Australian Banking Industry E-Commerce Industry Action Plan

December 2000 

Implementation Process

28 March 2001          Publicly Announce intention to Lodge Industry Action Plan on 30th of April 2001.

 

29 March 2001            Industry Action Plan made public on HREOC web-site and Australian Bankers’ Association web-site. Public comment and submissions welcome by 25th of April 2001.

 

                                    ABA:   www.bankers.asn.au

          

                                     HREOC: http://www.humanrights.gov.au/disability_rights/index.html

                                   

Submissions:               (e-mail: actionplan@bankers.asn.au)

                                    Reception, Level 3, 56 Pitt Street,    Sydney,    2001

 

30 April 2001 Lodge Industry Action Plan with HREOC.

Introduction

The Australian Banking Industry is committing itself to playing its part in eliminating the “Digital Divide” that exists in Australia today. As technology reshapes the financial services industry it is critical all people, including older people and people with disabilities have access to electronic networks such as EFTPOS, ATMs, internet and phone banking.

Accessing financial services is an important element in allowing people to participate in community life. Every adult person needs to access cash, pay bills and arrange their finances with convenience and safety. In June 1999, the Human Rights and Equal Opportunities Commission (HREOC) released its report “Accessibility of Electronic Commerce and New Service and Information Technologies for Older Australians and People With a Disability” which identified an emerging “Digital Divide” between those people who could utilise new technologies to improve their lives and those who couldn’t.The report made a series of recommendations to begin the process of eliminating the Digital Divide by dismantling E-commerce access barriers.

One of the key messages in the HREOC report is that some aspects of the “Digital Divide” involved barriers that conflicted with State and Federal Government anti-discrimination laws such as the Disability Discrimination Act 1992. This Act is the primary motivator for businesses to ensure their products and services are widely available and accessible to all people, including older people and people with disabilities.

It is the aim of this Industry Action Plan to contribute to the process of eliminating the “Digital Divide” by implementing the recommendations in HREOC report principally through the development of industry best practice standards or guidelines. Hence, the Industry Action Plan is primarily aimed at providing the necessary framework by which individual banks and financial service providers can implement their own Disability Action Plans and initiatives.

An important mechanism for the implementation of industry wide accessibility best practice standards is the Accessible E commerce Forum which is an initiative of HREOC and the ABA and includes representatives from a range of industry, government and community groups. The role of the Forum is to identify partnerships and strategies to address the recommendations in the HREOC report of e commerce. The Forum invites comment and contributions from all interested parties and will play and important role in achieving a community wide consensus on proposed best practice industry standards.

 

Scope and Structure of Industry Action Plan

This Industry Action Plan addresses the recommendations in the HREOC report  E-commerce access by older people and people with a disability. It mainly covers electronic banking issues, and is essentially concerned with reviewing, writing and adopting as best practice industry standards, guidelines for electronic banking facilities. There are two qualifications to this:

1.      The HREOC report does make specific recommendations about the maintenance of face-to-face services, which is related to but wider than E-commerce issues.

2.      While this Industry Action Plan is primarily concerned with establishing voluntary best practice industry standards, an industry-wide commitment for banks to meet W3C internet best practice industry standards is given under “Recommendation 8”

The structure of this Industry Action Plan is based upon a specifically recommended model by the Human Rights and Equal Opportunity Commission and is consistent with their published guidelines on producing such plans. 

Accessibility issues outside the framework of HREOC’s accessibility report, such as property access and statement information access, are the responsibility of individual banks to address, perhaps through their own Industry Action Plan. 

Review and Evaluation Process

This draft Plan is being made available for public comment and, when adopted, the Plan will be reviewed every six months as will the progress towards meeting the commitments and objectives. The results of the review will be published on both the ABA’s and HREOC’s Web Sites as well as outlined in ABA Media Releases. The review process will follow HREOC guidelines.

 

Recommendation One:

Industry Approach to Addressing Issues of

E-commerce Accessibility

Section One

Report Recommendation

“Relevant industry bodies taking an increased role in educating those developing and implementing new technologies on accessibility issues.”

Problems or Barriers Identified

Current standard setting processes unlikely to keep pace with technological change. HREOC’s report noted that “Traditional regulatory and standard setting processes are unlikely to be able to keep pace with developments in digital service and information technologies, or to be able to foresee and specify requirements for all features of new technologies.” 

Prescriptive regulatory approaches to accessibility may act to delay or restrain new technologies for consumers. HREOC notes: “Submissions and research have emphasised the importance of accessibility being built into technologies from the start, but also the undesirability of regulatory approaches which unduly delay of constrain availability to consumers of new technologies.”

Industry Action Already Taken

A core function of the Australian Bankers’ Association is to develop and implement best practice industry standards and protocols. The ABA participated in the drafting of the Uniform Consumer Credit Code and the Electronic Funds Transfer Code; it administers the Code of Banking Practice; and has many standing working groups that develop industry-wide policies across a range of public policy areas including, taxation, payments system, small business, security, prudential regulation and banking access.

The ABA was part of the committee that wrote and updated the current ATM Standard in the early 1990s.

 

Section Two

Objective

For the ABA to orchestrate an industry-wide response to HREOC’s E-commerce accessibility report.

1.1 Strategy: ABA/HREOC to joint sponsor the establishment of the Accessible E commerce Forum.  
  Who is Responsible?   ABA CEO
  Timeframe:       August 2000
  Measurable Outcome:   Meeting held to form working group.
     
1.2 Strategy: ABA to establish internal industry working group to advise on ABA’s participation on the Accessible E Commerce Forum  
  Who is Responsible? ABA CEO  
  Timeframe: August 2000  
  Measurable Outcome: Seek commitment from Member banks to allow ABA to respond to HREOC’s accessibility report.
     
1.3 Strategy: Set up Internet page with compilation of electronic banking best practice industry standards.  
  Who is Responsible?   ABA CEO
  Timeframe:   July 2001
  Measurable Outcome:    

Recommendation Two:          

Face-Face Banking Services

 

Section One

Report Recommendation

“Ensuring as far as possible that on line and automated services are used to complement and enhance availability of direct human service rather than completely substituting for it, and that information on available alternatives to automated services is effectively available.”

Problems or Barriers Identified

Electronic banking offers older people and people with disabilities the opportunity for greater independence and self-esteem, but for many it is not regarded as an option because of a range of barriers, including attitudinal, awareness, physical, affordability and safety. There is scope to improves electronic banking accessibility, but for many people, the only way these barriers will be avoided is by the continued presence of face-to-face services. For a person who chooses not to use electronic banking as a statement of protest or individuality, no design electronic banking design improvements will enhance their accessibility.

Industry Action Already Taken

Despite closing a significant number of traditional branches in recent years, banks are continuing to provide a high level of face-to-face facilities through development of alternative, less costly, facilities like giroPost and agency arrangements. Reserve Bank figures show that there are more face-to-face services in Australia today, than there were five years ago.

Section Two

Objective 

To raise awareness of new forms of face-to-face services available to customers and to emphasise to its members the importance of these services to older people and people with disabilities.

2.1 Strategy:   ABA to provide information to Accessible E commerce Forum about new innovations in face-to-face services.  
  Who is Responsible?   ABA CEO  
  Timeframe:   May 2001  
  Measurable Outcome:   Presentation given  

Recommendation Three:           EFTPOS

Section One

Report Recommendation

“Continued attention by relevant Australian industry bodies to international developments in EFTPOS accessibility options.”

Problems or Barriers Identified

The designs of EFTPOS machines pose a range of accessibility barriers. For people who are blind or vision impaired, entering a PIN can be difficult due to touch-sensitive keys which enter data on the slightest touch. They may also have difficulty with card orientation.

For people with severe motor disabilities, memory problems or dyslexia, PIN entry may be too difficult altogether.

The main barrier for people who use wheelchairs is the height of the key pad.

Industry Action Already Taken

Some service providers have introduced technology that provides better accessibility, such as spring loaded EFTPOS key pads.

 

Section Two

Objective

To provide banks and other financial institutions with an EFTPOS Standard which is consistent with the Australian Disability Discrimination Act and world best practice.

3.1 Strategy:   Establish EFTPOS sub-committee of Accessible E commerce Forum to write EFTPOS Standard.  
  Who is Responsible?   ABA CEO
  Timeframe:   End of April 2001
  Measurable Outcome: EFTPOS sub-committee established

 

3.2 Strategy:   To adopt Standard as the industry Standard for EFTPOS.  
  Who is Responsible?   ABA CEO  
  Timeframe:   End of Dec 2001
  Measurable Outcome:   An industry standard supported by the Accessible E commerce Forum and endorsed by ABA Council.  

 

Recommendation Four:           ATM Standards

 

Section One

Report Recommendation

Revision of Australian Standards applicable to ATMs and similar devices, to promote more effective guidance on achieving equal access consistent with requirements of the Disability Discrimination Act.”

Problems or Barriers Identified

Current ATM Standard (3769) deals mainly with physical access, not full range of issues. HREOC’s report into E-commerce accessibility concluded that the current standard does not meet the requirements of the Disability Discrimination Act (DDA). Nor does the standard reflect world best practice in this area. The current standard deals mainly with physical access issues and not with the full range of accessibility issues faced by older people and people with disabilities.

HREOC is recommending that the banking industry in cooperation with the Accessible E commerce Forum take the initiative and re-write and adopt a new standard as an industry guide/benchmark.

Research reveals wide ranging accessibility problems with ATMs, particularly for blind and vision impaired people. Problems include:

§             finding and physically accessing ATMs, due to physical barriers like steps, no grab rail, keyboard height, no leg room for wheel chairs;

§             learning the transaction process which often vary across machines, lack of instruction material;

§             memorising PIN and orientation of card, card gobbling, safety;

§             lack of tactile indicators on keyboards, confusion with one key having multiple functions, inconsistency; small font sizes, sun glare.

Industry Action Already Taken

ABA has established through the Accessible E commerce Forum a sub-committee to write and ATM standard, drawing upon work already completed in other countries, such as Canada, US and UK. The latter work provides a “head start” for putting together a standard for Australia.

Section Two

Objective

To provide banks and other financial institutions with an ATM standard which is consistent with the Australian Disability Discrimination Act and world best practice.

4.1 Strategy:   ABA to drive re-writing of ATM Standard to comply with DDA and world best practice on accessibility.  
  Who is Responsible?   ABA CEO
  Timeframe:   End of April 2001
  Measurable Outcome:   ATM sub committee established.  
     
4.2 Strategy:   ABA to adopt ATM Standard as industry standard.  
  Who is Responsible?   ABA CEO  
  Timeframe:   End of Dec 2001  
  Measurable Outcome:   ATM standard supported by Accessible E commerce Forum and to be endorsed by ABA Council.
     
4.3 Strategy:   Provide information to member banks on world best practice accessible ATMs.  
  Who is Responsible?   ABA CEO  
  Timeframe:   On-going  
  Measurable Outcome:    

 

Recommendation Five:           Smart Cards

 

Section One

Report Recommendation

“Attention to universal design approaches in implementation of automated identification technologies and smart card systems.”

Problems or Barriers Identified

Smart cards yet to be introduced.

 

Section Two

Objective

To ensure that the design of and introduction of smart card technology into Australia is done in a way that provides access to older people and people with disabilities.

5.1 Strategy:   ABA to invite representation of Mondex (or other smart card leader) to join Accessible E commerce Forum, so that they are kept informed of access issues.  
  Who is Responsible?   ABA CEO
  Timeframe:   28th March 2001
  Measurable Outcome:   Next meeting of Accessible E commerce Forum is 28 March 2001.

 

Recommendation Six:   Phone-based Services

 

Section One

Report Recommendation

“Wider implementation of the existing Australian Standard on interactive voice response systems.”

Problems or Barriers Identified

The HREOC accessibility report summarised the main problems with voice systems as:

§          Lacking in some cases of sufficiently clear and early “exit option” to a human operator for people who cannot use or understand automated facilities.

§          Inability of people who use telephone typewriters (TTYs) because of deafness or speech impairments to use automated telephone or service facilities.

§          Problems for people who cannot manage required keyboard input within the response times allowed by some automated systems.

HREOC concluded that submissions and research material indicated that wider implementation of the Australian Standard on IVR systems, and closer attention to usability issues generally, would improve accessibility and usability of these systems.  Centrelink has also emphasised the importance of this standard.

Industry Action Already Taken

Many banks have built their voice systems with reference to the IVR standard. 

 

Section Two

Objective

To provide banks and other financial institutions with a Telephone Banking Standard which is consistent with the Australian Disability Discrimination Act and world best practice.

6.1 Strategy:   Establish telephone banking sub –committee of Accessible E commerce Forum to review current Standard AS/NZS 4263  
  Who is Responsible?   ABA CEO
  Timeframe:   End of April 2001
  Measurable Outcome: Sub committee established and completes review

 

     
6.2 Strategy:   To adopt Standard as an industry standard for phone banking services.  
  Who is Responsible?   ABA CEO
  Timeframe:   End of October 2001
  Measurable Outcome:   An industry standard supported by the Accessible E commerce forum endorsed by ABA Council.  

         

Recommendation Seven:           Internet

 

Section One

Report Recommendation

“Other information and service providers ensuring compliance of their web sites with the World Wide Web Consortium’s Web Content Accessibility Guidelines.”

Problems or Barriers Identified 

HREOC’s Accessibility report noted the following accessibility barriers associated with internet sites:

§          Images lacking “alt text” labels.

§          Excessive download times.

§          Software incompatibility problems.

§          Frames not properly labeled.

§          Frame alternatives not provided.

Industry Action Already Taken

ABA is conducting a review of bank internet sites to check compliance with W3C. This review will form the basis of an industry-wide commitment to adopting the standard.

 

Section Two

Objective

To ensure bank web sites are consistent with the Australian Disability Discrimination Act and world best practice in accessibility.

7.1 Strategy:   Establish internet sub-committee of Accessible E commerce Forum to review W3C.  
  Who is Responsible?   ABA CEO  
  Timeframe:   End of April 2001  
  Measurable Outcome:   Sub-committee established.

 

     
7.2 Strategy:   To adopt W3C as the industry standard for internet accessibility.  
  Who is Responsible?   ABA CEO  
  Timeframe:   End of July 2001
  Measurable Outcome:   An industry standard supported by the Accessible E commerce Forum and endorsed by ABA Council.  
     
7.3 Strategy:   Bank compliance with W3C.  
  Who is Responsible?   ABA CEO
  Timeframe:   ?  
  Measurable Outcome:   Banks adopt industry standard and establish timeframe for implementation.  

 

Ends

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