CBA’s new EFTPOS “Albert” – accessibility short-changed

First Editorial
The Commonwealth Bank of Australia (CBA) is promoting a new touch-screen tablet EFTPOS payment device known as Albert. The CBA developed Albert with Wincor Nixdorf and IDEO.
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 the Commonwealth Bank initially announced the coming of Albert on 17 July 2012, it proclaimed that it was a world’s first, that Albert was engineered from the ground-up using a human-centered design approach, and that it would revolutionize the point-of-sale experience for consumers and businesses.

But did that “human-centered ” approach encompassed humans of diverse abilities and needs, and integrate accessibility into the design from the ground-up?

Alas, it does not appear so.

It was just an ordinary day for a blind woman from Geelong in Victoria when she pulled out her payment card to pay a consultation fee exceeding $100 at a doctor’s surgery. She 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 PIN. The receptionist explained this was a new touch screen tablet and the keypad was on the screen. There was no haptic marker on the smooth glass surface of the screen and 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.

She reported the incident to the CBA (whose telephone support staff advised there was no accessibility, that it was “an oversight”)  and to the new blindness and low vision organisation Blind Alliance Victoria, who referred it to the Digital Gap Initiative.

On 10 September 2015 President of the Digital Gap Initiative, Ted McCoskey, and founder, Gisele Mesnage, met with Mark Wood and David Budzevski from the Commonwealth Bank, at its Sydney offices in Darling Park, 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 test out the prototype of this solution.

Gisele: “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 and 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 and in a real-world situation this would mean I would have been blocked from using my card.

Note: Ted, perhaps here you could add your experience, comments, etc.

While we acknowledge that the bank is making an effort to add accessibility to the device, we take the view that this effort is belated and inadequate.

The accessibility issues relating to payment devices are well-known and well-documented. There was 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 turned into a discrimination complaint with the Canadian Human Rights Commission in 1991.
The CBA has had an Accessibility and Inclusion plan since 2004.

Gisele: Well, in part, this plan was developed after I lodged a complaint in the Australian Human Rights commission under the Disability Discrimination Act (DDA) in 2002, represented by the Public Interest Advocacy Centre (PIAC). The complaint, which followed approaches to the bank by Blind Citizens Australia (BCA, related to the accessibility of the bank’s ATMs and its website.

The CBA’s plan was also in response to the Australian Bankers Association’s (ABA) Industry Standards on Accessibility of Electronic Banking, which had been introduced in 2002. The voluntary standards cover Automated Teller Machines (ATMs), Electronic Funds Transfer at the Point of Sale (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.

In March 2006 the Australian Guidelines for Electronic Commerce were issued by the Treasury and the Attorney-General’s Department.

On 8 October 2008, reputable finance industry online newsletter creditcars.com 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: “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.”

Gisele: When I was testing 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.

Note: Ted, perhaps here you could come in with a comment and refer to the stats from the bank’s media release, which you referred to at the meeting. They are at
https://www.commbank.com.au/about-us/news/media-releases/2015/commonwealth-bank-set-to-disrupt-the-payments-space.html

Although touch screens only became popular in recent years, concepts for their application go back fifty years to 1965. And 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 in October 2002. This was a decade before the CBA announced their plan to release Albert

On March 15 2012 the US adopted Talking ATM Technical Standards.

Gisele: Reflecting on this timeline of events pertaining to the accessibility of payment devices (1984-2015) is crushing. More than 30 years since the Canadian case over talking ATMs and 13 years since my own case and the publication that same year of that US patent relating to accessible touch screen EFTPOS, Australia’s largest bank has released a touch screen payment device that was 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.

Note: Ted, here perhaps you could add comments re the limitations of the options the bank cited?

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. The 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 policy and the industry-based ABA Standards as reference, and this did not make one iota of difference. The CBA should be accountable for this omission but, ultimately, the responsibility for yet another example of the digital gap, lies squarely with government. It is unconscionable 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.

Regulation around access to digital technology would benefit all stakeholders. 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 regulations on the 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”. The Digital Gap Initiative takes the view that national standards on digital accessibility would provide the same certainty to the digital industry. We need now for the ABA and other business peak body, including the Business council of Australia, to support our drive for national compliance-based regulations.

It has to be remembered that people with disabilities, older people and others who are affected by the lack of accessibility and usability of digital technology are not just consumers. They are also employees and 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 problem for a customer who is unable to use the device at the check-out at the supermarket queue: it may very well make a difference to a person being able to have a job at that supermarket or compete in the business world as a supermarket owner. This example is applicable to any scenario involving the use of digital technology in our society.