AUSTRALIAN BANKERS’ ASSOCIATION
|
David Bell Chief Executive Officer |
Level 3, 56 Pitt Street Sydney NSW 2000 Telephone: (02) 8298 0401 Facsimile: (02) 8298 0447 |
Australian Bankers’ Association Industry
Standard
The attached
Industry Standard is today released for adoption by members of the ABA and
other financial institutions.
The Standard has been developed for improvement of accessibility of electronic banking services. The Australian Bankers’ Association and its members are working together with the community to improve accessibility and are contributing to efforts to narrow the digital divide.
Under the leadership of the ABA, representatives from the banks, other financial institutions, community groups and retailers have developed Industry Standards for:
· Electronic Funds Transfer at the Point of Sale (EFTPOS);
· Automated Telephone Banking;
· Internet Banking;
· Automatic Teller Machines (ATMs).
Our industry is committed to developing industry-wide best practice standards and protocols for voluntary adoption by the banks. Banks can use these standards to develop their own action plans.
The ABA is lodging a new Disability Action Plan with the Human Rights and Equal Opportunity Commission, with objectives essentially concerned with supporting and reviewing the implementation of the Industry Standards. Review and revision processes, and monitoring and reporting issues are also addressed in the Plan.
All Industry Standards can be found at:
· ABA website: www.bankers.asn.au
· HREOC website: www.hreoc.gov.au
Copies of the Standards are also available from the ABA, including alternate formats eg braille and large print. Telephone ABA on (02) 8298 0417.
Any comments on the Standards should be sent to reception@bankers.asn.au or posted to Australian Bankers’ Association, Level 3, 56 Pitt St, Sydney 2000.
Yours sincerely
______________________________
David Bell
AUSTRALIAN BANKERS’ ASSOCIATION
|
|
Level 3, 56 Pitt Street Sydney NSW 2000 Telephone: (02) 8298 0401 Facsimile: (02) 8298 0447 |
Industry Standard
The Australian Banking Industry lodged an Industry Action Plan with the Human Rights and Equal Opportunity Commission (HREOC) on 30 April 2001. The stated aim of the plan was to contribute to the process of eliminating the ‘Digital Divide’ by implementing the recommendations in the HREOC report, “Accessibility of Electronic Commerce and New Service and Information Technologies for Older Australians and People with a Disability”, principally through the development of industry best practice standards and guidelines.
This document addresses Automated Telephone Banking technologies and provides a set of standards for their design, deployment and operation.
This Standard has been developed by a Working Group comprising financial services industry and community representatives, and has been subject to an extensive community consultation process.
The Standard was funded and developed under the sponsorship of the Australian Bankers’ Association (ABA). The ABA appreciates and acknowledges the input and assistance provided by the Human Rights and Equal Opportunity Commission (HREOC), financial institutions, Working Group members and organisations of and for older Australians and people with disabilities.
The work conducted by other standards bodies including Standards Australia, the Human Factors and Ergonomics Society (HFES), Ameritech, US Access Board and ACIF, has assisted formulation of the content of this document.
In formulating these guidelines, the Automated Telephone Banking Working Group has sought to incorporate the best information and guidance from available sources, as well as new research.
This document can be read as a supplement to AS/NZS 4263: 1997/Amdt 1 - Interactive voice response systems—User interface—Dual tone multi frequency (DTMF) signalling.
Note: Issues related to matters covered in this document are being examined by Standards Australia’s IT/22 Committee. That activity may result in an update to AS/NZS 4263.
1. "I Just Called to say." Accessible Text Telephones for people in Australia who are Deaf-Blind. (1997) National Federation of Blind Citizens of Australia http://www.bca.org.au/ttyrep.htm
2. “Meeting the Needs of Older Adults in Speech Application Design”, Daryle Gardner-Bonneau, Principal, Bonneau and Associates
3. “Telephones
for All”, Nordic Committee on Disability, Nordic design guidelines
4. “The Telecommunications Charter”, COST 219 bis, National Research and Development Centre for Welfare and Health (STAKES), European Union, http://www.stakes.fi/cost219/charter.htm.
5. Accessible E-Commerce in Australia: A discussion paper about the effects of
electronic commerce developments on people with disabilities. (1999), Blind
Citizens Australia http://www.bca.org.au/ecrep.htm
6. AS/ACIF
S002:2001 Analogue interworking and non-interference requirements for Customer
Equipment for connection to the Public Switched Telephone Network
7. AS/ACIF S040:1999 Australian Standard - Requirements for general use Customer Equipment for use with the Standard Telephone Service – Features for special needs of persons with disabilities
8. AS/NZS 4263: 1997/Amdt 1 - Interactive voice response systems—User interface—Dual tone multi frequency (DTMF) signalling
9. AS/NZS 4277/Amdt 1 - Text telecommunications - User interface requirements – For
deaf people and people with hearing and speech disabilities
10. Designing User Friendly Interactive Voice
Response (IVR) Telephone Services for all. (1998) SoftSpeak Computer Services http://www.softspeak.com.au/ivrpap98.htm
11. HFES 200.5 Software User Interfaces – Interactive Voice Response (IVR) and Telephony Human Factors and Ergonomics Society
12. Public Law 508 rules for telecommunication equipment, US Access Board
This document is based in part on the local and international research on best practice in the design, deployment and operation of Automated Telephone Banking solutions which was available as at the time of publication. Future versions of the document will endeavour to incorporate the latest research.
As material in this document was both developed by the Working Group and drawn from a number of other sources, it must not be cited or reproduced in any form or by any means without permission from the ABA. It may however be referred to in tenders, requests for expressions of interest and requests for proposals without permission, where interested organisations are seeking to adopt its requirements.
There are many liability and other legal issues relating to matters covered in this Standard, the resolution of which falls outside the scope of the document. These include:
· Conditions of use (eg, proxy relationships, determinations of breaches)
· PIN entry (eg, inability to enter PIN, PIN replacing signature)
· PIN disclosure
· Disclosure of user IDs and passwords
· Strategies for avoidance of fraud
· Compliance with Commonwealth Electronic Transactions Act
· Compliance with the Commonwealth Privacy Act 1988 (which incorporates the amendments made to it by the Privacy Amendment (Private Sector) Act 2000).
Although the intended primary application of this Standard is stated in its Scope (see below, Section 9), it is important to note
that it remains the responsibility
of the users of the Standard to judge its suitability for their particular
purposes.
The Standard ought not be relied upon as a substitute for professional advice in complying with the law, and should be implemented only after relevant professional advice has been obtained.
The Australian Bankers’ Association, the Human Rights and Equal Opportunity Commission, and all other parties associated with the publication of this document, have made every effort to ensure the accuracy of information, but accept no responsibility for any loss or damage occasioned by any party in its seeking to implement any provision of the Standard.
The Commonwealth Disability Discrimination Act 1992 (DDA) makes it unlawful to discriminate against a person on the grounds of a disability. The objects of the DDA include eliminating, as far as possible, discrimination against people with disabilities and promoting recognition and acceptance within the community that people with disabilities have the same fundamental rights as the rest of the community.
The DDA uses a broad definition of “disability” that includes:
The law is administered by the Human Rights and Equal Opportunity Commission (HREOC) and sets out specific areas in which it is unlawful to discriminate. These areas include accommodation, employment, access to premises, and the provision of goods, services and facilities. The definition of ‘services’ in the DDA includes financial and information services provided, for example, through websites, telephones, ATMs and EFTPOS sites. An organisation that provides such services is liable for complaint if those services are not accessible to people with disabilities.
The DDA recognises, however, that in certain circumstances, providing equitable access for people with disabilities could cause ‘unjustifiable hardship’ for an individual or organisation providing goods or services.
Where a person with a disability believes they have been
discriminated against they can complain to the Commission who will investigate
the complaint and, where appropriate, attempt to conciliate a solution between
the two parties. Where conciliation is not possible the complainant may take
their complaint to the Federal Court or Federal
Magistrates Service who have the authority to determine whether unlawful
discrimination has occurred and what constitutes
‘unjustifiable hardship’.
The Commission also has a role in assisting organisations understand their responsibilities and supporting initiatives aimed at promoting compliance through best practice. While these Industry Standards have no force in law the Commission has supported their development in the hope that they will provide a level of access consistent with the requirements of the DDA.
This document is an Industry Standard: a set of standards and guidelines for the design, deployment and use of Automated Telephone Banking services in the financial services industry. The adoption of Industry Standards is voluntary.
This Standard does not have the force of law, and adopting the Standard does not guarantee fulfilment of legal responsibilities under the DDA, nor does it remove from any institution their obligation to comply with the requirements of that Act or any other relevant legislation.
The Standard has been developed in consultation with interested parties, including the Human Rights and Equal Opportunity Commission (HREOC), with the objective of describing best practice in accessibility consistent with the DDA. An organisation choosing to adopt the Standard may therefore have some confidence that they are implementing requirements which have evolved from community consultation with interested parties, and that adoption of the Standard will carry some weight as a defence against a complaint lodged under the DDA.
It is expected that banks and other financial institutions deciding to adopt this Standard will develop and lodge with HREOC Disability Action Plans which rely in large part on this and other Industry Standards.
A financial institution may also seek protection from complaint under the DDA during implementation of the Industry Standard by lodging a temporary exemption application with HREOC on the basis of its commitment.
Where a financial institution commits to implementing the Industry Standard through an action plan, any individual or group may monitor implementation. Any individual or group covered by the DDA retains the right to lodge complaints with HREOC for perceived breaches of the DDA.
Institutions should also refer to any relevant Australian and Australia/New Zealand Standards.
For the purpose of this
Industry Standard, the following definitions apply:
Automated telephone banking services - financial services
available to the customer via the telephone that can be used by the customer
without having to converse with an employee of the financial institution. The
customer may use the telephone to make various transactions with the financial
institution such as checking an account balance, transferring money from one
account to another, obtaining transaction history and paying bills.
Caller - a caller to the system (often termed a 'user'
in computing contexts). Note that some
IVR systems may call the user, rather than the user calling the system.
Command - a DTMF input from a user that controls an
IVR system. Examples of commands are Help, Stop, Skip, Back-up, Exit and
Connect to Operator. A command is not a response to a menu of choices or to a
data input request. A command is usually a single key-press.
Data input - a sequence
of DTMF tones input by a user to convey information such as numbers, values,
times and names. Data input may be of variable or fixed length.
Disability – the use of this term in the Standard relies on the DDA definition which, as noted above includes:
·
The presence in the body of disease-causing organisms.
Dual tone multi
frequency (DTMF) signalling - a system for transmitting address and other
information from terminal equipment by superimposing a succession of voice
frequency signals on the established DC current in a PSTN line. Each signal
comprises two simultaneously transmitted tones of different frequencies. Up to
16 different signals may be transmitted by standard DTMF signalling (in
Australia, see ACIF S002: 2001). Most
telephones are limited to 12 keys and hence 12 signals. The 12 keys are 0, 1,
2, 3, 4, 5, 6, 7, 8, 9, * and #. The four additional keys (not normally
provided on a telephone) are referred to as A, B, C and D.
Feedback - information supplied by the system to
indicate that user actions have had their intended effects. Typically, feedback
consists of a prompt indicating that an action has had its intended effect, but
feedback also includes error indications and tones.
HREOC - Human Rights and
Equal Opportunity Commission - The Australian Human Rights and Equal
Opportunity Commission administers federal legislation in the area of human
rights, anti-discrimination, social justice and privacy. This includes
complaint handling, public inquiries, policy development and education and
training.
Informative - the term
`informative' has been used in this Industry Standard to define the application
of the appendix to which it applies. An `informative' appendix is only for
information and guidance.
Interactive voice
response (IVR) system or service - an automated telephone-based system or
service that allows users to enter information and make menu selections using
DTMF devices, and to receive audible information. Examples include Automated Telephone Banking and bill pay (Bpay)
services. IVR system output is presented as audible signals or voice (whether
live, recorded, digitised or synthesised) carried over an interactive
telecommunications medium (whether public or private or a combination of both,
or whether wired or wireless) including the PSTN or ISDN.
IVR deployer – an
organisation that develops and/or operates IVR services, for example, a
financial institution.
Interrupt capability -
the ability to interrupt system output with valid input.
May – indicates the relative importance of a requirement. “Mays” follow “shoulds” in importance in this Standard, and carry a priority rating of “3” in the specification checklist in Section 12 in this document.
Menu - the presentation
to the user of a list of possible actions. A menu typically comprises a set of
prompts each describing an available function and the user action necessary to
invoke that function.
National Relay Service
(NRS) - in Australia, the National Relay Service is contracted to provide
access to the telephone network between people who have a hearing impairment or
speech impairment or are Deaf, and the wider community. The NRS can be accessed
by a teletypewriter (TTY), computer and modem or standard telephone. A Relay
Officer (RO) is involved to facilitate all calls. Relay Officers are bound by
Commonwealth laws to keep all calls confidential. For more information about
the National Relay Service, refer to http://www.aceinfo.net.au/Support/FAQ/faqnrs.html
Operator – a human who
is available to assists a caller of an IVR service. An operator service may not necessarily be available 24 hours a
day, or 7 days a week.
People of non-English
speaking background (NESB) – Anyone for whom English is not their first spoken
or written language. People of a
non-English speaking background often benefit from plain English writing, and
may prefer spoken English to written English.
Plain English – language
that is written as clearly and simply as is appropriate for the content. Clear
and simple writing will aid all users, especially those with cognitive,
learning, and/or reading disabilities. This should not discourage the writer
from expressing complex or technical ideas. Using clear and simple English also
benefits people whose first language is not English, including those people who
communicate primarily in sign language.
Prompt - an audible
system output that instructs or guides the user. A prompt may consist of
recorded voice, synthesised speech, tones or any combination of these.
Public switched
telephone network (PSTN) - that part of the public telecommunications network
which enables any customer to call and communicate with any other customer
either automatically or with operator assistance. The PSTN has a nominal transmission
bandwidth of 3 kHz (in Australia, see ACIF S002: 2001).
Relay Officer (RO) - A
Relay Officer is a person who is involved to facilitate calls between two
parties. Relay Officers are bound by
Commonwealth laws to keep all calls confidential. Also see National Relay
Service.
Shall – indicates the relative importance of a requirement. “Shalls” are of the highest importance in this Standard, and carry a priority rating of “1” in the specification checklist in Section 12 in this document.
Should – indicates the relative importance of a
requirement. “Shoulds” follow “shalls”
in importance in this Standard, and carry a priority rating of “2” in the
specification checklist in Section 12 in this document.
System - an interactive
voice response (IVR) system.
Telephone Relay Service
- a telecommunications service that enables text telephone users and voice
telephone users to interact by providing translation between the two modes of
communication. This translation is normally
provided by a human operator. See National Relay Service.
Timeout - an interval of
time where there is no user input, which causes the system to change state; or,
the state change resulting from such an interval. For example a timeout may result in information being repeated or
more details being offered to the user, or the call being transferred to an
operator.
Text Telephone - the
generic term commonly used to describe a device used to perform text telephony
whether through Baudot, DTMF, ASCII or other methods used in various countries
throughout the world. Such devices are
usually used by at least one party who has a hearing impairment. It could be a stand-alone unit or as an
addition to a voice telephone or as an application in a multi-function computer
based terminal.
TTY: one name that Australian and North American (Baudot-based) text telephones are commonly known by. The deaf community in Australia has adopted the term "TTY" as a common usage name for text telephones. TTY text telephones use the Baudot system to communicate across the telephone network.
User - a person who
accesses the automated system.
User ID – the number
which identifies the user and their accounts to the system.
User Interface - the term used to describe the methods by which people and technology interact. User interface includes the output and input formats that programs generate and recognise. Depending on the user interface design of equipment, devices and software can be easy, difficult or even impossible for various groups of people with disabilities to access.
This Industry Standard is intended for use by manufacturers, suppliers and designers of Automated Telephone Banking services, and by financial institutions providing Automated Telephone Banking services using interactive voice response (IVR) technology.
The Standard relates
only to automated telephone services and does not extend to direct
communication between a customer and an employee of a financial institution,
other than by specifying requirements which enable a user to gain access to a
human operator from within the IVR system.
Whereas AS/NZS 4263 is confined to generic user interface guidelines for automated telephone services, this document primarily deals with telephone applications relating to financial transactions.
As this Industry Standard is supplemental to AS/NZS 4263, it does not duplicate information appearing in that document.
The primary focus for this document is on IVR systems, not Automatic Call Distributor (ACD) systems or Auto Attendant ‘front ends’.
This Industry Standard
specifies requirements, guidelines, recommendations and suggestions for
Automated Telephone Banking services to make them more accessible to people
with disabilities and for older Australians.
This Standard also covers application, processing and service content issues where they relate to Automated Telephone Banking, and includes provision for direct TTY access to IVR systems.
Nothing in this document is intended to prevent the use of designs or technologies as alternatives to those prescribed below provided they result in substantially equivalent or greater access to and use of a product for older Australians and people with disabilities.
The service must be able to be operated by those with a speech impairment, or those who are unable to talk, or it must provide access to a service with equivalent functionality, able to be operated, for example, by use of DTMF signalling.
Other than in most cases requiring equipment which supports DTMF signalling, features of the customer’s telephone including keypad layout and handset design are outside the scope of this Standard.
There are instances in this document where a requirement is expressed as a performance objective rather than as an exact technical specification. In many cases this is because it is the most appropriate way to express the requirement. In the remainder, it is because no suitable published or de facto standard has been identified nor has any credible research been uncovered which would support the determination of a specification. In these instances, the ABA will wait for a suitable standard to emerge or adequate research to become available before adding a specification to this document.
As a first
principle, older Australians and people with disabilities should not be
financially disadvantaged by needing additional functionality.
The ABA supports and recommends the principles as set out in the COST 219
Group’s Telecommunications Charter, a copy of which is included at Appendix A3.
The wording of requirements as “shall”, “should” or “may” clauses indicates the relative importance of each requirement.
During design, and prior to implementation, it is strongly recommended that users with a range of capabilities and limitations be engaged to trial the automated solution and provide feedback.
There are significant benefits to consulting with users from the beginning of the project (for example through focus groups at the initial planning stages) and at key stages within the project. Feedback from users can then be incorporated into the business/user requirements that create a framework for the development of technical and design specifications. This helps minimise accessibility problems after implementation.
It is also important that accessibility considerations are understood prior to testing for wider usability. Decisions concerning accessibility are unlikely to adversely affect overall usability (in fact they often enhance usability for all customers). However, if changes are made for accessibility then the revised design will need to be tested again for general acceptance.
All IVR deployers shall comply with AS/NZS 4263: 1997/Amdt 1, or the most current version of that standard. This ABA Industry Standard document provides specific guidelines for financial transactions that are beyond the scope of AS/NZS 4263.
All users of IVR systems will benefit from consistent use of terminology, both across channels within a single institution, and across channels within the financial services industry. Examples where consistency is important include:
· Access number and card number
· Password and passcode
· Receipt and transaction number
· The order of steps for a funds transfer
· The order of steps for a Bpay payment
Experience has shown
that consistent and predictable human interfaces benefit users. The benefits
can include faster learning, greater productivity, fewer errors and greater
satisfaction.
Consistent interfaces
also benefit the industry by promoting greater acceptance of products and
services. Standardisation of Automated Telephone Banking systems is
particularly important because callers do not have the opportunity to read
instructions each time they access a different automated telephone banking
service.
Terminology use should
be consistent throughout an application and among applications that are
integrated with each other within a system.
Example: If an Automated Telephone Banking service and an Internet Banking service are in use in a financial institution, it is important that terms be used consistently throughout the two applications, and for all other channels (such as correspondence and customer communication) associated with the services.
Subject to
identification and security requirements, the user should be able to register
for an IVR service using the telephone or TTY without completing printed forms.
The IVR
deployer should, subject to identification and security requirements, accept
the registration of a customer to an IVR service when the registration request
is received either directly via a telephone or TTY, or indirectly through a
telephone relay service. For this to
occur, a process needs to be in place for disclosure of confidential
information such as security code to a relay operator, as an exception to
standard business rules.
User IDs more than 8 digits in length are too hard for most people to remember. This is a particular issue when a person is unable to read the number on their card. IVR deployers should work towards shorter identification and validation processes.
When a user is issued with a user ID, the ID should remain unchanged, unless it has to be changed for security reasons.
Within a given call,
unless information re-entry is required for reasons of privacy, security, or
verification, the user should not be required to enter any given piece of
information more than once.
The number of key presses required of the user should be minimised.
Users who are having difficulty in navigating or comprehending the automated service shall, during the hours operators are normally available, be given the option to speak with an operator in order to carry out their transactions. This may be satisfied by existing business rules for timeouts and errors.
This option should be offered at the earliest possible point in the session. If the institution has more than one access number for Automated Telephone Banking, the operator service need be provided on only one of those numbers.
Customers who are compelled to use an operator because the functionality of the automated service does not meet their accessibility needs, shall not be financially penalised in those instances where use of an operator is required.
The IVR deployer may choose to identify by appropriate means those customers who have a need to speak to an operator, or who require access to other options.
In those cases where the user is passed to an operator, the system should transfer to the operator customer information obtained by the IVR, so as to minimise the need for re-entry of information.
When technically
feasible, a user should be provided with the opportunity to cancel transactions
and/or change data and information that has been entered during a call.
Example: A user who has initiated a funds transfer
may change their mind and wish to cancel the transfer. After the caller has finished entering
transaction details, the system may repeat the details and ask the user if they
would like to proceed with the transfer, or make any changes to it.
Where an IVR system requires speech input, provision shall be made for callers who do not speak within a certain period by either allowing for DTMF input or transfer to a human operator.
Menus, commands and prompts should be designed to minimise confusion or complex choice making by the caller.
Voice output may be implemented using either recordings of a human voice or through use of synthetic speech (text to speech technology). In most cases the former will be understood more effectively by infrequent users.
If the service takes advantage of visual displays on customer equipment, there shall also be a means available to access all information via the audio channel.
Where appropriate to the context, scripts for audio should adhere to the following guidelines:
(a) Sentences should be short and simple in structure, and only the simplest vocabulary used. Care however should be taken to avoid patronising messages;
(b) Informative messages which advise the user of the progress of the transaction and inform the user when or how to perform a step in the transaction should be clear and to the point;
(c) Audible prompts, messages and instructions require excellent audio quality. They should be without distortion or interference, moderately paced, and be played at optimal volume and clarity;
(d) Similar sounding numbers, such as five and nine, need to be enunciated precisely. Female modulation is often received more easily by people who use hearing aids and tends to be perceived as more friendly. However, all audio output should be within the lower frequency ranges of human hearing, for example, through use of medium or lower pitched voices.
Many users have requested that an extended transaction history be available to them via the telephone.
A transaction history or statement review facility should be
provided. It is recommended that the
history contain at least the last month’s transactions, or the last 20
transactions, whichever is the lesser, irrespective of whether or not a printed
statement has been issued.
IVR deployers shall provide users with an option to repeat menus, commands and prompts.
IVR deployers should also consider providing users with an option to alter the speed of delivery of IVR system prompts. Many users would benefit from such an option.
While a faster delivery speed may suit experienced and expert users, it can be overwhelming for new users, older people, and those with other disabilities.
Although printed information such as quick reference cards and instructions may be provided, the IVR system shall be designed in such a way that it can be operated without reference to such information.
All text-based information shall be in plain English, and available in accessible formats.
Deployment of IVR solutions should include implementation of a suitable level of online context-sensitive help.
IVR deployers shall make available descriptions of transaction steps for Automated Telephone Banking services on request. This would be particularly helpful for customers using TTY facilities. These descriptions would be summaries of transaction flows.
Note: This information would also be made available to a telephone relay service on request.
If alphabetic entry is enabled by the service, through use of the customer’s keypad, then such alphabetic entry shall comply with the ‘repeat key method’ as described in Appendix B of AS/NZS 4263, which specification may be updated in a new version of AS/NZS 4263, expected to be released in 2002.
IVRs can be built which can be accessed directly from a TTY terminal where both the user input and the IVR output is directly communicated using BAUDOT (the TTY communication character set and protocol). There are however some challenges, for example absence of star and hash characters on the TTY keyboard (which might make alternative scripting and reference materials necessary), as well as the complexity and expense of developing a parallel service for a relatively small numbers of users.
IVR deployers shall ensure that their IVR systems are usable by TTY users directly with their TTYs or through telephone relay officers.
IVR deployers shall provide the option of repeating the IVR prompts for calls made via a telephone relay service to allow time for:
(a) The relay officer to type all the prompts to the customer;
(b) The customer to consider the prompts and type his/her instruction to the relay officer;
(c) The relay officer to make the appropriate selection from the menu.
IVR deployers should also consider providing a function for pausing the IVR prompts for calls made via a telephone relay service.
If it is not practical for a user with a TTY to directly interact with the IVR system, then an equivalent communication channel shall be made available to the TTY caller to provide the same functionality at no additional charge.
IVR deployers may wish to consider the use of SMS applications to supplement output from automated telephone services.
The table of timeout values in AS/NZS 4263 contains a range of values for different timeouts. If timeout values are too short, then insufficient time is available to many callers to make decisions and perform tasks, leading to confusion, anxiety, frustration, increased error rates and unsuccessful call completion. This is particularly so for some people with cognitive and/or psychiatric disabilities.
All IVR deployers should carefully review the timeout values in their IVR systems and where appropriate, extend these values in order to increase the proportion of people able to use their systems.
IVR deployers should consider extending the length of time for valid inputs in menus for a user’s second chance (after an error or timeout has been triggered).
User testing should include users from a range of ages and cognitive abilities, as well as those using telephone relay services.
Users should be provided with the opportunity to recover from their most recent error, without being required to re-enter correct information.
Words such as
"wrong", "illegal", “fatal” and “critical” should be
avoided in error messages for users.
Note: Deployers should also refer to AS/NZS 4263
for error recovery procedures.
Notes
1. The first column in the table below, “Requirements”, reproduces the headings (level H2, H3 and H4) in Section 11 above.
2. The second column, “Specifications”, reproduces the specifications stated in the text of Section 11.
3. Column 3, “Application”, indicates whether the requirement/specification applies to all equipment, services or installations (A) or only to new or substantially upgraded equipment, services or installations (N)
4. Column 4, “Priority Level”, gives the implementation priority of the requirement/specification, as expressed in the Requirements section above. Level 1 corresponds to “shall”, Level 2 corresponds to “should”, and Level 3 corresponds to “may”.
5. Column 5, “Achieved” is left blank to allow the user of the Standard to insert Y(yes), N(no) or NA(not applicable).
|
Requirements |
Specifications |
Application (A,N) |
Priority Level (1,2,3) |
Achieved (Y,N,NA) |
|
11.1 Compliance
with AS/NZS 4263 |
1. All IVR deployers shall comply with AS/NZS 4263: 1997/Amdt 1, or the most current version of that standard. |
A |
1 |
|
|
11.2 Consistency |
1. Consistent use of terminology, both across channels within a single institution, and across channels within the industry. Examples where consistency is important include: · Access number and card number · Password and passcode · Receipt and transaction number · The order of steps for a funds transfer · The order of steps for a Bpay payment |
A |
3 |
|
|
|
2. Terminology use should be consistent
throughout an application and among applications that are integrated with
each other within a system. |
A |
2 |
|
|
11.3 Registration |
1. Subject to identification and security requirements, the user should be able to register for an IVR service using the telephone or TTY without completing printed forms. |
A |
2 |
|
|
|
2. The IVR deployer should, subject to identification and security requirements, accept the registration of a customer to an IVR service when the registration request is received either directly via a telephone or TTY, or indirectly through a telephone relay service. |
A |
2 |
|
|
11.4 Input and Navigation 11.4.1 Shorter and
Sustainable IDs |
1. IVR deployers should work towards shorter identification and validation processes. |
N |
2 |
|
|
|
2. When a user is issued with a user ID, the ID should remain unchanged, unless it has to be changed for security reasons. |
N |
2 |
|
|
11.4.2 Non-duplication of information input |
1. Within a given call, unless information re-entry is required for reasons of privacy, security, or verification, the user should not be required to enter any given piece of information more than once. |
A |
2 |
|
|
11.4.3 Minimisation of user key presses |
1. The number of key presses required of the user should be minimised. |
A |
2 |
|
|
11.4.4 Access to Operator |
1. Users who are having difficulty in navigating or comprehending the automated service shall, during the hours operators are normally available, be given the option to speak with an operator in order to carry out their transactions. This may be satisfied by existing business rules for timeouts and errors. |
A |
1 |
|
|
|
2. This option should be offered at the earliest possible point in the session. If the institution has more than one access number for Automated Telephone Banking, the operator service need be provided on only one of those numbers. |
A |
2 |
|
|
|
3. Customers who are compelled to use an operator because the functionality of the automated service does not meet their accessibility needs, shall not be financially penalised in those instances where use of an operator is required. |
A |
1 |
|
|
|
4. The IVR deployer may choose to identify by appropriate means those customers who have a need to speak to an operator, or who require access to other options. |
N |
3 |
|
|
|
5. In those cases where the user is passed to an operator, the system should transfer to the operator customer information obtained by the IVR, so as to minimise the need for re-entry of information. |
A |
2 |
|
|
11.4.5 Changing information that has been entered |
1. When technically feasible, a user should
be provided with the opportunity to cancel transactions and/or change data
and information that has been entered during a call. |
A |
2 |
|
|
11.4.6 No Speech
Input |
1. Where an IVR service requires speech input, provision shall be made for callers who do not speak within a certain period by either allowing for DTMF input or transfer to a human operator. |
N |
1 |
|
|
|
2. Menus, commands and prompts should be designed to minimise confusion or complex choice making by the caller. |
N |
2 |
|
|
11.5 Output |
1. If the service takes advantage of visual displays on customer equipment, there shall also be a means available to access all information via the audio channel. |
N |
1 |
|
|
11.5.1 Scripts and
Wordings |
1. Where appropriate to the context, scripts for audio should adhere to the guidelines which appear above (at section 11.5.1). |
N |
2 |
|
|
11.5.2 Transaction
Information |
1. A transaction history or statement review facility should be provided. |
N |
2 |
|
|
|
2. It is recommended that the history contain at least the last month’s transactions, or the last 20 transactions, whichever is the lesser, irrespective of whether or not a printed statement has been issued. |
N |
2 |
|
|
11.5.3 Speed of
Delivery |
1. IVR deployers shall provide users with an option to repeat menus, commands and prompts. |
N |
1 |
|
|
|
2. IVR deployers should also consider providing users with an option to alter the speed of delivery of IVR system prompts. |
N |
2 |
|
|
11.6 Documentation |
1. Although printed information such as quick reference cards and instructions may be provided to the user, the system shall be designed in such a way that it can be independently operated without reference to such information. |
A |
1 |
|
|
|
2. All text-based information shall be in plain English, and available in accessible formats. |
A |
1 |
|
|
|
3. Deployment of IVR solutions should include implementation of a suitable level of online context-sensitive help. |
N |
2 |
|
|
|
4. IVR deployers shall make available descriptions of transaction steps for Automated Telephone Banking services on request. |
N |
1 |
|
|
|
5. If alphabetic entry is enabled by the service, through use of the customer’s keypad, then such alphabetic entry shall comply with the ‘repeat key method’ as described in Appendix B of AS/NZS 4263, which specification may be updated in a new version of AS/NZS 4263, expected to be released in 2002. |
A |
1 |
|
|
11.7 TTY Communication |
1. IVR deployers shall ensure that their IVR systems are usable by TTY users directly with their TTYs or through telephone relay officers. |
A |
1 |
|
|
|
2. IVR deployers shall provide the option of repeating the IVR prompts for calls made via a telephone relay service to allow time for: (a) The relay officer to type all the prompts to the customer; (b) The customer to consider the prompts and type his/her instruction to the relay officer; (c) The relay officer to make the appropriate selection from the menu. |
N |
1 |
|
|
|
3. IVR deployers should also consider providing a function for pausing the IVR prompts for calls made via a telephone relay service. |
N |
2 |
|
|
|
4. If it is not practical for a user with a TTY to directly interact with the IVR service, then an equivalent communication channel shall be made available to the TTY caller to provide the same functionality at no additional charge. |
A |
1 |
|
|
|
5. IVR deployers may wish to consider the use of SMS applications to supplement output from automated telephone services. |
N |
3 |
|
|
11.8 Timeouts and Errors |
1. All IVR deployers should carefully review the timeout values in their IVR systems and where appropriate, extend these values in order to increase the proportion of people able to use their systems. |
N |
2 |
|
|
|
2. IVR deployers should consider extending the length of time for valid inputs in menus for a user’s second chance (after an error or timeout has been triggered). |
N |
3 |
|
|
|
3. User testing should include users from a range of ages and cognitive abilities, and those using telephone relay services. |
N |
2 |
|
|
11.8.1 Error Recovery |
1. Users should be provided with the opportunity to recover from their most recent error, without being required to re-enter correct information. |
A |
2 |
|
|
|
2. Words such as "wrong", "illegal", “fatal” and “critical” should be avoided in error messages for users. |
A |
2 |
|
Other documents may
supersede this document. The latest status of this document series is
maintained at the ABA.
It is the intention of the Working Group to continue to work
with service providers and manufacturers to further improve the accessibility
of Automated Telephone Banking solutions. The Working Group will continue to
keep the Standard current and technically valid in so far as is practicable
and, as a minimum, will review the Standard annually.
A detailed list of changes to this document will be maintained at the ABA.
This `informative' appendix only contains additional information and
guidance. It in no way indicates requirements to be met by those choosing to
adopt this Standard.
Types of disability that are among the most common and relevant to
Automated Telephone Banking design, deployment and operation are described in
this Appendix.
According to the Australian Bureau of Statistics (ABS) 18.4 per cent of
the Australian population can be categorised as having a disability. An even
larger proportion is older and, while not defined as disabled, may have general
reduced ability associated with age. Some hidden disabilities (such as heart
impairment, breathing difficulties and psychological dysfunction, including
stress) can make it difficult for people to cope with electronic banking
services.
Problems that arise are
mainly concerned with getting about, gaining access to buildings and transport,
using products and equipment and carrying out the activities of daily life.
Such difficulties are also faced by people who experience temporary or
event-related access challenges: those who are temporarily ill or impaired,
pregnant women, parents accompanied by children, and people of short and tall
stature. If Automated Telephone Banking solutions are not designed and deployed in a way
that addresses their characteristics and capabilities they are disadvantaged.
People who are blind
have a total or near-total loss of vision. They rely more heavily on information
from other senses.
For some people who are blind it is an advantage if the directions for
use are available on audio tape, CD, online or in braille.
For users who have reduced vision, on-screen and printed information
should be available in large print format.
For users who are blind or vision impaired, and those who are in
eyes-busy situations (e.g. driving) it is important that the IVR service can be
operated without reliance on supplemental printed information.
Hearing impairment usually affects only part of the range of auditory
frequencies. In some cases it affects the whole range. The higher frequencies
are usually lost first with age.
Deaf people have little or no hearing and are much more reliant on visual
cues and information. They may use
Sign Language with English as their second language.
For people who are deaf or hearing impaired, written and spoken
information should be in plain English.
People with severe hearing loss will not be able to directly use IVR
services by use of a standard telephone; however, they may be able to access
such services via a TTY or a telephone relay service.
For people with a hearing impairment, discrimination of speech is
frequently affected, regardless of actual decibel loss, and this makes slow and
clearly delivered messages particularly important.
People with cognitive disabilities sometimes have poor memory, poor
processing time or difficulty with complex messages. If instructions and assistance
are given in an appropriate way, compensation
for cognitive impairment can often be achieved.
Speech disabilities create most difficulty in unfamiliar
surroundings. Pronunciation
difficulties, fluency or loudness are the most common manifestations. These may
be a problem where speech-input technologies or devices are used.
Older Australians may have any (or none) of the impairments described above.
From a vision standpoint the process of ageing can result in:
· Decrease in visual acuity: Many 60-year-olds require three times as much light as 20-year-olds to see an object.
· Reduced powers of accommodation: The older eye loses its ability to focus on near objects. The average distance of near point accommodation is 8 cm at age 16 and 100 cm at age 60.
· Decrease in contrast sensitivity: From age 20 to age 80 there is a progressive decrease in the ability to distinguish gradations of visual contrast so that greater contrast between information and background is needed to see an object, with the main decline beginning around age 40 or 50.
· Increased sensitivity to glare: The vision of individuals over 40 is more impaired by glare than is the vision of younger individuals.
· Longer dark adaptation times: It takes longer for an older person to become accustomed to seeing in a dark environment after coming from a bright environment.
· Decline of colour vision and discrimination: Colour vision and discrimination improves until age 30, then gradually declines from the ages of 30-40.
· Decline of binocular depth perception (Stereopsis): The ability to perceive depth by using both eyes remains constant until age 40, then declines until age 70.
· Glaucoma: Leading to loss of peripheral vision
· Macular degeneration: Loss of central vision
From a hearing standpoint the process of ageing can result in:
· Onset of many auditory disorders. The most common among these disorders is Presbycusis.
Age-related cognitive impairments include Alzheimer's disease and dementia. Individuals with Alzheimer's disease experience progressive intellectual decline, confusion, and disorientation. Individuals with dementia experience progressive loss of mental functions.
Most perceptual and cognitive limitations can be categorised as:
· Memory limitations: difficulty recognising and retrieving information;
· Perceptual limitations: difficulty taking in, attending to, and discriminating sensory information;
· Problem-solving limitations: difficulty recognising a problem; identifying, choosing, and implementing solutions; and evaluating outcomes;
· Conceptualising limitations: trouble with sequencing, generalising, categorising, cause and effect, abstract concepts, and comprehension; and,
· Language limitations: described separately in the following section.
Individuals with perceptual and cognitive limitations generally benefit from simple displays, low language loading, simple obvious sequences, and cued sequences. These individuals have difficulty understanding audio instructions, using written or electronic documentation, using automated systems, and/or using visual displays, depending on the type of limitation. Methods of improving designs to make them more accessible to this population include the use of voice prompts, increased size of print, simple fonts, high contrast, labels with icons or graphics, and progress displays.
Designing system interfaces that accommodate the deteriorating abilities of persons 65+ years of age has the potential to reach nearly half-a-billion consumers worldwide.
The primary
reason for knowing someone’s
“type” or “level” of intellectual disability is to identify suitable ways of providing support for this person. Therefore, the “levels” are defined
according to the support needs of
the person:
·
The characteristics of support for people with intermittent support needs would be:
episodic, not ongoing, every now and
then depending on what’s happening
for that person. For example, support may be suitable at times of significant change, such as when someone
starts a new job. However, support
is not required on a daily basis for the whole of someone’s life.
·
The characteristics of support for people with low or limited support needs are: minimal
support is provided on an ongoing,
life long basis.
·
The characteristics of support for people with medium or extensive support needs
are that more substantial amounts of
support are provided on an ongoing basis
· The characteristics of support for people with high or pervasive support needs are that this support is ongoing and provided for all daily living activities, including all personal care and self maintenance activities (such as bathing and eating).
The needs of the Intellectually Disabled have to be recognised in the provision of banking services that are within the capabilities of the person to manage. This Standard has as its core the simplification and standardisation of processes that will help people with minor intellectual disabilities. The standard does rely, however, on the presumption that those people provided with Automated Telephone Banking services have the capability to use those services without being in breach of the Conditions of Use that govern account operation. This requires as a minimum the ability to understand their rights and obligations, card and PIN security and usage, and the ability to correctly recognise transaction amounts presented for authorisation. Any lesser requirement would expose to exploitation those intellectually disabled persons with higher support needs.
The US ‘for comment’ standard HFES 200.5 (http://www.atis.org/pub/IVR/HFES-200-5.pdf) contains a variety of usability recommendations which are not contained in the existing Australian IVR standard AS/NZS4263. This HFES 200.5 document is being reviewed by Standards Australia and some of its recommendations may be included in updates to the Australian IVR standard.
The following paragraphs from HFES 200.5 should be considered by financial institutions, when developing or updating IVR services: 5.1, 5.2, 6.1 to 6.5, 7.1, 7.3 to 7.5, 7.7 to 7.10, 9.2, 9.5, 9.9, 10.1, 10.3, 10.4, 11.1 to 11.5, 12.2, and 12.4.
1. Telecommunication
facilities and services should be accessible to all.
2. The
needs of older people and people with disabilities should be taken into account
in the design of any new telecommunication equipment or service. Terminal
equipment should be designed for the widest possible market. Network services
should adequately support relevant special terminal functions so that all users
experience equivalent end-to-end service.
3. Where
inclusive design is not possible, provision should be made for people with
disabilities to access the service by means of additional equipment and
services.
4. People
with disabilities should, as far as possible, be able to use telecommunication
services at prices equivalent to those without disabilities. Most of the
additional costs of providing access to all should be met by dedicated funds or
absorbed within general operating costs.
5. Providers of telecommunication equipment and services and regulatory authorities should consult regularly with disabled and older users about their access requirements and take appropriate action. Equally, organisations representing older people and people with disabilities should be prepared to contribute their knowledge and experience.
6. Telecommunication
products and services that improve and increase access for older and disabled
people should be actively advertised and promoted, with information also
available in accessible formats.
Date ________________-
We hereby adopt this Telecommunication Charter
Signed by:_____________________________________________
Name Position in organisation
On behalf of____________________________________________(name of organisation/company)