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back to Policies & Submissions: Access
1. Introduction
2. Industry response
2.1
Identification of accessibility initiatives and commitments
2.2 Disability Action Plans (DAPs)
2.3
Implementation and progress with accessibility priorities
2.4 Review of the
voluntary Industry Standards
2.5 Emerging issues and technology
3. Examples of specific comments
3.1 Improving
communications and raising awareness of DAPs
3.2 ATMs
3.3 EFTPOS
3.4 Telephone banking
3.5 Internet banking
3.6 Monitoring
and evaluation of accessibility initiatives
4. Conclusion
The ABA welcomes the opportunity to respond to matters raised between HREOC, the ABA and banking industry representatives last year regarding the implementation of the voluntary Industry Standards covering accessibility of Automated Teller Machines (ATMs), Electronic Funds Transfer at the Point of Sale (EFTPOS), telephone and Internet banking1.
This ABA response report comprises an affirmation of the banking industry’s commitment to the voluntary Industry Standards and a description of the continuing improvements in accessible electronic financial services. This report provides specific examples of progress against particular initiatives as contained in individual banks’ Disability Action Plans (DAPs) and other banking industry practices.
The ABA and its members fully support and are committed to the practical implementation of the voluntary Industry Standards launched in April 2002.
Following the introduction of the voluntary Industry Standards, the major ABA member banks developed and/or revised their DAPs. Other member banks ensured that internal policies relating to staff and customers with disabilities were aligned to the voluntary Industry Standards.
The basis for the banking industry’s actions plans for improving accessibility is the Disability Discrimination Act 1992 and State and Territory anti-discrimination laws, as well as the voluntary Industry Standards. In addition, DAPs generally complement individual governance approaches to stakeholder engagement, such as customer service charters, community banking programs or social responsibility and disability practice indicators.
Outcomes and initiatives contained in the DAPs seek to improve accessibility for persons with disabilities2.
The Australian Bureau of Statistics report “Disability, Ageing and Carers: Australia”3 estimates that 19.2% of Australia's population (or approximately 3.6 million people) have a recognised and ongoing disability.
Initiatives and commitments contained in DAPs address accessibility issues associated with financial products and services, property and premises and communications with stakeholders, with a particular focus on electronic banking channels.
The ABA and its members welcome the opportunity to work with HREOC and the disability community on the development of new initiatives to enhance the DAPs.
The banking industry has made a commitment to develop and implement strategies and initiatives to ensure that financial products and services are accessible for everybody. The ABA and its members welcome the opportunity to continue to work with HREOC on particular accessibility priorities.
For example, ABA members note the initial comments made by HREOC last year in relation to improvements with Internet banking and have made significant progress in updating website structure and capability. Banks are reviewing further enhancements to website content and functionality to continue to improve accessibility to Internet banking for persons with disabilities.
Banks indicate that continuous improvements to Internet banking are a significant part of their implementation and upgrade programs.
A complete review of the voluntary Industry Standards is deemed unnecessary at this time as implementation continues, and it is too early for a thorough practical examination by banks and the community of the benefits of the voluntary Industry Standards as they have been applied.
ABA members will raise specific issues with the ABA. The ABA and HREOC will continue to work together to identify emerging concerns from the disability community.
The partnership between the banking industry, Government and the community is vital to ensuring accessibility issues are identified and solutions are designed to address any recommendations.
The ABA notes there has been an accessibility comparison survey of banks' websites conducted by the National Information and Library Service (NILS)4.
The banking industry's commitment to “remote” banking facilities seeks to remove the physical barriers that may make it difficult for older persons and persons with disabilities accessing banking products and services, otherwise available through branches.
The ABA acknowledges positive comments on accessibility, usability and levels of service with telephone and Internet banking made by HREOC.
Recognising the importance of accessibility initiatives that leverage technology to deliver financial products and services to everybody, the ABA and HREOC will continue to work together on anticipating needs and possible solutions regarding emerging technologies, online banking strategies and accessibility for people with a disability. The ABA notes HREOC interest in developments with smart card infrastructure.
The following section provides comments from individual member banks on HREOC’s review of progress with electronic financial services. Comments have been included from the four major banks and other member banks.
Given that developments are happening at different rates across the various ABA member banks, information contained in this report aims to provide simply a snapshot. Comments relate to progress on implementation of the voluntary Industry Standards on ATMs, EFTPOS, telephone and Internet banking.
The ABA and the banking industry acknowledge that broader issues with accessibility for older people and people with a disability fall outside the core standards. Nevertheless, DAPs by the major member banks include initiatives aimed at physical access to branches, security and education of disability related matters.
Following the introduction of the voluntary Industry Standards, the major member banks developed and/or revised their DAPs. Many of the initiatives contained within the DAPs respond to concerns expressed by HREOC in its “Accessibility of Electronic Commerce and New Service and Information Technologies for Older Australians and People with a Disability” (March 2000).
DAPs provide an opportunity for the banking industry to consolidate their policies, procedures and practices relating to access to banking products and services for people with a disability. In addition, it provides an ongoing framework for improving access to banking products and services, and a basis for discussion with community groups on improving accessibility for people with a disability.
For some time the banking industry has been improving accessibility. Past initiatives have focused on improving physical access to branches. For example, branch access (for new premises) is designed to conform to Australian design standards for people with a disability, such as wheelchair access, automated doors, signage, lighting, colour schemes, queuing systems and teller access. In addition, as far as possible, refurbishing programs apply design standards to existing premises.
Banks have considered structural limitations and have sought to implement alternative options for people with a disability. For example, occupational health and safety requirements determine height of teller counters, but this may not provide comfortable access for persons in wheelchairs. In response, some branches have installed alternative teller services for people with a disability, including low height writing counters with wide access for wheelchairs. One major bank reported that ParaQuad NSW was invited to participate in a trial and provide feedback to inform further initiatives.
In addition, some banks offer their customers the opportunity to receive documents (e.g. account statements) with features designed to enhance usability by people with a disability (e.g. large print, audio tape or braille).
Electronic financial services offer the opportunity to expand the range of banking products and services available to people with a disability, and therefore the DAPs have a particular focus on initiatives for improving accessibility for ATMs, EFTPOS, telephone and Internet banking, consistent with the voluntary Industry Standards.
As part of the DAP process, banks have conducted audits of product distribution channels and customer access points and identified where products and services could be improved for people with a disability.
Current DAPs of the major ABA member banks:
The DAPs of the major banks are all available on the individual banks’ public website. Accessibility initiatives of other member banks are contained in equivalent corporate policies and procedures and are included in strategies for improving stakeholder engagement.
Banks have made significant improvements to accessibility of information about customer commitment and disability related matters. Following initial feedback from HREOC, the major banks have assessed accessibility of information about their current programs aimed at improving accessibility to banking products and services by people with a disability. For example, ‘3-clicks’ standards generally apply to DAPs and associated stakeholder and community information9.
The ABA and the banking industry are strongly committed to ensuring the accessibility of banking products and services for all Australians. For example, banks have outlined strategies for ensuring that all customers have at least two points of access to banking services.
However, the ABA acknowledges comments by HREOC that suggest further awareness of the voluntary Industry Standards is needed. There are opportunities to enhance communication with stakeholders and promote community awareness of both the voluntary Industry Standards and progress against initiatives contained in individual banks’ DAPs.
Some examples of important initiatives that are contained within DAPs include:
Initiatives aimed at raising awareness of the community of the voluntary Industry Standards should:
Improvements in awareness of the voluntary Industry Standards and DAPs would:
In relation to ATMs, while significant progress has been made on improving accessibility to ATMs for people with a disability over recent years, further improvements could be made to ensure ease of use of all existing and new ATMs.
One of the challenges for the banking industry in relation to accessibility of ATMs is that as there is no ATM manufacturer in Australia; ATM facilities are limited by design standards in the United States. US manufactured ATMs are designed to meet disability and accessibility standards in accordance with the Americans with Disabilities ACT 1990.
Nevertheless, the commitment by the Australian banking industry to improving accessibility to ATMs is demonstrated by satisfying the Priority 1 components of the voluntary Industry Standards in the installation of all new ATMs. In addition, existing ATMs are subject to upgrade plans to ensure the replacement ATMs meet the Priority 1 components.
Promoting accessibility to self service facilities is essential for supporting the financial independence of people with a disability. ABA member banks report they have commenced ATM upgrade programs.
Since September 2004, a major bank has provided audio-capability at a further 218 ATMs and installed enhanced frontal access ATMs at a further 34 locations. This major bank now has 265 audio-enabled ATMs and 49 enhanced frontal access ATMs installed. Further ATM installations planned as part of its ATM investment program will seek to upgrade 3,000 ATMs over the next 5 years.
Another bank reports that it has replaced 95 of its 255 ATMs with the new enhanced ATMs. In addition, the bank has purchased and scheduled for replacement over the next 4–6 months a further 40 new enhanced ATMs for the network.
Another major bank reports that considerable progress has been made in ensuring that their ATMs meet the voluntary Industry Standard:
This same bank reports that it has also been compliant with the Crime Prevention Victoria ATM site assessment guidelines since June 2003.
Another bank reports that approximately 210
ATMs across city and regional locations have been audio-enabled. The bank aims
to provide audio output to approximately 80% of its ATM network by December
2006. In addition, all new ATMs provide colour contrast and identification,
sunlight viewable screens and tactile keypads.
Another major bank indicates it commenced a trial program of 10 audio-enabled
ATMs in January 2003, resulting in additional audio-enabled ATMs. The bank
continues to install new audio-enabled ATMs and upgrade existing ATMs as part of
its upgrade plan.
Another major bank reports that it has commenced its “Access Friendly ATMs” installation program, with 10 ATMs modified by December 2004. Further modifications scheduled over the next 2 years (75 ATMs by December 2005; 150 ATMs by December 2006). An audit of technology software and hardware is scheduled as part of the installation program.
ABA member banks also maintain comprehensive information about location and access features: for example, lists that contain locations of disabled access branches and audio-enabled ATMs. In addition, search locators on the website highlight disabled access facilities.
All DAPs contain accessibility initiatives to ensure that access to ATMs by people with a disability remains a priority outcome. For example, implementation reviews against the voluntary Industry Standards include:
Improvements to accessibility of ATMs for people with a disability aim to:
In relation to EFTPOS, ABA member banks are pleased to report the increased penetration of EFTPOS terminals allowing persons with disabilities greater access to banking services. However further improvements could be made to ensure broader access to EFTPOS for banking customers.
One major bank reports it is fully compliant with Priority 1 components for all its EFTPOS terminals. Current upgrades in relation to Priority 2 components include high contrast symbols; improved ‘dip’ readers; clear swipe direction symbols; bevelled opening for card swiping; and colour variations for function keys. As part of the same banks’ ongoing EFTPOS investment program, approximately 127,000 EFTPOS terminals will be upgraded over the next 5 years to include increased character size, increased key spacing, and exaggerated tactile key functions.
Another major bank reports it is fully compliant with the voluntary Industry Standards, with the exception of audio-enablement for EFTPOS devices. Other member banks also report similar levels of compliance.
A challenge for the banking industry with accessibility improvements to EFTPOS terminals is currently twofold: (1) the technology limitations with providing audio-enablement, and (2) the substantial number of EFTPOS devices within the network that are not bank-owned. Nevertheless, EFTPOS improvement programs are generally being implemented along with upgrades to other self service facilities, such as ATMs.
Improvements to accessibility of EFTPOS for people with a disability aim to:
In relation to telephone banking, the banking industry has been making continual improvements to meet the needs of all customers, including people with a disability. Progress with automated telephone banking services indicates that the banking industry is generally compliant with Priority 1 components.
Customer support facilities to assist people with a disability are generally available either 24 hours a day, 7 days a week or 8am – 8pm, Monday to Friday (AEST), depending on the bank. For example, Interactive Voice Response (IVR) services and/or Telephone Typewriter (TTY) operator assisted service may be provided 24 hours a day, 7 days a week or during standard customer support service times. In addition, people with a disability having difficulty navigating or comprehending the facility are given the opportunity to conduct their banking with a bank operator, without financial penalty.
One bank reports compliance with Priority 1 components, with the following exceptions:
The banking industry is also working towards consistent delivery of additional support services including:
In relation to the National Relay Service, some banks already have in place arrangements for customers to work with the bank operator via the National Relay Service. Other banks indicate that where such services are not currently available, projects have commenced to ensure that customers with a disability who require assistance of the National Relay Service will be able to contact the bank and conduct their banking securely via that service.
Improvements to accessibility of telephone banking for people with a disability aim to:
In relation to Internet banking, the banking industry recognises the substantial opportunity to leverage technology to deliver easy and convenient financial products and services to people with a disability. Some accessibility improvements may however depend on customers maintaining customised software or hardware. The banking industry is nevertheless committed to improving Internet banking services for all customers.
Many banks have commenced or have completed projects for improving their Internet banking facilities, with a particular focus on making usability better for people with a disability, but also providing all customers with efficient and effective banking products and services.
Information technology (IT) investment or upgrade programs include:
Banks have made improvements to information structure, search functionality and web-capabilities of both the bank website and Internet banking service.
A major bank reports that it is already fully compliant with the voluntary Industry Standards. Other banks indicate they maintain a continuous program of improvement, introducing alternative search functions, text only equivalents and alternative web-browser options to accommodate different download capabilities.
Another major bank reports it is currently “retro-fitting” high usage webpages. The bank has also implemented internal design parameters and standards that meet the voluntary Industry Standards and the W3C/WAI web content accessibility guidelines. IT staff are trained on website development and accessibility issues (e.g. not designing animated gifs or “flickering” text or imagery) and testing standards adhere to accessibility criteria. Design standards apply to all parts of the website, including Internet banking.
Another major bank reports that it has two projects currently under way to improve accessibility for customers using screen reading software. The first project is to provide easily accessible navigation within the existing website so screen reading software can read the website logically. The second project is to place encoded messages on the website, only detectable to automated screen readers, which advise customers to call the customer support service if difficulties are incurred.
Furthermore, specific problems identified by the same bank’s “Accessible Information Solutions Australia Review” conducted in 2003 have largely been addressed. The accessibility review of the Internet banking sections of the existing website highlighted some meta-data problems, which have been rectified in 2004, including ensuring:
Additional functionality has been added permitting log-in capabilities without using a mouse, allowing minimal keystrokes for transactions and making available interactive demonstrations of services and online tutorials.
Another major bank reports that it has completed an initial upgrade of its website, including improved navigation to information particularly relevant for people with a disability, including access to the DAP and a branch/ATM search locator listing all audio-enabled ATMs.
Another bank reports that it has completed upgrades aimed at improvements for visually impaired persons, with further upgrades for hearing impaired persons scheduled for the next 6-12 months (e.g. captioning of audio streaming and video clips).
Another bank reports that it has tested all parts of the website for colour-blindness accessibility, with positive results. In addition, the bank will be introducing a variable font size capability for sight impaired customers as well as improving the navigation for locating branch/ATM information for people with a disability.
Some banks have indicated that progress with Priority 3 components has been delayed pending additional consumer testing of recommendations to ensure benefits for customers with a disability. Furthermore, recognising that technology advances are rapid, some banks have determined to await the release of the updated W3C/WAI web content accessibility guidelines before conducting an evaluation. This will result in assessments and modifications being made against the most current standards to take account of emerging disability concerns and current international practice10.
In addition to online facilities, the banks also operate customer support facilities to assist people with a disability, generally available either 24 hours a day, 7 days a week or 8am – 8pm, Monday to Friday (AEST), depending on the bank.
Some banks already have in place arrangements for customers to work with the bank operator via the National Relay Service. Other banks indicate that where such services are not currently available, projects have commenced to ensure that customers with a disability who require assistance of the National Relay Service will be able to contact the bank and conduct their banking securely via that service. A bank also reports it has shifted it TTY facilities to its IT support centre to accommodate extended hours of operation.
Improvements to accessibility of Internet banking for people with a disability aim to:
Under section 61(e) of the Disability Discrimination Act, a DAP must contain provisions for evaluating policies and strategies aimed at eliminating discrimination. Measuring effectiveness of DAPs will ensure the transparency and accountability of governance and process.
Banks report that they distinguish between
progress reporting against the targets contained in DAPs and periodic review of
the plans themselves.
Banks generally have conducted an annual assessment of DAPs to review the
appropriateness of the plan. This takes into consideration any emerging
concerns, industry developments (e.g. technology advances, new financial
products and services, other changes to the external setting, i.e.
legislative/regulatory impacts) and international best practice. Banks generally
have included a 6 monthly review of achievements in their DAPs.
Banks have been working closely with the disability community to ensure they continue to provide improved accessibility for older people and people with a disability. Recently, in November 2004 a major bank was awarded an “Accessibility Award” by a local Council as a result of improvements made to branch accessibility.
The ABA and its member banks are grateful for the continuing opportunity to work with HREOC and the community on delivering improved banking products and services, especially for older persons and people with a disability, and are committed to delivering enhanced benefits to all Australians.
1 The voluntary Industry Standards are available on the ABA website at http://www.bankers.asn.au.
2 The Disability Discrimination Act 1992
defines disability in relation to a person as:
(a) total or partial loss of the person's bodily or mental functions; or
(b) total or partial loss of a part of the body; or
(c) the presence in the body of organisms causing disease or illness; or
(d) the presence in the body of organisms capable of causing disease or illness;
or
(e) the malfunction, malformation or disfigurement of a part of the person's
body; or
(f) a disorder or malfunction that results in the person learning differently
from a person without the disorder or malfunction; or
(g) a disorder, illness or disease that affects a person's thought processes,
perception of reality, emotions or judgment or that results in disturbed
behaviour;
and includes a disability that:
(h) presently exists; or
(i) previously existed but no longer exists; or
(j) may exist in the future; or
(k) is imputed to a person.
3 Australian Bureau of Statistics (ABS). Disability, Ageing and Carers,
Australia: Summary of Findings. [4430.0] 15 September 2004.
http://www.abs.gov.au/
4 http://ausweb.scu.edu.au/aw04/papers/refereed/celic/paper.html This survey examined the home page only of the websites of ANZ Bank, CBA, NAB, Westpac, BankWest, Bendigo Bank, St George Bank and Suncorp as at December 2003. The ABA notes that as this examination was conducted shortly after most banks concluded comprehensive reviews following the introduction of the voluntary Industry Standards, significant progress has been made since the completion of the survey. The ABA does not warrant the reliability of this survey.
5 http://www.anz.com.au/Documents/AU/Aboutanz/20021129_Disability_Action_Plan.pdf
6 http://about.commbank.com.au/group_display/0,1922,CH2142,00.html
7 http://www.national.com.au/About_Us/0,,53213,00.html (NAB’s DAP was initially released in 1997.)
8 http://www.westpac.com.au/internet/publish.nsf/b813d03d529183daca256c9300092759/$file/dda_plan2004.pdf (Westpac’s DAP was initially released in 2001.)
9 Website development rule of thumb: whatever a user is searching for should never be more than 3 clicks away from the home page. The “3 click rule” is a standard for all users, not only people with a disability.
10 A working draft of the “Web Content Accessibility Guidelines” was discussed at a working group meeting held in June 2005.
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