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 Internet Banking technologies and provides a set of standards for their design, deployment and operation.
All organisations providing services to the general public are obliged by the Disability Discrimination Act 1992 to ensure that online information and services are accessible by people with disabilities.
During 2000, the Commonwealth Government’s Online Council agreed to the adoption of the World Wide Web Consortium's Web Content Accessibility Guidelines as the best practice standard for all Australian government websites. This decision should ensure that people with disabilities or technical constraints can use online resources provided by Australian governments. The Guidelines are widely recognised internationally, and have the support of HREOC, disability groups and rural representatives.
Adoption of common standards by all Australian financial services will promote the confidence of users in online services, and improve the accessibility of online financial services.
HREOC has been investigating issues surrounding website access by people with disabilities and older Australians. As part of this work, HREOC has drawn on the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). The WAI has resulted in the development of documents such as Web Content Accessibility Guidelines (WCAG) 1.0 and Authoring Tool Accessibility Guidelines 1.0.
These guidelines are primarily aimed at making web content and applications accessible to people with disabilities, however they also make web content more accessible to other users with technical constraints (eg, people using a low speed Internet connection). The Rural Industries Research and Development Corporation, in its report “Web Sites for Rural Australia: Designing for Accessibility”, has cited the W3C guidelines as a useful tool for addressing some of the particular accessibility problems experienced by rural users, mainly relating to slow download speeds.
All Commonwealth websites are to be tested by agencies for accessibility, and all new Commonwealth website contracts are to include accessibility as a key performance measure. Commonwealth websites are to follow the W3C guidelines to a sufficient extent that they pass recognised tests of accessibility.
1 Preface..................................................................................................................... 2
11.4.4.1 Continuity
of Navigation across site revisions........................................... 10
11.4.7 Learning,
User Support and Documentation.................................................... 10
11.4.7.3 Accessible
Downloadable Site Documentation......................................... 11
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.
In particular the work conducted by other standards bodies such as the World Wide Web Consortium (W3C) and the US Government’s Access Board has assisted formulation of the content of this document.
In formulating these guidelines, the Internet Banking Working Group has sought to incorporate the best information and guidance from available sources, as well as new research.
1. ”Electronic and Information Technology Accessibility Standards”, final Public Law 508 standards, Architectural and Transportation Barriers Compliance board [Published in the Federal Register on December 21, 2000] 36 CFR Part 1194, [Docket No. 2000-01], RIN 3014-AA25. Online at http://www.access-board.gov/sec508/508standards.htm.
2. A 24 August 2001 Public Comment draft of Web Content Accessibility Guidelines (WCAG) 2.0 is online at http://www.w3.org/TR/WCAG20/.
3. 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
4. Australian Human Rights and Equal Opportunity Commission (HREOC) World Wide Web Access: Disability Discrimination Act Advisory Notes (Version 3.1 May 1999) http://www.hreoc.gov.au/disability_rights/standards/www_3/www_3.html
5. Authoring Tool Accessibility Guidelines 1.0 http://www.w3.org/TR/ATAG10/ . For software developers, explains how to make a variety of authoring tools support the production of accessible Web content, and also how to make the software itself accessible.
6. Commonwealth government departments and agencies are obliged by the Disability Discrimination Act 1992 to ensure that online information and services are accessible by people with disabilities. See: http://www.govonline.gov.au/projects/standards/accessibility.htm.
7. Material from the Nordic Committee on Disability’s document, “Telephones for All” has also been used in developing this document.
8. User Agent Accessibility Guidelines 1.0 http://www.w3.org/TR/ATAG10/ . For software developers, explains how to make accessible browsers, multimedia players, and assistive technologies that interface with these.
9. Web Content Accessibility Guidelines 1.0 http://www.w3.org/TR/WCAG10/ . These explain in detail how to make a website accessible for people with a variety of disabilities.
This document is based in part on the local and international research on best practice in the design, deployment and operation of Internet 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
· Electronic signatures
· 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).
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 Internet 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:
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.
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.
Internet banking – this
includes web content and applications as well as transaction services
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
of this document.
People of non-English
speaking background (NESB) – Anyone for whom English is not their first spoken
or written language.
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.
Screen enlarger – a
piece of software that enables the user to enlarge computer screen print and
graphics. Such software has features
including zooming into specific screen content, tracking highlighting and mouse
pointers and adjusting on-screen colours to enhance readability.
Screen reader - the term
used to describe software designed to "read out" (or present in
braille) the contents of a computer screen for use by a person who is blind,
vision impaired or who has a reading disability. Screen readers are available for MSDOS, Microsoft Windows, the
Macintosh and some Unix platforms.
Screen readers usually work hand-in-hand with a speech synthesiser or braille
display device in order to present computer information in an accessible
format.
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 of 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 of this document.
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.
W3C - World Wide Web
Consortium – The World Wide Web Consortium (W3C) develops interoperable
technologies (specifications, guidelines, software, and tools) to lead the Web
to its full potential. The World Wide Web Consortium was created in October
1994 to lead the World Wide Web to its full potential by developing common
protocols that promote its evolution and ensure its interoperability. W3C has
more than 500 Member organisations from around the world and has earned
international recognition for its contributions to the growth of the Web. The
W3C is online at www.w3.org.
WAI - Web Accessibility
Initiative - a domain of the World Wide Web Consortium (W3C) charged with
developing recommendations for accessible web design. It has several sub-committees that are looking at guidelines for
web authors, browser manufacturers and web design and testing tools.
Web Accessibility - a
philosophy of website design which endeavours to make a site as easy and
effective to access for the widest possible range of potential users,
irrespective of their limitations and capabilities, their location, equipment
or bandwidth.
Other technical terms to be found in this document conform to W3C usage. A W3C glossary may be found at http://www.w3.org/TR/WCAG10/ - glossary.
This Industry Standard
is intended for use by developers, suppliers, designers and users of Internet
Banking Services.
This Industry Standard specifies requirements, guidelines, recommendations and suggestions that apply only to web content presented to a human reader. A structured database or metadata collection where the data is intended for use by another machine and thus requires no interface lies outside the scope of these guidelines.
The scope of the document is confined to Internet-based technologies, and does not include for example, Macintosh applications, or non-browser software using a dial-up front end to perform a transaction
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.
This document focuses on online transactional banking services and associated applications and documentation, however the principles should also be applied to the broader range of Internet services offered by financial institutions. Examples of transactions covered include, but are not limited to:
· Online service registration
· Balance enquiry
· Statement viewing
· Transfer between accounts
· Bill pay
· Third party funds transfer
· Reviewing and updating investments and portfolios
· Online loan applications
· Interactive financial calculations performed online.
The Standard will also apply to related services such as online annual reports and account aggregation tools.
Email messages associated with the delivery of Internet Banking services, and sent from a financial institution to its customers, are within the scope of this Standard.
A range of factors can impact the effective accessibility and usability of online services including:
(a) (for the financial institution) choice of web development tools, expectation of minimum hardware/browser technology used by customer, reliance on scripting and applet technologies;
(b) (for the customer) level of experience with web-based technologies, platforms/operating systems selected, brand and version of assistive technologies (screen readers, print enlargers, etc), firewalls and quality of telecommunications lines and other factors.
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.
Many of the design principles in this document represent broad concepts that apply to all Web-based content. In most cases they are not specific to HTML, XML, or any other technology. This approach was taken so that the design principles could be applied to a variety of situations and technologies, including those which do not yet exist.
The wording of requirements as “shall”, “should” or “may” clauses indicates the relative importance of each requirement.
Websites shall, with the allowable exception of checkpoint 6.3, meet the sixteen W3C WCAG V1.0 Priority 1 checkpoints within six months of the release date of this Standard, either by compliance with the checkpoint, or stipulation of the checkpoint as not applicable. See http://www.w3.org/TR/WCAG10/full-checklist.html.
Checkpoint 6.3 is “Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent information on an alternative accessible page.”
If a website does not meet checkpoint 6.3, then it shall conform to US Public Law 508 rule L, which appears at 11.1.2.1 below.
Websites shall without exception meet all sixteen W3C WCAG V1.0 Priority 1 checkpoints within eighteen months of the release date of this Standard, either by compliance with the checkpoint, or stipulation of the checkpoint as not applicable.
Websites should also meet all W3C WCAG V1.0 Priority 2 checkpoints and should work towards meeting all Priority 3 checkpoints within eighteen months of the release date of this Standard.
Financial
institutions should follow rules l, n, o and p from US Public Law 508
pertaining to Internet sites, which are additional to the guidelines of WCAG
1.0.
When pages utilise scripting languages to display content, or to create interface elements, the information provided by the script is to be identified with functional text that can be read by assistive technology.
When electronic forms are designed to be completed on-line, the forms are to allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
A method is to be provided that permits users to skip repetitive navigation links.
In addition to applying this rule, web developers should minimise the need for any repetitive screen navigation.
When a timed response is required, the user is to be alerted and given sufficient time to indicate more time is required, except in those cases where time outs are required for security purposes.
Note: The above text is an adaptation of the Rule P content in Public Law 508.
During design, and prior to implementation, it is strongly recommended that users of different ages, and with a range of capabilities and limitations be engaged to trial the new service 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 the site’s usability for all customers). However, if changes are made for accessibility then the revised design will need to be tested again for general acceptance.
Institutions should also test their websites with adaptive technology such as screen readers and screen enlargers.
There are a variety of automated and semi-automated tools for gaining indicative information about the probable accessibility of a page or a site. The best known of these is Bobby http://www.cast.org/bobby a tool developed by CAST (Center for Applied Special Technology).
A range of other tools is listed by the WAI Evaluation and Repair working group at http://www.w3.org/WAI/ER/existingtools.html.
Automated tools can only give a general guide of how accessible a site is. To gain a real sense and perspective of the accessibility of a site, a range of potential end users will need to be engaged to identify what aspects of pages are accessible or not.
Financial institutions should test accessibility of their customer websites with both automated tools and user accessibility trials.
Every effort should be made to support the widest possible range of users. Institutions should provide information to customers on the minimum user configuration supported.
The following recommendations are particularly relevant to financial institutions, and relate to enhanced usability of Internet services.
Login and security procedures need to be designed in such a way that they can be operated without the use of a mouse, and can be independently accessed by customers who use screen reading software.
Subject to
identification and security requirements, the user should be able to register
for an Internet service online or by using the telephone or TTY, and without
completing printed forms.
The
institution should, subject to identification and security requirements, accept
the registration of a customer to an Internet banking 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, as an exception to standard business rules.
Within a given session,
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 or mouse clicks required of the user should be minimised.
A user should be
provided with the opportunity to cancel transactions and/or change data and
information that has been entered during a session.
Redundancy of
information across more than one sensory channel should be provided, and will
assist users with sensory disabilities as well as users of personal/mobile
technologies. For example, video clips
should contain audio descriptions for blind users and text captions for deaf
users.
Audible bells and alarms
from the computer should also be visually indicated.
Pictures, tables, flow
charts and other visual information should be described or summarised in
textual form for those who cannot see them or for those who do not have
graphical capabilities readily available.
When live streaming is used, text script should be provided as soon as possible following the event.
Financial institutions should maintain continuity of core online banking functions as the site is upgraded and revised. For example, if an older person learns to use the site to pay bills, they should be able to make minimal adjustments to the steps they have learned following upgrades.
Consideration should also be given to developing wizards to lead users through transactions.
Customer sites shall contain a link containing a textual overview of the site layout and structure. This is essentially a non-visual site map, and will assist users to understand the philosophy of the site, and improve their navigation through it. (See the Australian Tax Office’s Assist site as an example http://www.ato.gov.au).
Financial institutions should, beginning with their own organisations, work towards consistency of Internet-related terminology, concepts and processes, with the following objectives:
(a) consistency of standard transactions across financial institutions, for example, by agreeing on order of fields in funds transfer forms, Bpay forms, etc;
(b) consistency on terminology for user name, password, receipt number etc.
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.
The following notes from W3C WAI should also be considered:
“Provide consistent and predictable responses to user actions within the
online service. Make interactions consistent, both throughout the site and with
commonly used interaction metaphors used throughout the Web. For example,
similar layout for user interface components is used throughout your site,
similar user interface components are labelled with similar terminology,
controls that look the same are designed to act the same, operating system,
language, or application conventions likely to be familiar to the user have
been followed, unusual user interface features or behaviors that are likely to
confuse the first-time user are documented.
Providing responses to user actions is important feedback for the user.
This lets them know that your site is working properly and encourages them to
keep interacting. When the user receives an unexpected response, they might
think something is wrong or broken. Some people might get so confused they will
not be able to use your site.”
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.
The deployer may wish to consider the implementation of settings profiles for a user, so that preferred settings such as screen colour, font style and size, text or graphics layout, audio settings and other parameters are linked to an account or user identification number.
Each site should have a practice section, where people can perform trial transactions to safely explore and master the service, without risking funds or embarrassment. To ensure accessibility, the practice facility should provide an identical customer experience and should give feedback on the success or otherwise of the practice transaction. Such feedback should also include suggestions on what went wrong and on the correct procedure.
Users may benefit from accessible online tutorials for a site or feature. To ensure accessibility, tutorials should be developed using the same technologies as for the actual service.
To assist new users, downloadable documentation and quick reference cards for the site should be available, and kept up-to-date when site structure is altered.
These materials should be available in accessible formats, not just PDF files.
All new documents made available online in PDF format, shall also be made available in HTML, RTF or another suitable text format.
PDF versions of documents should be created in accordance to the Adobe guidelines for accessible PDF creation which are found at the following URL: http://access.adobe.com/information.html
Institutions may need to develop a solution to protect sensitive documents such as loan applications against unauthorised editing which also ensures access to the information for people with disabilities.
All text-based information, including terms and conditions and policy documents, shall be in plain English and available in accessible formats.
Financial institutions may wish to incorporate Auslan video clips to inform and assist deaf users who employ Australian Sign Language (Auslan).
Supervisors and senior helpdesk staff should be given training in access technologies and in understanding how people with disabilities access online services.
Web developers should receive training and guidance in developing accessible websites and in understanding how people with disabilities access online services, so that they can develop appropriate strategies for broader accessibility of sites.
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”. These priority levels are different from and do not correspond with W3C levels.
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 Implementation |
|
|
|
|
|
11.1.1 W3C
Compliance |
1. Websites shall, with the allowable exception of checkpoint 6.3, meet the sixteen W3C WCAG V1.0 Priority 1 checkpoints within six months of the release date of this Standard, either by compliance with the checkpoint, or stipulation of the checkpoint as not applicable. See http://www.w3.org/TR/WCAG10/full-checklist.html. |
A |
1 |
|
|
|
2. If a website does not meet checkpoint 6.3, then it shall conform to US Public Law 508 rule L, which appears at 11.1.2.1. |
A |
1 |
|
|
|
3. Websites shall without exception meet all sixteen W3C WCAG V1.0 Priority 1 checkpoints within eighteen months of the release date of this Standard, either by compliance with the checkpoint, or stipulation of the checkpoint as not applicable. |
A |
1 |
|
|
|
4. Websites
should also meet all W3C WCAG V1.0 Priority 2 checkpoints and should work
towards meeting all Priority 3 checkpoints within eighteen months of the
release date of this Standard. |
A |
2 |
|
|
11.1.2 US Public
Law 508 |
1. Financial institutions should follow rules l, n, o and p from US Public Law 508 pertaining to Internet sites. |
A |
2 |
|
|
11.2 Testing Accessibility |
1. During design, and prior to implementation, it is strongly recommended that users of different ages, and with a range of capabilities and limitations be engaged to trial the new service and provide feedback. |
N |
2 |
|
|
|
2. Institutions should also test their websites with adaptive technology such as screen readers and screen enlargers. |
N |
2 |
|
|
|
3. Financial institutions should test accessibility of their customer websites with both automated tools and user accessibility trials. |
A |
2 |
|
|
11.3
Compatibility |
1. Every effort
should be made to support the widest possible range of users. |
A |
2 |
|
|
|
2. Institutions
should provide information to customers on the minimum user configuration
supported. |
A |
2 |
|
|
11.4 Enhancing Usability |
|
|
|
|
|
11.4.1 Registration and Login |
1. Login and
security techniques need to be designed in such a way that they can be
operated without the use of a mouse, and can be independently accessed by
customers who use screen reading software. |
N |
2 |
|
|
|
2. Subject to identification and security requirements, the
user should be able to register for an Internet service online or by using
the telephone or TTY, and without completing printed forms. |
A |
2 |
|
|
|
3. The institution should, subject to identification and
security requirements, accept the registration of a customer to an Internet
banking service when the registration request is received either directly via
a telephone or TTY, or indirectly through a telephone relay service. |
A |
2 |
|
|
11.4.2 Input Requirements |
1. Within a given
session, 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 |
|
|
|
2. The number of key
presses or mouse clicks required of the user should be minimised. |
A |
2 |
|
|
|
3. A user should be
provided with the opportunity to cancel transactions and/or change data and
information that has been entered during a session. |
A |
2 |
|
|
11.4.3 Redundancy of Information |
1. Redundancy of information across more than one sensory channel should be provided. |
A |
2 |
|
|
|
2. Audible bells and alarms from the computer should also be visually indicated. |
A |
2 |
|
|
|
3. Pictures, tables, flow charts and other visual information should be described or summarised in textual form for those who cannot see them or for those who do not have graphical capabilities readily available. |
A |
2 |
|
|
|
4. When live streaming is used, text script should be provided as soon as possible following the event. |
A |
2 |
|
|
11.4.4 Navigation |
|
|
|
|
|
11.4.4.1
Continuity of Navigation across site revisions |
1. Financial institutions should maintain continuity of core online banking functions as the site is upgraded and revised. |
N |
2 |
|
|
|
2. Consideration should also be given to developing wizards to lead users through transactions. |
N |
2 |
|
|
11.4.4.2 Textual Overview/Site Map |
1. Customer sites should contain a link containing a textual overview of the site layout and structure. |
A |
2 |
|
|
11.4.5 Consistency |
1. Financial institutions should, beginning with their own organisations, work towards consistency of Internet-related terminology, concepts and processes, with the following objectives: (a) consistency of standard transactions across financial institutions, for example, by agreeing on order of fields in funds transfer forms, Bpay forms, etc; (b) consistency on terminology for user name, password, receipt number etc. |
N |
2 |
|
|
11.4.6 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 |
N |
2 |
|
|
|
2. Words such as "wrong", "illegal", “fatal” and “critical” should be avoided in error messages for users. |
A |
2 |
|
|
11.4.7 Learning,
User Support and Documentation |
1. The deployer may wish to consider the implementation of settings profiles for a user, so that preferred settings such as screen colour, font style and size, text or graphics layout, audio settings and other parameters are linked to an account or user identification number. |
N |
3 |
|
|
11.4.7.1 Practice
Option |
1. Each site should have a practice section, where people can perform trial transactions to safely explore and master the service, without risking funds or embarrassment. To ensure accessibility, the practice facility should provide an identical customer experience and should give feedback on the success or otherwise of the practice transaction. Such feedback should also include suggestions on what went wrong and on the correct procedure. |
N |
2 |
|
|
11.4.7.2
Accessible Online Tutorials |
1. Tutorials should be developed using the same technologies as for the actual service. |
N |
2 |
|
|
11.4.7.3
Accessible Downloadable Site Documentation. |
1. Downloadable documentation and quick reference cards for the site should be available, and kept up-to-date when site structure is altered. |
N |
2 |
|
|
|
2. These materials should be available in accessible formats, not just PDF files |
N |
2 |
|
|
11.4.7.4
Equivalents to PDF |
1. All new documents made available online in PDF format, shall also be made available in HTML, RTF or another suitable text format. |
N |
1 |
|
|
|
2. Institutions may need to develop a solution to protect sensitive documents such as loan applications against unauthorised editing which also ensures access to the information for people with disabilities. |
N |
3 |
|
|
11.4.7.5 Provision of Information |
1. All text-based information, including terms and conditions and policy documents, shall be in plain English and available in accessible formats. |
N |
1 |
|
|
11.4.7.6 Auslan |
1. Financial institutions may wish to incorporate Auslan video clips. |
N |
3 |
|
|
11.4.8 Staff Training |
1. Supervisors and senior helpdesk staff should be given training in access technologies and in understanding how people with disabilities access online services. |
A |
2 |
|
|
|
2. Web developers should receive training and guidance in developing accessible websites and in understanding how people with disabilities access online services, so that they can develop appropriate strategies for broader accessibility of sites. |
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 Internet 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 Internet 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 Internet Banking solutions
are not designed and deployed in a way that addresses their characteristics and
capabilities they are disadvantaged.
All users will benefit from well thought-out page and site design, from clear language usage, and from presentation of the most appropriate information, based on user preferences and profiles.
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.
People who are vision impaired will benefit from uncluttered
pages and pages which display important information without other visual
distractions such as flashing or moving text.
Users who are blind will benefit from labelled graphics, consistent navigation, meaningful link names, textual or audio descriptions of video content, and the ability to access information otherwise only available on paper.
Users who are vision impaired or colour blind will benefit from highlighting text as the cursor moves over it, good colour contrast on pages, use of cascading style sheets allowing them to override screen fonts and colours and avoidance of reliance on colour as the only means of differentiating information on a page.
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.
Users who are deaf or hearing impaired will benefit from
clear, concrete language usage, visual and text equivalents for audio content
on pages, and sign language videos which explain services and processes.
Reduced function in the
lower limbs - due to disease, accidents or age - often leads to poor mobility.
Poor mobility can result in people having to use wheelchairs.
Users who are homebound will benefit from availability of
information and transactions via the Internet, rather than having to attend
offices and shopfronts.
Reduced function in the
upper limbs, as a result of reduced strength or coordination, can make the
operation of keys, knobs, handles and everyday utensils extremely difficult.
Unless carefully designed, electronic devices are difficult or impossible to
use by people with poor dexterity or grip.
Users with arthritis or reduced fine motor hand control will benefit from minimal reliance on mouse movements for navigation and selection.
Greater use of direction keys may be required in preference to a mouse.
To assist users with reduced dexterity all areas of the
website should be accessible with a single slow mouse click within a large
button. Older users often suffer from unsteady hand and arm movements, caused
by Parkinson’s disease or general infirmity and are often unable to accurately
position the mouse on a small area. They may also have reduced reflex skills,
which prevent the double click movement from being easily made.
Almost all manual tasks
involve an element of reaching and stretching. People with musculoskeletal
disorders such as arthritis have difficulty reaching and stretching. The extent
of effective reach is often determined by the amount of force to be applied by
the hand and the posture that is adopted.
Headstick and mouthstick
users, and people who can use only one hand, are unable to press more than one
key at a time. Consequently, it must not be necessary to press two keys
simultaneously in order to activate any features and facilities.
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.
Users with epilepsy will benefit from text that doesn’t
flash and minimal use of moving text, as would the aged, those with vision
impairments and new users.
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 Internet 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, 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.