Accessibility of Electronic Banking: Progress Report 2006

December 2006

1. Introduction

The Australian Bureau of Statistics (ABS) estimates that 20% of Australia's population (or approximately 4 million people) have a recognised and ongoing disability. An even larger proportion of the population may have general reduced ability associated with age.

In 2001 the Australian banking industry lodged an Industry Action Plan with the Human Rights and Equal Opportunity Commission (HREOC). The 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.

In 2002 the Australian Bankers' Association (ABA), in collaboration with the disability community¹, produced voluntary Industry Standards which aim to improve the accessibility of electronic banking: Automated Teller Machines (ATMs), Electronic Funds Transfer at the Point of Sale (EFTPOS), telephone and Internet banking².

The voluntary Industry Standards are important steps in helping overcome the 'digital divide' and will assist individual banks develop or enhance their electronic banking services for people with disabilities and older people.

This report provides specific examples of progress against particular initiatives as contained in individual banks' Disability Action Plans (DAPs) and other banking industry service commitments and eBanking practices. This 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 banking and financial services.

2. Legal obligations and disability action plans

2.1 Disability Discrimination Act

The Disability Discrimination Act 1992 ("DDA") makes it unlawful to discriminate against a person on the grounds of a disability³. 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 law is administered by 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, services⁴ and facilities.

An organisation that provides such services is liable for complaint if those services are not accessible to people with disabilities.

However, the DDA recognises 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 HREOC 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 Court who have the authority to determine whether unlawful discrimination has occurred and what constitutes 'unjustifiable hardship'.

HREOC also has a role in assisting organisations understand their responsibilities and supporting initiatives aimed at promoting compliance through best practice. For example, HREOC supported the ABA producing the voluntary Industry Standards, and even though the standards do not have the force of law, they were developed in the hope that they would provide a level of access consistent with the requirements of the DDA.

2.2 Disability Action Plans (DAPs)

The basis for the banking industry's action plans for improving accessibility is the DDA and State and Territory anti-discrimination laws, as well as the voluntary Industry Standards.

Following the introduction of the voluntary Industry Standards, the major ABA member banks developed and/or revised their Disability Action Plans (DAPs).

Current DAPs of the major ABA member banks:

• ANZ, September 2002⁵
• Commonwealth Bank, July 2004⁶
• NAB, September 2006⁷
• Westpac, December 2006⁸

In addition, a number of other member banks are currently looking to introduce a DAP or customer service guidelines for people with disabilities.

Suncorp is currently developing a DAP and envisages introducing this in 2007 to complement its existing disability service commitments. St George is about to release its customer service policy and guidelines for hard of hearing and deaf customers. The bank is also working on similar guidelines for visually impaired customers and customers with intellectual disabilities.

These service commitments generally complement individual governance approaches to stakeholder engagement, such as customer service charters, principles for doing business, community banking programs or social responsibility and disability practice indicators.

Banks that do not maintain DAPs have demonstrated a commitment to participate in supporting the voluntary Industry Standards through incorporating elements into their eBanking product development. Banks also have internal policies relating to staff and customers with disabilities that are aligned to the voluntary Industry Standards. For example, some member banks maintain Statements of Commitment to customers with a disability and older customers, as required by the Code of Banking Practice⁹.

Success of DAPs and other disability programs will be measured by:

• Reduction/absence of customer complaints about disability access;
• Positive customer feedback on the suitability of access for people with disabilities and older people to Internet banking, telephone banking, ATM and EFTPOS facilities; and
• No discrimination complaints are made by people with disabilities.

3. Progress with the voluntary Industry Standards

The banking industry has made a commitment to develop and implement strategies and initiatives to ensure that banking products and financial services are accessible for all Australians.

There are a number of channels for customers to access their retail banking needs - via branches, over the telephone or Internet, using ATMs or EFTPOS terminals and BPAY. Commitments contained in the 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.

3.1 Adoption of the voluntary Industry Standards

The ABA and the banking industry are strongly committed to ensuring the accessibility of banking products and services for all Australians. Member banks recognise that a customer's disability should not act as a barrier to having equitable access to their products and services. For example, banks have outlined strategies for ensuring that all customers have at least two points of access to banking services and that communications are available in variable formats to cater for different customer needs.

Furthermore, member banks have commitments to achieve key outcomes for people with disabilities and older people, such as:

• Maximising technology developments to expand accessibility for retail banking;
• Removing barriers to banking and financial services through revising policies and procedures; and
• Improving customer service standards by raising staff awareness of the accessibility needs of their customers.

There has been widespread adoption by the banking industry of the voluntary Industry Standards. The ABA and its member banks welcome the opportunity to work with HREOC and the disability community on the development of new initiatives to enhance the DAPs and address particular accessibility priorities.

The ABA and member banks acknowledge that there are accessibility issues for people with disabilities and older people that fall outside the voluntary Industry Standards. Electronic financial services offer the opportunity to expand the range of banking products and services available to people with disabilities and older people, 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.

Notwithstanding, the major member banks have included initiatives aimed at physical access to branches, security, education and employment in their DAPs. For example, a number of banks have commitments to achieve key outcomes for people with disabilities and older people, including addressing accessibility of premises, facilities and services as well as ensuring equitable employment opportunities for people with disabilities.

3.2 Review of the voluntary Industry Standards

As implementation strategies continue to be progressed, the ABA does not consider that it is necessary to conduct an independent examination of the voluntary Industry Standards at this stage. All major banks are currently reviewing or revising their DAPs based on thorough internal and external assessments.

For example, ANZ conducted an internal review of their DAP in December 2004, and an external review was commissioned in May 2005. Following, the consultants were engaged to workshop the revised DAP with various internal stakeholder groups, advising on strategy and initiatives, including external stakeholder engagement activities, to assist with effective implementation.

Commonwealth Bank has reviewed their DAP and is in the process of having it internally signed off before publishing it on their website. It is expected that their DAP will be updated at least annually.

NAB has also recently undertaken a review of their DAP. As a result of the review, NAB has, amongst other things, introduced a dedicated 1300 number for customers with disabilities and older customers so they can obtain more information about their banking products and services.

Westpac has recently released a new DAP, now referred to as its Accessibility Action Plan. The new plan was developed through extensive internal and external consultation. As a result of the review, Westpac is, amongst other things, improving its communication strategies with customers and employees with a disability.

Other member banks have also been working with HREOC and groups representing people with disabilities in implementing policies for customers with disabilities and older customers.

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 and member banks will continue to work with HREOC to identify emerging concerns from the disability community.

3.3 Capability building and the voluntary Industry Standards

ABA member banks are implementing DAPs and other disability programs as priorities within their retail banking service delivery. Specific capability building amongst banking staff includes:

• Staff communication: Raising awareness of, and lifting the commitment to, the needs of customers with disabilities by providing information on current functionality and new or upgraded functionality as it is introduced.
• Staff awareness: Incorporating awareness training on service for customers with disabilities for relevant staff (branch and call centre customer service) in order to improve the customer experience for customers with disabilities.
• Staff recruitment: Reviewing current HR policy/practices to ensure applicants with disabilities have opportunities for employment and employees with disabilities have opportunities for promotion.

3.4 Technology developments and the voluntary Industry Standards

The ABA acknowledges positive comments on accessibility, usability, availability and levels of service with electronic banking made by HREOC.

Recognising the importance of accessibility initiatives that leverage technology to deliver financial products and services to everybody, the ABA will continue to work with HREOC and the disability sector on anticipating needs and possible solutions regarding emerging technologies, online banking strategies and accessibility for people with disabilities and older people. The ABA notes that HREOC has a particular interest in authentication and smart card technologies. (For further details, see section 5.)

4. Update on accessibility priorities

The 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 disabilities and older people. In addition, it provides an ongoing framework for improving access to banking products and other financial services, and a basis for discussion with community groups on improving accessibility for people with disabilities and older people.

Banks have in place programs for continuous improvement with accessibility for people with disabilities and older people. For example, as part of the DAP process, banks have conducted reviews of product distribution channels and customer access points and identified where products and services could be improved for people with disabilities and older people.

The DAPs of the major banks are all available on the individual banks' website. Accessibility initiatives of other member banks are contained in equivalent customer service policies and procedures and are included in strategies for improving stakeholder engagement.

Last year HREOC suggested that further staff and community awareness of the voluntary Industry Standards, and broader accessibility of banking, was needed. In response, a number of member banks have included additional information on improvements with accessibility in their communications with shareholders and other stakeholders, including annual reports, stakeholder impact reports and/or CSR reports; revamped availability of information on accessible banking on their websites for all customers; and released information via their intranets to raise staff awareness of the accessibility needs of their customers.

The banking industry will continue to promote community and staff awareness of both the voluntary Industry Standards and progress against initiatives contained in individual banks' DAPs.

The following provides a snapshot of progress on implementation of the voluntary Industry Standards on ATMs, EFTPOS, telephone and Internet banking.

4.1 ATMs

A challenge with for the banking industry with accessibility improvements to ATMs is that ATM hardware is designed and manufactured overseas generally to meet international requirements. This is a constraint to fully meeting the voluntary Industry Standards. Nevertheless, there has been significant progress over the past year with enhancements to ATMs and improvements to accessibility of ATMs for people with a disability. As a minimum, member banks ATM installation programs ensure new ATMs meet Priority 1 components of the voluntary Industry Standards.

A major bank reports it has 380 audio-enabled ATMs and 72 enhanced frontal access ATMs installed. This bank continues its ATM installation program with a view to upgrading its entire fleet of 3,200 ATMs by 2010.

Another major bank indicates that it meets a majority of standards for ATM accessibility. The bank meets 22 out of 29 Priority 1 standards, 14 out of the 27 Priority 2 standards and 1 out of the 4 priority 3 standards. Those outstanding are being addressed as part of the bank's current upgrade and installation program. Currently, this bank reports that of its fleet of 1,800 ATMs, approximately 80% has audio capability for all transaction types.

Another major bank indicates that as part of its "Access Friendly ATMs" installation program, it has about 186 fully audio-enabled ATMs throughout Australia. A further 133 ATMs are capable of being audio-enabled subject to a software refit, and this is planned for completion by June 2007. Since 2005 all new ATMs rolled out as part of the bank's ongoing replacement program or its expansion program have been fully audio-enabled. This means that by December 2007, the bank will have about 500 audio-enabled ATMs.

In addition, about 86% of its fleet is compliant with the Australian Building Code standard (AS 3769) for accessibility and around 80% comply with the voluntary Industry Standards. The bank also tracks sites that are non-compliant (for example, they may be in heritage buildings or subject to council approvals or landlords' consent) and actively seeks to reduce these sites.

Another major bank reports that currently 88% of its fleet of 1,300 ATMs are audio-enabled. Its upgrade program has been underway for some years, with automatic upgrades on ATMs when they are replaced and conversion of existing ATMs where technology permits. While the bank previously committed 100% by the end of 2006, this will now be achieved by February 2007.

Another bank indicates that approximately 680 ATMs across city and regional locations have been audio-enabled. This bank has a fleet of 876 ATMs, and is on track to meet its commitment to provide audio capability for approximately 80% of its ATM network by December 2006. All new ATMs have tactile keyboards and sunlight viewable screens. The same bank has also adopted consistent branding of the ATM fleet, providing colour contrast and identification for visually impaired customers. With regard to physical access, the bank has located receipt bins to the side of its ATMs so as to maximise customer access to the ATM/customer interface. Customer feedback indicates improvements in ATM accessibility levels, particularly wheelchair access.

Another bank reports that its ATM fleet has undergone a significant upgrade over recent years, in particular all new proposed sites are assessed to ensure that the final ATM position is easily assessable by people with wheelchairs and other customers with a disability. The same bank reports that following discussions with the Royal Society for the Blind, monochrome ATM screens were replaced with high definition colour screens in all ATMs. No ATMs are fitted with audio jacks or are voice-enabled at this time.

Another bank indicates that it is currently in the process of reviewing its ATM network to enable greater effectiveness of hearing devices. The review has been driven by customer feedback about product and service improvement and the results of the review will feature in the bank's DAP.

Member banks maintain comprehensive information about location and access features for ATMs, including lists of audio-enabled ATMs and locations of branches with disabled access. Some member banks also maintain search locators on their website to assist customers locate disabled access facilities.

ATM accessibility improvement initiatives include:

• Ease of use of ATMs (including keypad size and height, text/font display, screen quality, consistency of functionality);
• Functionality of ATMs (including tactile keypads, card swipe operations and funds retrieval);Access and location of ATMs (including height and design of ATMs as well as security and privacy); and
• Installation and maintenance of ATMs (including consistent design standards, i.e. similar 'look and feel' for bank branded ATMs to assist visually impaired customers; deployment/operation of ATMs, i.e. ATM enhancements to existing fleet).

Actions: Member banks to continue to improve accessibility and include information in communications with the public. Measures include:

• Where adopted, report against compliance with the voluntary Industry Standards;
• Work towards developing standards for design, deployment and operation of ATMs;
• Increase staff and customer confidence in the bank's ability to deal with people with disabilities and older people;
• Reduce customer complaints about ATM accessibility by customers with a disability and older customers; and
• Promote awareness of ATM accessibility.

4.2 EFTPOS

A challenge for the banking industry with accessibility improvements to EFTPOS terminals is due to the limitations with the size and functionality of the device.

In addition to technology limitations, a significant number of EFTPOS terminals within the network are not bank-owned. Nevertheless, EFTPOS improvements are being implemented along with upgrades to other self service facilities, such as ATMs.

A major bank reports that it is progressing with its plan to improve its EFTPOS facilities. Multipos, which covers 90% of the banks' EFTPOS base, meets the requirements of 5 out of the 8 Priority 1 standards and 24 out of the 30 Priority 2 standards. An audio jack for EFTPOS terminals is not being considered due to device limitations. Furthermore, EFTPOS terminals are attended; therefore there is someone available to help customers that may require assistance. However, this same bank is exploring EFTPOS terminals that can be operable with one hand, therefore not requiring tight grasping or twisting of the wrist by the user.

Another major bank reports it is fully compliant with the voluntary Industry Standards, with the exception of audio-enablement for EFTPOS terminals.

Other member banks also report similar levels of compliance with accessibility and security standards.

Another bank is introducing new EFTPOS terminals with backlit displays and large display screens, enabling functions on the terminals to be more easily read by customers, especially those customers that have vision impairments.

A number of banks have outsourced their EFTPOS terminals to, for example, Cashcard. Cashcard have advised the banks that they comply with the voluntary Industry Standards.

Actions: Member banks to continue to improve accessibility and include information in communications with the public. Measures include:

• Where adopted, report against compliance with the voluntary Industry Standards;
• Work towards developing standards for design, deployment and operation of EFTPOS terminals;
• Increase staff and customer confidence in banks' abilities to deal with people with a disability and older people;
• Reduce customer complaints about EFTPOS accessibility by customers with a disability or older customers; and
• Promote awareness of EFTPOS accessibility.

4.3 Telephone banking

The banking industry has been making continuous improvements to meet the needs of customers with a disability and older customers. Progress with automated telephone banking services indicates that the banking industry is generally compliant with Priority 1 components.

A major bank reports that it meets all Priority 1, 2, and 3 standards, with the exception of 6 priorities. The only Priority 1 standard not met is in relation to IVR deployers making available descriptions of transaction steps for automated telephone banking services on request. In order to partially meet this requirement, the bank is compliant with the Priority 2 standard requiring online context-sensitive assistance. This bank has made telephone type-writer (TTY) available 24 hours a day, 7 days a week, with the National Relay Service available to provide support. This bank is also currently implementing a staff education program for customer service staff to learn about the use of the National Relay Service to facilitate calls with deaf, hearing and speech impaired customers.

Another major bank reports that TTY is available for hearing and speech impaired customers via its main call centre number and freecall number between 8am and 8pm. This service covers all the services of telephone banking.

Another major bank indicates that TTY is available during customer contact centre operating hours, being 9am-5pm. This bank indicates that priority is given to TTY calls. The National Relay Service is also utilised by hearing impaired customers who are already been pre-authenticated users or people requesting general information.

Another major bank reports that its customers can access telephone banking in two different ways. A self-service Voice Response Unit enables customers to obtain account details, transfer funds, make credit card and bill payments using a touch-tone telephone. Alternatively, customers can speak to a customer relations consultant to order statements and cheque books, obtain product and interest rate information, change their personal details or register for Internet banking or obtain assistance with specific problems. Customers can also use the National Relay Service. This service is available 24 hours a day, 7 days per week.

A bank reports that they completely replaced their telephone banking service in 2003, and the voluntary Industry Standards were adopted as core functionality. Call centre staff can communicate with hearing or speech impaired customers with the help of the National Relay Service. The new telephone banking service can cater for many user orientated devices and provides a platform for Natural Voice Recognition technologies if deemed appropriate in the future. This bank also provides an email facility for customers to communicate directly with relevant staff for their inquiry.

Another bank reports that it uses the services of the National Relay Service to assist its hearing impaired customers via its call centre networks.

Use of the service is detailed in staff training packages and is available to staff over their intranet.

Actions: Member banks to continue to improve accessibility and include information in communications with the public. Measures include:

• Where adopted, report against compliance with the voluntary Industry Standards;
• Increase staff and customer confidence in banks' abilities to deal with people with a disability and older people;
• Reduce complaints or issues regarding telephone banking accessibility by older customers or customers with a disability; and
• Promote awareness of telephone banking accessibility.

4.4 Internet banking

Internet banking provides opportunities for the banking industry to leverage technology to offer wider accessibility to banking products and services for all customers, including customers with a disability and older customers who may find it difficult to access their banking using the branch network. However, some accessibility improvements may depend on customers maintaining customised hardware or software and therefore may not be completely addressed through website development solutions.

Nevertheless, the banking industry is committed to improving Internet banking for all customers. Internet banking upgrade programs include development and implementation activities targeting high usage web pages. User testing involves representation from a wider range of users, including people with disabilities and older people, to make sure that specific disability issues are taken into consideration with Internet banking enhancements. User testing has resulted in improvements being made to website structure, functionality, readability and search capabilities for both Internet banking and website services.

An emerging challenge is the use of authentication technologies. (For further information, see section 5.)

A major bank reports that it currently has a major project underway to redesign their Internet banking and bank website. Internet banking system developments will be trialled by people with varying disabilities prior to implementation. As part of this project, the bank will be reviewing the availability of content about accessibility of banking products and services. Notwithstanding, the bank's current Internet banking service complies with the W3C/WAI guidelines.

Another major bank reports that they are fully compliant with the voluntary Industry Standards and W3C/WAI guidelines.

Another major bank indicates that it has improved accessibility of its Internet banking website by ensuring that high usage web pages have been retro-fitted for accessibility as they are replaced with new content updates. Robust development and testing standards ensure that any online developments and new web pages are fully compliant with the voluntary Industry Standards and W3C/WAI guidelines. In addition to providing training on accessibility issues and best practice web page design to employees involved in development and management of web pages, testing standards have been revised to incorporate use of assistive technologies, such as screen readers.

Another major bank indicates that it is currently conducting trials of its Internet banking website with assistance from people with varying and diverse disabilities to ensure changes in technology maintain and improve accessibility for customers with disabilities.

A bank reports that it continues to maintain an HTML-based Internet banking website that complies with the W3C/WAI guidelines, and is usable by a majority of text-to-speech readers. The bank is currently migrating all of its customers to this Internet banking platform.

A bank reports that its Internet banking service was completely replaced in June 2004, and the voluntary Industry Standards were adopted as core functionality from the service supplier. The online application is browser independent and can be viewed and used via many software applications designed to assist visually impaired customers. This same bank has also introduced 2nd factor security authentication for Internet banking services; as part of this implementation it offers devices with larger security code digits and voice output to customers with visual or dexterity impairments.

Other member banks indicate they maintain continuous programs for improving their Internet banking services, including introducing alternative search functions, text only equivalents and alternative web-browser options to accommodate different download capabilities.

Actions: Member banks to continue to improve accessibility and include information in communications with the public. Measures include:

• Where adopted, report against compliance with the voluntary Industry Standards and the W3C/WAI guidelines;
• Increase community confidence in banks' abilities to deal with customers with a disability;
• Reduce customer complaints about Internet banking accessibility; and
• Promote awareness of Internet banking accessibility.

4.5 Complaints about accessibility to banking products and services

The ABA notes that generally complaints regarding accessibility for people with disabilities are decreasing. A number of member banks indicate that they have not received any complaints from customers or non-customers about accessibility to electronic banking. Others indicate that of complaints received, they are minor and are addressed within current programs and approaches. While others indicate they have received a few complaints regarding accessibility to premises and facilities. Some banks indicated that they may receive minor complaints at the branch level which are resolved without necessarily being referred through a formal complaints mechanism.

For example, a major bank reports that it has received 9 complaints relating to accessibility for the 12 month period October 2004 - September 2005.

The breakdown of these complaints:

• 6 complaints related to design of branches;
• 1 complaint related to a customer being charged staff assisted transaction fees despite not being able to use EFTPOS/ATMs;
• 1 complaint related to a hearing impaired customer being referred to a phone number for help with a query; and
• 1 customer queried the availability of over-sized print statements.

Such complaints are addressed on a case-by-case basis and become the precedent for dealing with similar future complaints. Some complaints become the catalyst for procedural changes on a corporate group wide basis.

Another major bank indicates that it has received 12 complaints relating to accessibility for the 2 year period November 2004 to November 2006.

The breakdown of these complaints:

• 7 complaints related to physical access to premises or ATM;
• 2 complaints related to the need for chairs while queuing;
• 1 complaint related to ATM requiring audio facilities;
• 1 complaint related to lack of information for people with a disability; and
• 1 complaint related to the authentication process for a new keycard.

Complaints are addressed on a product/service basis. This bank notes that the decrease in complaints over the past year may be the result of greater progress with implementing the actions in their DAP.

Another bank reports that its customer complaint area has received 12 complaints relating to accessibility during the year to December 2006. Six of these complaints related to location and accessibility of banking services; for example the lack of disabled parking spots outside a branch; and a further 2 complaints related to branch layout. These complaints are addressed on a case-by-case basis, although may become a catalyst for wider change if appropriate.

Another bank indicates that it has encountered some issues with regards to premises that it leases, rather than owns. The bank is managing these issues in cooperation with the building owner.

4.6 Monitoring and evaluation of accessibility initiatives

Under section 61(e) of the DDA, a DAP must contain provisions for evaluating policies and strategies aimed at eliminating discrimination.

Banks generally have conducted an annual assessment of DAPs to review the effectiveness and appropriateness of their plans. The assessment generally takes into consideration emerging customer and business concerns, advances in technology, industry developments (i.e. new financial products and services), legislative/regulatory changes, and international best practice. Banks generally have included a six monthly review of achievements in their plans. These reviews result in action by the banks to improve accessibility for customers and employees with disabilities.

For example, a major bank indicates that contained in their new two-year plan there is a commitment to review and report internally every six months and externally every year. The plan places increased importance on communication, including a new awareness training program to be completed by all employees by February 2007, captioning its high-end videos, and providing Auslan interpreter services and an Auslan webcast at its annual general meeting. Other initiatives in the plan cover a broad range of activities to help meet the needs of customers and employees with a disability. For example, new branches will have a queuing system with audio and visual prompts and, for the first time, the bank is providing mental health awareness training for its managers.

Another major bank indicates that as part of its recent review of their DAP, with a view to updating their DAP, they conducted both internal and external evaluations of their accessibility commitments and programs as contained in their existing DAP. This same bank also reports that as a consequence of its recent assessment involving staff and customers, the bank will introduce a disability support network. The network will involve hosting a meeting each month for staff with a disability and colleagues to gain an improved understanding of bank initiatives, infrastructure and support that is available to assist people with a disability. The network is also a forum for staff with a disability or staff who have close contact with a person with a disability to discuss the issues and challenges they may face with their day-to-day work activities.

Another major bank has made a commitment to undertake an ongoing review of their DAP at six and twelve month intervals. To do this a dedicated resource has been appointed to maintain and coordinate this area. As a consequence of the appointment, a recent review has identified a shortfall for customers that have a print disability. The bank is now working on improvements and anticipates revised services by early February 2007.

Another major bank reports that since it launched its first DAP, disability issues have been incorporated into their Induction Program for all staff. This same bank also reports that it is working to ensure that all metropolitan branches are located close to a disability compliant hub, e.g. railway station, and that all regional branches are accessible.

Another bank indicates that as part of developing their DAP that it has consulted across the corporate group and is engaging stakeholders to finalise the DAP. Part of finalising the DAP includes ensuring that technology changes are incorporated, and anticipated, and that there is a clear framework for implementing their DAP across the corporate group.

Member banks are using their progress with implementing their DAPs and other disability plans and programs as well as tracking and monitoring of complaints as measures for improving accessibility to retail banking products and services by people with disabilities and older people.

5. Next steps - Accessible Authentication

The ABA has been working with HREOC and the disability community, through the ABA's Accessible Authentication Working Group, to develop a set of Guiding Principles for Accessible Authentication.

The aim of the Guiding Principles is to provide a framework banks and other financial institutions may use to help reach a workable balance between security requirements, commercial strategies and equitable access to banking products and services.

Specifically, the Guiding Principles have been developed to:

• Provide guidance to financial institutions adopting stronger authentication technologies as part of their banking services¹⁰;
• Ensure that all customers of financial institutions operating in Australia, including people with disabilities and older people, are able to access and manage their finances independently, securely and effectively; and
• Ensure that the access needs of people with disabilities and older people are considered in the design and deployment of authentication technologies.

The ABA and our member banks recognise that as with any technological developments, careful consideration of accessibility implications needs to be factored into the design and deployment of authentication technologies, to ensure that people with disabilities and older people are not disadvantaged.

The ABA has recently released the Consultation Draft Guiding Principles for Accessible Authentication for a period of public consultation, with a view to finalising in the first half of 2007.

6. Conclusion

Banks have been working closely with HREOC and the disability community to ensure they continue to provide improved accessibility for customers with a disability and older customers. The ABA and our member banks are grateful for the continuing opportunity to work with HREOC and the disability community on delivering improved banking products and services.

The ABA has identified a number of areas for further development:

• The ABA and HREOC to work with banks to promote the development and enhancement of DAPs and other accessibility service commitments across the banking industry;
• The ABA to identify and develop industry guidance on principles for functionality of authentication and online security in banking; and
• The ABA and member banks to identify improvements in accessibility of electronic banking and include information in communications with the public.

The ABA will also conduct a stocktake of the voluntary Industry Standards to take account of technological and service delivery changes.

December 2006

Australian Bankers' Association