DGI Position Statement on Touchscreen Point-of-Sale (POS) Devices

Standards, Laws and Accessibility

According to Standards Australia, globally there are well over half a million published Standards.  These are the products of over 1,000 recognised Standards Development Organisations (SDO) worldwide.

The International Standards Organisation (ISO) has a portfolio of accessibility-related standards, but curiously Accessibility has yet to be identified as one of the benefits of standards by ISO and other SDOs.

The UN International Year of Disabled Persons (IYDP) (1981) and the subsequent UN Convention on the Rights of Persons with Disabilities (CRPD) (2006) have been instrumental in driving many positive reforms in this social policy area, as have the three standards under Australia’s very own Disability Discrimination Act (1992):

But in this digital age, in Australia and internationally, there is a startling want of laws and standards governing digital technology, particularly requirements for incorporating Accessibility and Usability features in digital products and services.

Yet the need is evident and urgent: people with disability, older persons, those who are socially disadvantaged and those with limited tech-savvy skills are among those who experience the biggest barriers when using online services, mobile apps, touchscreen home and office appliances, automated services and the myriad of other technologies now so embedded in our everyday lives.

It is against this backdrop that the Digital Gap Initiative (DGI), a not-for-profit, grassroots Australian organisation, was founded on 7 December 2014, to advocate for legal, policy and other systemic reforms, including national and international standards, with the objective of closing the gap between those able to participate in the rapid transformation of our society and those who are being left behind.

Where to begin?

The challenges of tackling the accessibility barriers of our digital age are great, but not insurmountable.  Our motivation to overcome these barriers is deeply rooted in necessity, and above all driven by the conviction that digitalisation offers unprecedented prospects for universal access and real social inclusion.

DGI has therefore identified priority areas for action, among these the surge of touchscreen technologies.

Currently no national or international standards incorporating accessibility requirements for touchscreen technologies exist, a question DGI has been raising since its inception.

But standards can take many years to create and work their way through the adoption process, so it is important to set short-term, achievable goals alongside more long term goals for closing the digital gap.

While DGI is working on its position statement on Australia’s adoption of the EN 301 549 Accessibility requirements suitable for public procurement of ICT products and services, based on its submission to the recent public consultation conducted by Standards Australia, the current barriers presented by touchscreen payment devices, particularly the PIN entry issue, have highlighted a more immediate human rights issue, the basic daily activity of purchasing goods and services independently, so it is this area that our first position statement will focus on.

The Issues

At the time of writing, a number of new touchscreen payment devices are being released on the Australian market.  The first of these, however, and the one on which DGI has the most information is CommBank’s Albert.  Another similar device called Blade is being released by the ANZ Bank, but DGI is yet to acquire sufficient information to comment on this device.  Therefore, Albert is named by way of an example, but all comments apply generically to all similar devices. For the purpose of this position paper, we have not directly addressed the particular issues connected with touchscreen ATMs.

Albert has been available to Australian merchants since March 2015 and the bank is marketing it to retailers, including cinemas and restaurants, festivals and events, and medical, transport and government services that use EFTPOS terminals.  CommBank attempted to retrofit an Accessibility Mode for PIN entry by people who are blind or vision impaired and cannot see the virtual keypad on the touchscreen. But 3 key issues have emerged:

  1. Many people find the current gesture-based PIN entry solution inaccessible, resulting in people divulging their PIN, violating the privacy and security of their payment information and subsequently breaching Payment Card Industry Data Security Standards (PCI DSS);
  2. Accessibility Mode to use this solution can only be activated by the merchant, and people report that many merchants do not know how to do this; and
  3. Accessibility Mode does not extend to the customer-facing and business-related apps on the device.

History of Touchscreen Payment Systems and Accessibility

Although touchscreens only became popular recently, concepts for their application go back 50 years to 1965.  The world’s first colorgraphic touchscreen point of sale computer was created in 1986.

Ideas of designing touchscreen 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.

The possibility of using mobile apps to assist the blind, and others, to interact with touchscreen point-of-sale devices have been touted.  But almost five (5) years on since this solution was suggested, there’s no standard secure procedure for mobile payments.

It is worth noting also that as far back as 2000, the Australian Human Right’s Commission’s report on Access to Electronic Commerce For Older Australians and People With A Disability referred to the then newly emerging touch-sensitive EFTPOS devices and touchscreen kiosks, noting that people who had difficulty using these were being forced to reveal their PIN.  It is disquieting to read through the 19 recommendations made by the Commission at the time, and to then realise that some 16 years on we are revisiting many of the same issues.

It is therefore evident that while it is desirable, possible and necessary to develop a universal accessibility mode for use with payment devices, and codifying this in an international standard, this aspiration is not currently on the near horizon.

On the other hand, since 2004 in California USA, the law has required that any newly purchased touchscreen-based credit card terminals, or any upgraded units, must be equipped with tactile number keypads.

The Law Office of Lainey Feingold, and Co-Counsel Linda Dardarian, has 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.

The Fundamental Principles of Accessibility and Usability

Underpinning the rationale for this Position Statement, and others DGI will develop, are the following fundamental principles.

Principle: Accessibility makes good business sense.

Application to this issue

  • People being held up in a queue while someone has difficulty using the payment device is not good for business;
  • As the US cases above demonstrate, businesses risk being sued if a customer is unable to use the payment device on the grounds of their disability;
  • Businesses also lose significant revenue if a customer does not have the cash to pay to cover purchase of over $100 in the event they are unable to enter their PIN.

Principle: Accessibility and usability should be incorporated in the design phase, not retrofitted.

Application to this issue

  • The accessibility and usability barriers to those touchscreen payment devices currently on the market is a direct result of not considering, and incorporating, accessibility and usability into the design phase;
  • All attempts to retrofit these needs now are likely to be costly and to fall short of providing an effective, standardisable, solution.

Principle: Human Factors (HF) should be at the core of all technological design.

Application to this issue

  • Evidence-based research went into the design of the telephone-style tactile keypad (dial pad) that was used as the basis for numeric keypads used in point-of-sale devices. It evolved out of the pioneering work of Jon E. Karlin in Human Factors Engineering (HFE);
  • The European SDO ETSI has incorporated this principle in its Human Factors (HF); Telecommunications keypads and keyboards; Tactile identifiers Standard;
  • ETSI is working to develop a common standard for tactile identifiers through harmonisation with other European and international SDOs, including ITU-T and ISO for a worldwide standard;
  • Comparatively, despite the long history of touchscreen devices, there is little evidence-based research incorporating HF studies. A notable exception is the research done around Human-Computer Interaction (HCI), but this is still an evolving field.

Principle: Digitalisation has no inherent accessibility barriers.

Application to this issue

Principle: Don’t reinvent the wheel.

Application to this issue

  • The wheel for transportation was invented 5,520 years ago and the inclined ramp 4,620 years ago, the period known as the Bronze Age.
  • While both of these inventions are what some would term “dated”, they have been successfully incorporated, or co-exist, with more modern inventions that actually enhance access;
  • Braille as a literacy medium for the blind was invented over 200 years ago, and the concept as a military code for reading combat messages in the dark pre-dates this, yet today not only is Braille still used in its original form, but it has been successfully electronically adapted for use with computers, mobile phones, etc.

It is generally accepted that the Braille system has succeeded because it is based on a rational sequence of signs devised for the fingertips, rather than imitating signs devised for the eyes.

An example of this is the recent addition of tactile dots on Australian bank notes [see full story];

  • The hardware tactile keypad should be retained until at least such time as a viable alternative mechanism has been developed, tested and standardised (something that has yet to occur);
  • As in the above example of the marriage of Braille with new technology, tactile keypads could be adapted to access auditory (or Braille) account information not currently accessible when using tactile keypads on standard POS devices.

Principle: An existing and proven accessibility mechanism should not be removed or omitted from a product or service, without first executing an equivalent or superior alternative accessibility mechanism to replace it.

Application to this issue

  • The tactile keypad is a mechanism that has provided near universal accessibility for secure and private PIN entry into point-of-sale systems globally for decades;
  • No alternative mechanism by way of gesture-based screen access, mobile access, or other pathway has been successfully implemented to serve the purpose, or standardised;
  • The tactile keypad is already standardised.

Principle: The onus for accessibility and usability of a product and service should be with the designer, manufacturer or seller, not the user.

Application to this issue

  • Consumers and merchants should not need to compensate for the lack of accessibility of a product or service, including being expected to bear additional costs for adjustments or training, etc. (i.e. just as wheelchair users are not expected to carry a ramp with them to board a bus, consumers should not have to carry extra gadgets to use a POS terminal);
  • The Australian Government’s recent adoption of accessible ICT procurement standards support this principle by placing the onus on the supplier to ensure accessibility;
  • Although consumers and merchants need to familiarise themselves with new technology, technologies should conform to usability principles by design, and should not require an unreasonable amount of training;
  • All customer-facing features should be able to be activated by the customer, including Accessibility Mode and other support features.

Principle: People with disability and others with accessibility needs are not just consumers.

Application to this issue

DGI’s Position


Outcomes we are seeking

  1. All touchscreen payment devices should be equipped with an integrated or auxiliary standard tactile keypad as an interim, secondary method for ease of secure, private and independent PIN entry by customers, until an equivalent or superior mechanism or superior method to perform this task is developed, tested and standardised.  The keypad should be coupled and cabled to the device to ensure constant availability;
  2. Accessibility mode, help and training features and all customer-facing apps should be able to be activated by the customer;
  3. All on-board apps on touchscreen and other payment devices should be accessible, based on the WCAG 2.0 ICT informative notes;
  4. Merchants, app developers and other third parties should be required to make their app accessible, as per above, as part of their contractual agreement with the supplier of the payment device;
  5. All manufacturers of touchscreen and other payment devices should be required to abide by the principles of HFE, HCI and inclusive design, including incorporating accessibility features at the design stage.

Actions and Approaches to these Outcomes

  1. DGI supports the current Disability Discrimination Act (DDA) complaints lodged by Blind Citizens Australia (BCA) and some individuals around the accessibility of Albert, issues we first brought to the public’s attention as far back as September, 2015;
  2. DGI will continue to circulate the Change.org petition it co-initiated with blind double-amputee advocate and cricket enthusiast Martin Stewart, calling for the retention of the accessible tactile keypad on touchscreen POS devices;
  3. DGI will approach the Payment Card Industry Security Standards Council (PCI SSC) to recommend developing accessibility criteria as part of the compliance requirements in the PCI Data Security Standard (PCI DSS), including for PIN Transaction Security (PTS) devices and methods for all PCI-certified touchscreen payment terminals
  4. DGI has been approached to contribute to the current review of The Australian Bankers Association’s (ABA) Industry Standards on Accessibility of Electronic Banking which were first introduced in 2002.  The voluntary ABA standards cover ATMs, EFTPOS, Automated Telephone Banking and Internet Banking.  DGI will comment on all of these, advocate for the ABA to adopt guidelines that would prevent recurrences of the release of inaccessible POS devices, and take this opportunity to recommend a review of the ABA’s Guiding Principles for Accessible Authentication (2007);
  5. DGI plans to also confer with the Office of the Australian Information Commissioner (OAIC) to raise the privacy issue of people being placed in the untenable position of divulging their PIN, and confer with other such authorities as appropriate;
  6. DGI will continue to confer with federal, state and local government agencies, bodies and business groups to encourage them to apply the EN 301 549 Standard in their ICT Procurement Policy when considering the purchase of touchscreen payment devices and similar products;
  7. DGI proposes that the Australian Human Rights Commission (AHRC) should develop Advisory Notes to the DDA on touchscreen technologies, including payment devices, ATMs, self-service kiosks, etc.;
  8. DGI will continue to confer with Standards Australia around the development of relevant international standards on touch screen technologies;
  9. DGI will continue to work collaboratively and constructively with other organisations and individuals, including experts, to explore alternative approaches to achieve solutions to the issues.

Why the PIN Entry issue is DGI’s priority concern

As further noted by Vision Australia in their recent Touchscreen Technology Position Statement “more development is required before touchscreen-based payment terminals can be considered sufficiently accessible to be used in… financial transactions”, something DGI has been publicly asserting since September, 2015.  It’s still within the realm of possibility that CommBank, the ANZ and other suppliers of these devices could put a hold on the marketing of these devices, at least in Australia, in response to DGI’s advocacy and community feedback exemplified by the signatures and comments to our petition and Vision Australia’s removal of its initial commentary about Albert on CommBank’s website.  All approaches must be explored, but, in the meantime:

  • No evidence-based practicable solution has been developed that can currently equate or better the use of a tactile keypad for secure, independent and easy PIN entry on touchscreen payment devices anywhere in the world, despite at least 15 years of concerted efforts to this end;
  • A harmonised standard for gesture-based PIN entry that may facilitate a universal solution is not currently in force and may not be on the near horizon;
  • PIN Entry is an everyday task and a solution to the accessibility barriers to the performance of this task cannot wait for a national or international standard to be created and adopted;
  • The alternative for bills exceeding $100 is to pay cash or cancel the purchase (i.e. if the goods have not yet been consumed, as in a restaurant or hotel). This is an imposition on customers and merchants;
  • Currently many people who are blind or vision impaired, older people, people who experience manual dexterity limitations, poor eye-hand coordination and others are being forced to provide their PINs to merchants, which is a violation of their privacy and a breach of the abovementioned PCI Standards;
  • Even people who are savvy users of touchscreen smart phones have reported failure in their attempts to enter their PIN using the gesture-based method in accessibility mode, because of the fact that the operation has to be performed in noisy, busy locations, often with impatient customers waiting in the queue;
  • DGI supports those who call for Accessibility Mode to be turned on by the user. However, we note that even if a merchant is aware of how to turn on this mode, or the manufacturer or bank devises a method for the customer to turn the feature on, this will not, in the immediate, provide accessibility to the on-board apps.  It will only be useful for those who are familiar with, and confident in the use of, the gesture-based solution (evidence indicates a mean of two years of mobile, touch-screen experience is required to be able to confidently evaluate touch-based apps), and will therefore leave without relief those unable to use this solution.  Otherwise, insanely, we may need to become familiarised with different PIN Entry gestures for each device, because the Albert method is patented, whereas a keypad is standard and universal;
  • 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.

In Conclusion

The steps CommBank has taken in the direction of retrofitting accessibility in Albert have still not sufficiently addressed the needs of the many people who are simply not able to enter their PIN number on the touchscreen at outlets where the payment device is currently in use, and now similar devices are arriving on the scene, unchecked.  This is exposing people to the unacceptable risk of needing to reveal their PIN number in order to process payment.  Being put on the spot to enter a PIN without the familiar raised buttons of the tactile keypad (with the dot on the 5 to orientate one’s fingers with surety), is causing people to make errors, and to have their payment card blocked if they fail 3 times.  The experience of having to use the device at locations which are often busy and noisy, and when impatient customers in the queue make loud sighs or tch sounds, is causing anxiety, distress and embarrassment to many and risks reviving the outmoded stereotype that people with disability are unable to perform basic daily tasks without assistance when they have previously been able to be self-reliant when paying for their own goods.

This is an extremely sorry state of affairs, is occurring here and now in the 21st Century, and so demands an immediate solution.  DGI urges the retention or addition of the tactile keypad to all touchscreen payment devices as an interim measure that can, and must be, applied now.  There are no PCI, technical, financial, logistical or other objections that can be made for the implementation of this solution.  This solution does not constrain the use of touchscreen payment devices, that are currently on the market, as intended, or the implementation and pursuit of other workaround solutions.  The flaw here is not in the solution DGI has advanced, nor are we solely concerned about the single purpose of PIN entry.  The flaw is that in the rush to design multi-purpose, state-of-the art payment devices, the diversity of needs of the different users are not considered, not even for the most basic purpose of entering a PIN to process a payment, let alone for the other purposes bundled onto these so-called innovative devices.  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.

DGI has a focus on systemic change.  We hold that as a country founded on the values of egalitarianism, we cannot continue to permit that products are manufactured, imported and sold that completely disregard users with disability.   How is it, we ask, that, despite the fact that this year we mark 25 years of the Disability Discrimination Act, so many inaccessible products continue to circulate?  It is time that Accessibility be included under the mandate of the ACCC, be regulated under Australian Consumer Law, included in trade agreements, be subject to standardisation at all stages from design to retail, and be included as one of the social values and productivity drivers that govern public and private sector policy.

Digital Gap Initiative

4 January 2017

Blind double-amputee cricketer bats for touchscreen EFTPOS devices to have tactile keypads

In 2002 Martin Stewart, a then 39-year old blind advocate was on his way to work one ordinary day when he stepped into what he thought was an open carriage doorway of a train that had just pulled in to Richmond Station, in Melbourne, Victoria, and fell into the void between carriages and on to the tracks.  Despite the desperate attempts of an onlooker to flag down the driver, the train took off and dragged him 200 metres along the tracks. The train tore off his lower right leg, his right arm and the top of his left ear, fractured his cheekbone and ribs, and left him with painful friction burns down the front of his body.

That same year, 2002, the Australian Bankers’ Association (ABA) introduced Industry Standards on Accessibility of Electronic Banking, after blind and other disability advocates around Australia lobbied them to act to remove barriers to their Automated Teller Machines (ATMs), Electronic Funds Transfer at Point of Sale (EFTPOS) devices, Automated Telephone Banking, and Internet Banking (15 years on, the ABA is in the process of reviewing and updating these standards to ensure the ongoing accessibility of banking in a changing world).

Martin continued his advocacy work after his traumatic accident, and he now has a message for the ABA and the four big banks it represents:

“The new standards must include specs for tactile keypads for PIN (Personal Identification Number) entry to be fitted to all touch screen EFTPOS and ATMs and Self-Service kiosks.”

Although Martin lost his dominant right hand in the accident (causing him to no longer be able to read Braille), he makes the most of his remaining limbs and is an avid blind cricket player and a whiz at using his iPhone.  But new touchscreen EFTPOS devices such as the Commonwealth Bank’s Albert are preventing him from the basic ability of entering his PIN at checkout, something he was able to manage on tactile keypads.

Albert has been available to Australian merchants since March 2015 and the Commonwealth Bank is marketing it to retailers, cinemas, restaurants, event and festival organisers, in addition to other businesses and government services that use EFTPOS terminals.

The Commonwealth Bank retro-fitted an Accessibility Mode option onto its Albert touchscreen EFTPOS tablet, but it is gesture-based and  impractical for many people to use, including those who have low or no vision; limited hand dexterity; cognitive challenges; older people and those not au fait with touchscreen devices.

Kate Begley of Vision Australia states:

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.”

Martin explains:

“Even though I am able to use my iPhone in a private setting, it is nerve-wracking to be confronted by a touchscreen payment device in the usually busy and noisy environments in which these machines are found, often with impatient customers queuing behind and making exasperated comments and noises.  A physical button keypad which is permanently attached to the device is not a backward, out-of-touch request at all. This physical keypad will enable accessible, efficient and inclusive access.  In California it’s been law since 2005 that tactile number keypads be attached to all touchscreen POS (Point-of-Sale) devices, so it’s not as if by requesting these in Australia we are asking for anything new. So why should we put up with what blind citizens in other countries have not!  We have the absolute right to financially transact with our independence, privacy and security intact.  If Albert is left to spread without very major changes to its design, it will be the precursor to other such devices in many other environments, such as taxis and teller machines, creating further marginalisation for us.

The Digital Gap Initiative, a group advocating for legislation and standards on digital technology, questions how Albert could have been released by the Commonwealth Bank despite the ABA’s Industry Standards on Accessibility of Electronic Banking, and fully backs Martin’s call for the fitting of tactile keypads to payment systems.

Albert highlights the need for national, compliance-based standards on digital accessibility, but updating the voluntary ABA standards is a step in the right direction.

Martin is part of a group of several consumers who are blind or have other impairments and have lodged complaints to the Australian Human Rights Commission under the Disability Discrimination Act 1992.

Please sign Martin’s change.org petition

Keep pushing for tactile Keypads on Touch Screen POS devices

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:

  1. Raley’s Point of Sale Settlement Agreement
  2. Best Buy Tactile POS Settlement Agreement
  3. Trader Joe’s Point of Sale Agreement and Amendment
  4. CVS Accessible Web Site and Point of Sale Settlement Agreement
  5. Target Point of Sale Settlement Agreement
  6. Staples Point of Sale Press Release
  7. Dollar General Settlement Agreement
  8. Rite Aid Tactile POS Agreement
  9. 7-Eleven Point of Sale Agreement
  10. RadioShack POS and Web Agreement
  11. Safeway POS Agreement
  12. 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.

DGI 2015 Wrap-up and what’s ahead for 2016

How DGI was born

Gisele Mesnage founded the Digital Gap Initiative (DGI) on a stormy Sunday in Sydney on 7 December 2014.

Gisele recalls:

“At the time I was in the midst of a legal action pursuant to the Disability Discrimination Act (DDA) against supermarket giant Coles, over the accessibility of their website. It was at least the 12th DDA complaint I had lodged over web accessibility issues since 2001. My experience in conciliating these cases led me to believe that a more systemic approach – including legislative reforms – was needed to tackle digital accessibility issues in our digital age. So on Sunday 7 December 2014 I was bouncing ideas on this question over the phone with a friend, Leah Grolman. We were both drinking Rooibos tea and chatting between breaks in the wild thunderclaps that raged over Sydney. By the end of the storm, the Digital Gap Initiative had been born and named.”


Gisele then connected with people who shared the vision for the goals of DGI.  On 15 April 2015 an inaugural meeting of an informal DGI management committee was held over Skype.  It was decided that DGI would operate as a network.

Launch events in Melbourne, Sydney and Canberra

Melbourne – Global Accessibility Awareness Day

On 13 May 2015 the company AccessHQ hosted an event at its Melbourne offices to launch DGI.  Ted McCoskey, who had taken on the role of President of DGI, and Gisele Mesnage, founder of DGI, both spoke at this gathering.

Sydney – Global Accessibility Awareness Day (GAAD)

This was followed by a bigger launch event at the Sydney Hilton on 21 May 2015, Global Accessibility Awareness Day. The event was again sponsored by AccessHQ and attended by over 50 government and business representatives.  Ted and Gisele again addressed this gathering.  One of the guests at the event was Greens Senator Lee Rhiannon, who invited DGI to hold a launch event at Australian Parliament House in Canberra.

Parliament House, Canberra – World Usability Day (WUD)

The Canberra launch took place at Australian Parliament House on 12 November 2015 on World Usability Day (WUD).

The event was co-hosted by Senators Rachel Siewert and Lee Rhiannon (the Greens) and Senator Jo Lindgren (Liberal Party) and Senator Carol Brown (ALP).

The launch event, opened by DGI Founder, Gisele Mesnage (download Opening Speech document here) was attended by 60 people, including parliamentarians and other government representatives, as well as business and community leaders.

The highpoint of the event was Gisele’s opening speech (below), and a panel discussion hosted by Ted McCoskey. Panellists included Greg Barnett (AccessHQ), Roger Sniezek (Coles), Andrew Arch (Digital Transformation Office), Christos Petrou (IBM), Alex Varley (Media Access Australia), Johmar Gazo (NAB), Sarah Pulis (PWC) and James Newton (DGI).  The animated discussion explored the theme of inclusion and innovation.  The event received a special video message from Lainey Feingold of the Lainey Feingold Legal Office in the US.


We extend warm thanks to all those who donated to our chuffed.org appeal and made it possible for three DGI members to travel to Canberra to participate in the event.  We also wish to extend special thanks to Coles for paying for the catering at the event, to NAB for a $1,000 donation, and to all panellists and other supporters who assisted us with practical tasks.

Other 2015 Highlights

Our Focus for 2016

  • Accessible online shopping such as Coles
  • Continued campaigning on Touch Screen POS devices such as the “Albert”
  • Advocating for designated accreditation codes to be applied to ICT, web and other digital accessibility skills training under the Australian Skills Quality Authority (ASQA)
  • Accessibility and ICT public procurement
  • Advocating against PDF as a sole format for online downloadable documents
  • Networking
  • Opening up discussion on compliance-based standard on digital accessibility

Digital Gap Initiative Takes Call for Action on Digital Inclusion to Parliament

On 12 November 2015, Digital Gap Initiative will call on the government to kick-start serious discussion on what is being done to ensure access for up to 1 in 5 Australians currently locked out of the digital marketplace.

The DGI launch event at federal Parliament, hosted by cross-party representatives Senators Rachel Siewert, Jo Lindgren and Carol Brown, follows DGI launch events in Sydney and Melbourne, and coincides with World Usability Day. The Canberra event features a panel discussion with Coles, the Digital Transformation Office (tbc), IBM, NAB, PwC Australia, AccessHQ and Media Access Australia, chaired by DGI President, Ted McCoskey.

“The panel will focus on ‘Innovation’. How can Australia be innovative in this domain? What are business and government doing to ensure that when they innovate, they innovate for everybody?” Mr McCoskey explains.

Finish Reading: Digital Gap Initiative Takes Call for Action on Digital Inclusion to Parliament

Digital Gap Initiative heading to Parliament

We’re excited to announce that Digital Gap will be taking its message of inclusive design and a call for national compliance standards on Accessibility to Canberra on November 12 2015 at Parliament House at 10am. The event has been scheduled to coincide with the 10th anniversary of World Usability Day which seeks to use innovation to ensure that technology enhances the lives of people rather than placing additional barriers to everyday life.

Finish Reading: Digital Gap Initiative heading to Parliament

Commbank’s new EFTPOS “Albert”: Accessibility short-changed

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 is a new touch-screen tablet EFTPOS payment device developed and promoted by CBA in partnership with global hardware and software specialist Wincor Nixdorf and design firm 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 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.

Finish Reading: Commbank’s new EFTPOS “Albert”: Accessibility short-changed

Don’t Exclude Us from the Digital Era: Call for National Standards on Digital Accessibility

Don’t exclude us from the digital era: Call for National Standards on Digital Accessibility Gisele Mesnage, is known to many as the blind woman from Sydney who took on Coles Supermarket. The highly publicized landmark case challenged the supermarket giant over accessibility issues on their online shopping website. The Case settled amicably in February 2015 however, Gisele was motivated more than ever to continue in her quest in closing the digital gap that exists for as many as 20% of Australians affected by disability and for older people. The Digital Gap Initiative (http://www.digitalgap.org), founded by Gisele, is a non-profit network that has brought together like-minded individuals from varied backgrounds all around Australia. They share a wealth of personal first-hand experience, daily facing issues which affect them as normal people who contribute to society and wish to access life. This includes the readiness to spend money with retailers who often inadvertently place barriers in the way of these willing customers. Access to digital technology should be guaranteed by law. The Digital Gap Initiative project will focus on advocating for legal, policy and other systemic reforms, with the aim of reducing digital barriers experienced by people with disability and older people. The project will provide information to groups and individuals on how best to communicate with those whose services are currently inaccessible. At a higher level, the Digital Gap Initiative will seek to bring about systemic change by involving individuals, governments, companies and other stakeholders to work towards policies and compliance-based accessibility standards that are equitable and workable. Gisele: “Digitalisation offers unprecedented opportunities for universal access to education, employment, entertainment and much more, because it is far easier to adapt digital codes than the mortar and bricks of the built environment. And for people with disability, older people etc., it is far more convenient to access online services.” Ted McCoskey, an adaptive technology trainer and vision impaired web developer who is President of the digital Gap Initiative Network, echoes this sentiment and adds: “Leaving this to the better angels of conscience simply isn’t working. People would be shocked by how many companies, even huge ones who ought to know better, and government services too, either ignore or are ignorant of how to make this work. Access to digital technology should be guaranteed by law, in the same way as is access to premises” Integrating Human Quality in Accessibility. With the generous support of innovative quality integrator consultancy AccessHQ and a grant from My Choice Matters, the Digital Gap Initiative will be launched in Sydney on Thursday 21 May at a breakfast seminar to be hosted by AccessHQ. Greg Barnett, General Manager – Customer Experience Consulting at AccessHQ, where HQ stands for Human Quality, comments: “Despite an increased focus on accessibility in recent years, the rush of businesses coming online has created a situation where the rate of websites becoming accessible is being outpaced by the rate of new, inaccessible websites. Although the WCAG 2.0 guidelines are a powerful and sincere way to approach web accessibility, we are seeing gaps in the effectiveness of WCAG 2.0 to cover all accessibility requirements”. Global Accessibility Awareness Day The Launch has been timed to coincide with Global Accessibility Awareness Day (GAAD) 2015. GAAD encourages people around the world to talk, think and learn about digital accessibility in all forms. Gisele urges Australians to take the Global Accessibility Awareness Day challenge: “For just one hour on 21 May, do not use your mouse – use the keyboard instead. Or switch on a screen reader like VoiceOver or TalkBack on your mobile device” The Digital Gap Initiative Launch Time: 8.30 am – 9.30 am Location: Hilton Sydney Hotel, 488 George Street Sydney Key Speakers: Greg Barnett (AccessHQ); Ted McCosky and Gisele Mesnage (Digital Gap Initiative) Contact Gisele Mesnage (Founder/Coordinator Digital Gap Initiative Network) Phone: 02 9799 5388 (please use this landline # as main contact or to leave a message) Mob: 0428 260 600 Email: Gisele@digitalgap.org Ted McCoskey (President, Digital Gap Initiative Network) Mob: 0404 878 957 Email: ted@digitalgap.org Greg Barnett (General Manager – Customer Insights Practice AccessHQ) Mob: 0430 453 304 Email: greg.barnett@accesshq.com Digital Gap Initiative: http://www.digitalgap.org/ Gisele Mesnage Founder and Coordinator Digital Gap Initiative web: http://www.digitalgap.org/ email: gisele@digitalgap.org Phone: 02-9799 5388 mob: 0428 260 600 (please use landline number as first contact or to leave messages)

Launch of Digital Gap Initiative

Don’t exclude us from the digital era: Call for National Standards on Digital Accessibility

Gisele Mesnage is known to many as the blind woman from Sydney who took on Coles Supermarket. The highly publicised, landmark case challenged the supermarket giant over accessibility issues on their online shopping website.

The Case settled amicably in February 2015 however, Gisele was motivated more than ever to continue in her quest in closing the digital gap that exists for as many as 20% of Australians affected by disability and for older people.

Finish Reading: Launch of Digital Gap Initiative

About the Digital Gap Initiative

About Digital technology is now so integral to our everyday life; it can be compared in scope to the built environment. The plus is that digitalisation offers unprecedented prospects for universal access and real social inclusion, due to being more adaptable than the bricks and mortar of the built environment. Yet the reality is that a social gap, an e-gap, exists between those able to participate in this rapid transformation of our society and those who, through circumstances rather than choice, are being left behind. The Digital Gap Initiative, or e-gap project, will aim to contribute to efforts in Australia and internationally to promote inclusive digital accessibility. The Initiative’s focus will be centred on advocating for legal, policy and other systemic reforms, with the objective to reduce the barriers that people with disability, older persons, socially disadvantage or technically-challenged people face in using digital technology – online services, mobile apps, touch screen devices, ATMs and other automated services, digital TVs and radios, cloud technology and intranet systems in work places and educational establishments, many of which are inaccessible because they have not been designed with accessibility and inclusion in mind. Goals The Initiative will motivate discussion on, and advocate for, the adoption of national, compliance-based digital accessibility standards to be adopted in Australia. These standards would complement the Disability (Access to Premises – Buildings) Standards 2010 (Cth), administered by the Attorney-General’s Department, which codifies requirements for ramps and other accessible features in the built environment. At present, enforcement of digital accessibility is via a complaints process to either the Australian Human Rights Commission or an anti-discrimination body at the State or Territory level. With no uniform minimum standard of digital accessibility guaranteed under Australian law, equality remains a distant promise. The Initiative will aim to connect with stakeholders and experts across disciplines and sectors, towards exploring and developing these model standards and implementation strategies, which would: · go beyond the Web Content Accessibility Guidelines (WCAG) 2.0, and include criteria for qualitative usability, responsiveness and performance of web design and online services; · cover the broad spectrum of digital systems and services that have become central to our lives; · shift away from piecemeal change through disputes and litigation, instead effecting systemic change; · avoid ambiguity about legal requirements; · include review mechanisms to reduce lag between technological progress and the law; · include training certification and other occupational accreditation standards for those working or teaching in the digital industry to ensure quality of professional services; · apply to government and the non-government sectors; · set proportionate requirements or exemptions as appropriate for individuals, the community sector, small businesses and so on; · Address the question of digital security measures where these impact inclusive access; · Enhance flow-on benefits to the wider community and business; and, · Include other ideas, as generated through the conversation process in working towards this goal. Recognising that no one pathway can bring about change overnight, the Initiative will also pursue a broader strategy which will include: · where feasible, influence public and private sector policies and programs that will generate digital inclusion and minimise the impact of accessibility barriers on educational and employment opportunities, independence and social interactions in Australia; · Connect with international efforts, including lobbying the United Nations to declare an International Year focusing on closing the digital gap globally. The Initiative will operate on the basis of building a network of people committed to these ideals, through the website, social media, conversations and consultations, and other collaborations. Gisele Mesnage Digital Gap Initiative