Gap Initiative, Ted McCoskey, and the group’s founder, Gisele Mesnage, met with officials from CBA to get the facts on the accessibility of Albert. We were told the bank was presently working on an accessibility solution. We had an opportunity to trial the accessibility solution on a test device.
Gisele Mesnage: “It took over 10 minutes to listen to the instructions on what gestures I had to use to enter a PIN. I am just learning to use an iPhone. This was an Android device and I just could not get the gestures right. I had three failed attempts at entering a pre-set number. In a real-world situation this would mean I would have been blocked from using my card. There appeared to have been no understanding by those who came up with the accessibility solution of the difficulties for those who are blind or have poor dexterity of moving their fingers in a straight line on a flat surface, without any tactile or audio clues.”
Ted McCoskey also used the device. Ted is a former Vision Australia Adaptive Technology Trainer who has trained hundreds of users on how to use touch screen mobile phones and tablets in addition to consulting on accessibility and usability testing. He was also unable to successfully enter his PIN within three attempts.
Ted McCoskey: “What does this mean for the estimated 350,000+ people with a vision impairment of some sort? Blind and low vision users are only the tip of the iceberg – many other users rely on the tactile nature of current model EFTPOS machines in order to enter their PIN numbers. Those with Parkinson’s or other dexterity issues with their hands, to name just a few. Think of anyone you know who has trouble using a touch screen mobile. Many people with cognitive or other learning disabilities also rely on tactile clues to complete tasks like this.”
Digital Gap Initiative acknowledges that the bank is making an effort to add accessibility to the device. But in our view this effort is belated and inadequate. Bottom line: Albert was released and sold to businesses without accessibility features.
Further, the Merchant Guide distributed with Albert since March 2015 makes no mention of the fact that the device as no accessibility features; that the bank has an accessibility solution in the pipeline and that it will require special training of staff and customers; or what business owners should do if a person is unable to enter their PIN in the EFTPOS device.
So where does this leave the businesses who have signed up for an Albert plan – and they include Foot Locker, Event Cinemas, David Jones, hotel chain Rydges and the parent of petrol distributors Mogas and EasyFuel? What will it mean when a customer cannot complete a payment transaction because they cannot enter their PIN in the EFTPOS device? What will it mean if an employee with a disability is unable to use the apps on the tablet?
CBA has had an Accessibility and Inclusion plan since 2004. The Australian Bankers Association’s (ABA) also has Industry Standards on Accessibility of Electronic Banking, which were introduced in 2002. The voluntary ABA standards cover ATMs, EFTPOS, Automated Telephone Banking and Internet Banking. The Digital Gap Initiative has been approached by the ABA to contribute to the review of these standards.
The CBA’s Accessibility and Inclusion plan states that CBA “considered accessibility and the ABA Standards when designing new EFTPOS terminals for CommBank’s EFTPOS fleet”. It also states that the bank “conducted consultation with customers with a range of disabilities to help inform and test a more accessible design.”
Gisele Mesnage: “That may be the case, but I heard nothing about these consumer consultations for Albert: not from the bank, not from any of the blindness and low vision agencies or advocacy groups, not from any accessibility and usability consultants; not from any blind community lists or social media networks. It is through these avenues that testing participants are usually recruited.”
“The CBA have told Ted and I they would be running ‘familiarisation’ sessions. But how practical is it to familiarise thousands of people with the steps to enter their PIN? And will other banks decide to develop their own touch screen EFTPOS machines with their own accessibility solution, and will we have to learn different sets of gestures for each one? Without national mandatory standards, that is very much on the cards.”
Over 30 years of data on accessible ATMs and point-of-sale terminals
Aside from the CBA and ABA policy framework, the accessibility issues relating to payment devices are well-known and well-documented. There is no excuse here for lack of awareness.
The first talking ATM was installed by the Royal Bank of Canada on 22 October 1997. The talking ATM was a result of concerns Chris and Marie Stark, two blind customers, raised with the bank beginning in 1984. Their concerns gave rise to a discrimination complaint with the Canadian Human Rights Commission in 1991. A working group of blind Canadians has now been assembled to advocate for accessible touch-screen point-of-sale devices. An article titled “The Epidemic of Inaccessible Touch-Screen Point of Sale Devices” published in 2012 in the Journal of the Alliance for Equality of Blind Canadians declares, “The barrier here is not a technological one; it is a lack of will, oversight or regulation”.
Although touch screens only became popular recently, concepts for their application go back 50 years to 1965. Ideas of designing touch screen interface for the vision impaired (IVI) have been around for many years. For example Patent US6464135 “Method and system for assisting the visually impaired in performing financial transactions”, was published in the United States on 15 October 2002. This was a decade before the CBA announced their plan to release Albert.
On 8 October 2008, a finance industry online newsletter published an article titled “Advocates for the blind take aim at touch-screen terminals”, reporting on the experiences of a blind lawyer in the US named Jonathan Simeone, who told of his encounter with a touch screen payment device at a supermarket:
Jonathan Simeone: “I couldn’t do debit because I wouldn’t give them my PIN, so I had to switch from debit to credit. Since they had already rung me up, the cashier had to find a manager who knew how to print out a paper credit card receipt and I had to sign that. Because I couldn’t do those things, it held up the line for a minute.”
Jonathan’s experience could soon be the reality for many people in Australia.
Gisele Mesnage: “When I was trying out Albert I could picture myself in that same type of situation, with customers getting impatient while I struggled to enter my pin in one of these Albert devices. And what of the unsuspecting customer who has to first listen to the 10 minutes-plus tutorial?”
Ted McCoskey: “It’s hard to believe that in 2015, we are still treated as second class citizens every time a new device, website or app that everyone says is ‘revolutionary’ is released because accessibility is bolted on at the end, or worse yet as in this case, released with no accessibility or communication to users, merchants, or bank support staff as to how a blind user is going to pay for a service they just used. There are already thousands of Albert EFTPOS terminals in use by merchants. They’ve been out for nearly 6 months, and CBA’s current suggestion is that users anticipate coming across Albert one week in advance by having to organise a ‘signature preferred card’ from the issuing bank of their credit or debit card.”
“Contrast that to the marketing material for Albert, which talks about how merchants lose sales because of not being able to process them fast enough … that if it takes longer than 5 minutes to pay, a customer will walk out. The average lost sale amount is $94, and so on and so on. How many sales are going to be lost if the accessibility solution the bank demonstrated to Gisele and I is released, and requires a user to sit through a 10-minute tutorial before they even try to use Albert? In my opinion, it gets right back to the lack of standards. If manufacturers knew what their responsibility was in the first place, and adequate mechanisms in place to hold them accountable when they fail, this simply wouldn’t happen.”
On 31 March 2010, 5 years prior to the launch of the Albert touch screen tablet, US retail chain Best Buy announced that it had begun to add tactile keypads to point-of-sale devices at Best Buy stores, enabling shoppers who cannot read information on a touch screen to privately and independently enter their PIN in order to protect their financial privacy. The website of the US-based Law Office of Lainey Feingold includes archives on other initiatives relating to accessible point-of-sale terminals and talking ATMs.
In California, USA, since 2004 the law has required that any newly purchased touch-screen-based credit card terminals or any upgraded units be equipped with tactile number keypads. And on 15 March 2012, the US adopted Talking ATM Technical Standards after a 17-year-long campaign initiated in1995. The Talking ATM requirements are part of what is known as the 2010 Standards for Accessible Design, which are themselves part of the US Department of Justice Regulations implementing the Americans with Disabilities Act (ADA). The Standards for Accessible Design were adopted in September 2010, but the technical standards for talking ATMs were not mandatory until 15 March 2012. In the US it is predicted the next wave of lawsuits under the ADA will undoubtedly be against businesses that use inaccessible touch screen point-of-sale terminals.
And these are but a few of the resources readily viewable online on the question at hand.
Gisele Mesnage: “Looking back on this timeline of events and the copiousness of information the bank had at its fingertips pertaining to the accessibility of payment devices (1984-2015), it is crushing that consumers have been short-changed on accessibility again. More than 30 years since the Canadian human rights complaint over talking ATMs, Australia’s largest bank releases a touch screen payment device that is not accessible. Here we were, cradling Albert in our hands, being told it was a “first in the world”, “revolutionary”, and loaded with apps that could do these amazing things. I should have felt proud that this was an Australian innovation. But all I could think about was of the many people with disabilities, older people, and others who would no longer be able to perform the simple task of entering their PIN number at a point-of-sale.”
Beyond the PIN issue
The PIN entry issue is just one barrier. Albert has 8 pre-installed apps, and currently these are not accessible. App developers and merchants have been encouraged to design new apps for the device, but we could not find any reference to accessibility in the promotional material given to app developers and merchants.
Gisele Mesnage: “It has to be remembered that people who are affected by the lack of accessibility and usability of digital technology are not just consumers. They are also accountants, employees, employers and business owners. For example, the lack of accessibility of an everyday piece of technology such as an EFTPOS device does not only create a barrier for a customer who is unable to use the device at the restaurant: it may very well make a difference to a person being able to have a job at that restaurant or compete in the business world as a restaurant owner. Think of how many cafes and other social enterprises today employ, or are run by, people with disabilities. This example is applicable to any scenario involving the use of digital technology in our society. This case encapsulates for me the reason why I founded the Digital Gap Initiative.”
Ted McCoskey: “In addition to a user having previously secured a signature preferred card, which is in effect having the user decide and accept that they cannot participate in the new digital world, the other main alternative offered by the CBA was the availability of paper-based transactions, which are often only able to be done, or known how to be processed by management staff at merchant locations. What about the weekend waitress at Joe’s Café working night shift with no manager? What about the casual holiday worker doing Christmas shifts at a large clothing store? What about the fact that a blind user has just as much right to use an EFTPOS terminal as anyone else, and if a bank wants to “change the world”; they need to change it for everyone.”
Our vision: an inclusive digital world
Again we repeat that this editorial is not published with the intent of naming and shaming CBA and we hope to continue the open dialogue between the bank and the Digital Gap Initiative with respect to the accessibility of its products and services. In the anecdotal example of the incident in the doctor’s surgery at Geelong, there were four parties involved: the patient (the customer), the receptionist (employee), the doctor (the merchant) and CBA (the vendor). All parties, including the bank, were in a sense casualties of the absence of regulations on digital accessibility.
The case of Albert points to the need for mandatory national standards on digital accessibility. Voluntary standards or guidelines have their place in our society but the case of Albert evidences their limitations. CBA had a singular opportunity to demonstrate progressive thinking and rise to the challenge of integrating accessibility in the design of its innovative product, and had both the bank’s own Accessibility and Inclusion plan and the Banking Industry (ABA) Standards to refer to. This does not seem to have made an iota of difference.
Ultimately, the responsibility for yet another example of how the digital gap is created lies squarely with government. The Australian guidelines for e-commerce which were developed to close the “digital divide” for people with disabilities and older persons, issued in 2006, are woefully outdated and are not mandatory.
It is incredible that, even though we are now well and truly in the digital era, there are no mandatory standards or compliance-based regulations around digital accessibility.
All of the CBA’s alternative options for those who cannot use Albert may have their place in terms of meeting different needs and preferences for making a payment. But the position of the Digital Gap Initiative is clear: our target is the accessibility of digital technology and services. We will not be relegated to the past and be satisfied with using telephone services in lieu of an accessible website or mobile app, or a signature preferred card in lieu of an EFTPOS terminal. We want to be part of the digital age.
It is likely that many businesses will balk at the idea of more legislation. There was a long battle for mandatory standards around access to the physical environment and initially much resistance from developers, building owners and architects to the idea of imposing more regulations on industry. But in May 2011 the Property Council of Australia issued a statement in support of the Disability (Access to Premises – Buildings) Standards, stating in part, “The Premises Standards provide much-needed certainty for building owners about how to comply with the Disability Discrimination Act”. This common-sense pronouncement notwithstanding, the application of the standards by way of features such as access ramps have benefited the community at large, including businesses.
The Digital Gap Initiative advocates for national, compliance-base standards on digital accessibility. Such standards would provide the same certainty and economic benefits as those for physical accessibility. We need now for the ABA and other peak bodies, including the Business Council of Australia, to support our drive for national compliance-based regulations.
We can only hope that in his new role as Prime Minister, Malcolm Turnbull, who formerly held the office of Minister for Communications and headed the Digital Transformation Office (DTO) will show leadership on this critical question.