This is the third article in our series on the Commonwealth Bank of Australia’s “Albert” point-of-sale touchscreen payment device.
Albert has been available to Australian merchants since March 2015 and the bank is marketing it to retailers, cinemas, restaurants, festivals and other businesses and government services that use EFTPOS terminals.
The PIN entry function of this device is not functionally accessible for many people who experience blindness or significant vision impairment (357,000 Australians); combined vision and hearing difficulty (3,800,000 Australians), acquired brain injury (700,000+ Australians) and other cognitive disabilities (668,100 Australians), or manual dexterity difficulties (685,000 Australians). So, approximately 25% of the population. It also poses a challenge for a significant number of the 53% of those older Australians who report having a disability.
DGI has received reports of outlets that have affixed Albert to a pole, no doubt due to concerns the tablet may be stolen or dropped, as replacement of the device incurs a fee to the merchant by the bank of $1,500. This creates an extra difficulty for people with residual vision, or restricted movement, who often need to manipulate an object to get the best angle to see the screen or use gestures.
Our first feature article titled Commbank’s new EFTPOS “Albert”: Accessibility short-changed was followed by our second feature article on how Councils across Australia are choosing to adopt CommBank’s ‘Albert’ new payment system in spite of their knowledge that the device is not accessible to people experiencing vision, cognitive and manual dexterity disabilities.
So what has happened since the Digital Gap Initiative first broke the news on this inaccessible payment device?
Well, a lot and little.
“Accessibility Mode” Out of Touch with Retail Environment
It appears that the bank has finally acknowledged that it could have done more to incorporate accessibility in its design processes. On its Accessibility Mode for Albert page, Sarah Abbott, Senior Manager Diversity and Inclusion, Commonwealth Bank, states:
“Commonwealth Bank recognises and endorses the importance of payment accessibility, and we are continually enhancing the features of our payment devices, including improvements to the accessibility function of Albert for blind and vision impaired customers.
“We continue to build a strong culture of awareness, understanding and participation for people with a disability. This includes looking at improving our future design processes so we can better include accessibility standards for platforms used by our customers and employees.”
While it is positive that the Bank has made this declaration, they need not wait for the future to remedy the accessibility deficit of Albert.
Kate Begley, Policy Advisor at Vision Australia, in their Submission to the Economy and Infrastructure Committee Inquiry into the regulation of ride sourcing services (dated 5 August 2016) (page 7), further states:
“Another area of technological development is in the use of touch-screen tablet devices, with gesture based input, for the purpose of processing financial transactions. The Commonwealth Bank’s Albert Payment terminals are one such example. There is a growing trend towards the use of touchscreen-based payment terminals that are completely inaccessible for the majority of people who are blind or have low vision.
Regardless of attempts to familiarise people who are blind or have low vision with tablet gesture based devices, it must be emphasised that this is neither the preferred, nor the most suitable payment option for the majority of our community.”
This demonstrates that the steps the bank has taken in the direction of retrofitting accessibility in Albert have not measured up to the needs of the many people who are simply not able to enter their PIN number independently at outlets where the payment device is currently in use.
Basically, the bank expects we will all have to use gestures, instead of using the familiar tactile keypad with a dot on the number 5 that has provided a practical means for almost everyone to use a point-of-sale device everywhere in the world for decades, thanks to the genius and insight of Bell Labs industrial psychologist, and pioneer in human factors engineering, John E. Karlin.
To fully comprehend the profound thinking that went into the design of telephone-style tactile keypads, we urge our readers to read the obituary of John. E. Karlin, published in the New York Times on February 8, 2013.
It is doubtful that the same depth of research has gone into human factors engineering with touch screens, virtual keyboards and keypads, given the amount of companies now developing tools adapted from the analog world to tackle the significant limits of touch screens.
The natural course of progress means that at times even the best practices have to give way to new ideas. But a new idea that makes it difficult for people to perform an everyday task that was previously simple is not progress or innovation.
To get an idea of Albert being used in “Accessibility Mode”, it is worth tuning in to the Talking Tech podcast – June 7, 2016 by David Woodbridge, Senior Adaptive Technology Consultant at Vision Australia. David is demonstrating a tutorial app he downloaded to an Android smart phone. It sounds “easy enough” when David demonstrates the PIN entry steps. But with no disrespect intended to David, the following points need to be made:
- David is an experienced user and demonstrator of technology (he worked for Apple Australia as an Accessibility Ambassador from 2009-2015 so over 6 years of daily experience with touch screen, gesture technology). The average disabled or aged customer will not likely have his level of expertise and confidence in using new technologies;
- The demo includes audio feedback of numbers, which will not happen when using Albert in live-mode for PIN entry;
- David is using the demo in a private, quiet and relaxed setting, not at the check-out queue in a busy and noisy shop, restaurant or mobile food van at a music festival, street carnival or major sporting event;
- David is likely to have practiced the PIN entry step repeatedly, even before presenting this demo. The demo is quite long, yet it’s still the “short version” of how much someone would need to practice to enter their PIN correctly in a few seconds. It’s the equivalent of “I cooked this one before the show”, when a chef demonstrates a recipe on a cooking show;
- Albert is an Android device and the demo tutorial is only for Android devices. Many blind people are more likely to have iPhones or other IOS devices, if they have a smart phone at all;
- The audio prompts in the demo tutorial can be heard cautioning the user to take care of swiping straight in the direction of the numbers on the keypad. Many blind people will find it challenging to trace a line on a smooth surface, as will those who are sighted but may have poor eye-hand coordination; and
- The demo has a friendly little suggestion at the end that you should practice the PIN entry before attempting to enter it in Albert in a real situation. But, what are all those people who don’t have an Android device to practice the demo supposed to do?
Further to these points, the “accessibility mode” in Albert needs to be switched on by a sighted person. Even though the bank added instructions for “accessibility mode” in its Merchant Guide distributed with Albert (in the format of an inaccessibly designed PDF so not even able to be interpreted by a screen reader user) after DGI pointed out its omission in September 2015, many merchants report being unaware this mode is on the device, let alone how to turn it on or guide a customer on how to use it.
So what is DGI’s solution? It is simple enough: Albert has Bluetooth capacity so it should be possible for an auxiliary tactile keypad to be paired to the device.
Next wave of lawsuits against retailers who use touchscreen POS devices
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.
The Law Office of Lainey Feingold and Co-Counsel Linda Dardarian have negotiated close to a dozen agreements with national retailers requiring telephone-style keypads at point-of-sale devices so that people who are blind do not have to disclose their PIN when using a PIN-based card.
These have included:
- Raley’s Point of Sale Settlement Agreement
- Best Buy Tactile POS Settlement Agreement
- Trader Joe’s Point of Sale Agreement and Amendment
- CVS Accessible Web Site and Point of Sale Settlement Agreement
- Target Point of Sale Settlement Agreement
- Staples Point of Sale Press Release
- Dollar General Settlement Agreement
- Rite Aid Tactile POS Agreement
- 7-Eleven Point of Sale Agreement
- RadioShack POS and Web Agreement
- Safeway POS Agreement
- Wal-Mart POS Agreement
Note: Lainey Feingold is a disability rights lawyer and an author who works primarily with the blind community on technology, digital, and information access issues. She is nationally-recognised in the US for negotiating landmark accessibility agreements without lawsuits and for pioneering the collaborative dispute resolution method known as Structured Negotiation. Lainey’s book about structured negotiation, Structured Negotiation: A Winning Alternative to Lawsuits was just published by the American Bar Association (ABA). Read about Lainey’s book, available for sale on the ABA website in a range of formats.
In America it is therefore predicted the next wave of lawsuits under the ADA (their country’s equivalent to our own Disability Discrimination Act) will undoubtedly be against businesses that use inaccessible touch screen point-of-sale terminals. A number of complaints have already been lodged here in Australia under the Disability Discrimination Act (DDA) regarding the inaccessibility of this device.
It would therefore surely be prudent and relatively cost-efficient, and technically feasible without compromising the concept or design of the product, for CommBank to supply all the merchants who have signed up (or will sign up in the future) to use the Albert terminals, with compatible auxiliary Bluetooth tactile keypads (which must be secured to the device by a cable so they are immediately available whenever a customer requires access to it).
Disabled unable to get a fair piece of the App Pi
The PIN entry issue is just one barrier. Albert has pre-installed Apps, and at the time of writing we were unable to obtain verifiable information if these Apps are accessible.
On the Pi App bank support pages, which feature basic descriptions about each app available for use on Albert, there is no mention of Accessibility.
One of the most talked-about Apps on Albert, however, is the “Split Bill” App. The description states this App “has been designed to enrich the customer experience between restaurants and their customers. It allows:
- Fast and simple splitting of the bill with a human touch
- Each person at the table to pay their share and add tips
- A summary showing total amount of a bill paid on card, by cash and tip amount”
To read and hear these upbeat promos, and to know that chances are that many people will miss out on that “enriched customer experience”, or to put it in more down-to-Earth lingo, miss out on the ordinariness, or sheer fun, of working out one’s share of a bill, like everyone else sitting around the restaurant table, is dispiriting.
Even for those who manage to get used to entering their PIN in the device, what about access to all these other Apps? The description of the Accessibility App states that it “Enables customers to practice the secure PIN entry process using Accessibility mode.” On the “Accessibility Mode” page, again reference only appears to be made to PIN entry “accessibility”.
App developers and merchants have been encouraged to design new Apps for the device, and there is a Software Developer Kit (SDK) but it is only available to registered developers and there is no reference to Accessibility whatsoever in its Pi Developer Terms and Conditions Agreement.
And if CommBank’s stylish YouTube Albert promo includes any mention of the Accessibility Mode, it certainly didn’t rate a mention in the lead presentations.
Sounds like Accessibility is not cool enough, or not profitable enough! And yet it can be both.
Albert continues to leave a bad taste in the mouth
But it appears that it’s not only accessibility issues plaguing Albert. As was reported in our second feature article, the Taste of Tasmania was one of the first large-scale events in Australia to use the Commonwealth Bank’s Albert system. This year the event will again be a cashless event, but Hobart City Council has abandoned the controversial Albert system in favour of a more accessible EFTPOS setup.
Albert processed more than 330,000 transactions for the event, but was plagued by connectivity failures and voided transactions. So it didn’t just fail in being accessible for all, but also from a universal design perspective.
No doubt CommBank’s competitors are watching all of these matters closely and are being mindful of the need to truly innovate in this competitive arena by not losing sight of the human factor in the design of new technologies.
Although this article has once again focused on the Albert payment terminal, it is only one of the inaccessible touch screen devices used in payment and related processes that DGI has been monitoring. Touch screen payment devices are also becoming increasingly used in the taxi and ridesharing industry. Touch screen self-service kiosks are also in use in airports, libraries, Centrelink, Medicare and other customer service centres, and are now being installed in major retail centres such as supermarkets. Touch screen controls are replacing physical buttons in lifts and security systems in many office buildings, hotels and residential apartments. Then there is the full range of home appliances now overlooking us as consumers. If legislation and mandatory standards on the accessibility of digital technologies are not applied soon, it will be of little consequence if payment devices are accessible because for many there will be few things usable to buy.