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COTA commends the Australian Bankers' Association for its initiative in developing the E-commerce Industry Action Plan to address issues identified by the Human Rights and Equal Opportunities Commission (HREOC), in its Inquiry and report "Accessibility of Electronic Commerce and New Service and Information Technologies for Older Australians and People with a Disability" (HREOC 2000). The Plan is available at www.bankers.asn.au under Disability Action Plan.
The plan mainly covers electronic banking issues, and is essentially concerned with reviewing, writing and adopting as best practice industry standards, guidelines for electronic banking facilities. Face-to-face banking issues are also addressed, and discussed under Recommendation Two.
COTA, as a representative on the Accessible E-commerce Forum arising from the HREOC Inquiry, welcomes the opportunity to comment on the Plan, and to nominate representatives for the working groups being set up to progress standards for ATMs, EFTPOS, phone based services and Internet banking.
COTA notes the ABA statement that "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", - on a voluntary basis. However COTA argues that the standards based approach does not address issues of implementing the standards once they are agreed upon, apart from the commitment to meet WC3 Internet industry standards. A parallel plan is needed so that the agreed best practices are in fact implemented by ABA member banks on a more pro-active basis than waiting for customers to lodge complaints under the Disability Discrimination Act.
The ABA objective here is to orchestrate the banking industry response to the HREOC e-commerce accessibility report.
Strategies primarily revolve around the Accessible e-commerce forum, jointly sponsored by ABA and HREOC with representatives from the banking and financial service industries; retailers; community advocacy groups from the disability and older people sectors (COTA); government and the internet and IT industry.
As outlined below under the heading Discussion, the plan does not address how to provide access or education for groups on the wrong side of the 'digital divide'. COTA has always argued that providers of online and e-commerce services must provide alternative methods of access for vital information and services, as there will always be people unable or unwilling to access electronic services. Such groups should not be financially penalised.
Greater acknowledgement of the barriers to electronic banking are needed than those identified as 'attitudinal, awareness, physical, affordability and safety". Inability to use electronic services is not identified, for example due to limited literacy, cognitive impairment or memory loss. It needs to be kept in mind that consumers do not 'fail' if they resist or do not adopt technology, but are influenced by a combination of factors. These factors include access to, quality and cost of infrastructure, geographical location, education, literacy competence, disability, access to learning opportunities, poor design (Foskey 2001).
COTA has constantly represented older people's preference for face-to-face delivery of information and financial services, and welcomes the statement that "for many people, the only way these barriers will be avoided is by the continued presence of face-to-face services".
While the 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" is commendable, older people have constantly told us that they have been dismayed by the removal of existing face-to-face services, whether by the introduction and increases in over-the-counter charges or closure of branches. A decline in service standards has also been noted.
The closure of banks is a major issue because when banks go so do other services. When services go, older people in rural areas have to travel long distances for health and other services that can't be done electronically. One respondent suggested "if the banks were to think laterally they could donate money to local community transport services".
Problems identified with the new forms of face-to-face facilities which replace branches, such as giroPost and agency arrangements, include:
Pragmatically, it would probably be cheaper for the banks to provide free face-to-face services to the current cohort of older people while electronic services improve and become more widespread. COTA Board at its November 2000 meeting made the recommendation that people over 80 be exempt from any penalties for not using electronic banking. It was gratifying to see the ANZ announce unlimited fee-free over the counter transactions for customers aged 60 or over from ANZ personal transaction accounts from July 2001. Hopefully other banks will follow their example.
The accessibility problems posed by design features have been well-documented by the HREOC inquiry and supporting submissions (HREOC 2000 - online), a Bankwatch audit of ATMs (Connolly & Thomas 2000) and the ABA plan. They do not need to be repeated, apart from highlighting the issues of cognitive impairment and slowness in performing tasks that may be associated with ageing.
COTA welcomes the initiative taken by HREOC and ABA in re-writing new standards to adopt as industry benchmarks and in taking account of existing best practice in other countries. This is particularly pleasing considering that back in 1995 we recommended to the Prices Surveillance Authority Inquiry into bank fees and charges "that financial institutions investigate design standards in ATM facilities and develop common industry standards to ensure physical and user-friendly access". Universal design principles rather than adapted or specialised design is the preferred option – expressed by one respondent as "adaptation of the technology environment to meet people's needs across the lifecycle rather than adapting older people to existing technology".
COTA stresses the need for safety issues to be considered in any standards development. Fear and the real risks of robbery or exploitation associated with ATM and eftpos use are frequently expressed by older people. National Seniors Association for example have recommended in their 2001 Federal Budget submission that "security of automatic teller machines should be addressed to ensure the safety of all Australians using them". A potential consequence of encouraging minimum numbers of withdrawals is the risk involved in withdrawing and carrying larger amounts of cash.
One of the problems for all users, not only those older or disabled, is the difference in design, user instruction and formatting at the various outlets. Standardising would alleviate confusion, for example between "ENTER' or 'OK' keys.
As argued in the introduction, consumers will be looking for translation of upgraded design standards into practice. New features can be added to upgraded ATMs and eftpos, without needing to completely retrofit.
If smart cards are to be introduced, a golden opportunity to "get it right the first time" exists, unlike the experience of introducing ATMs.
HREOC recommended the "wider implementation of the existing Australian Standard on interactive voice response systems". Widespread non-compliance with this standard has been identified as a problem with existing IVR systems. Whether the existing standard is good enough also needs to be established. Current research (cited in Scott 1999) and anecdotal evidence emphasises the frustration and dislike of automated telephone systems expressed by consumers across all age and socio-economic levels. While "martini banking" (access any time, any place, anywhere, via any access device) is convenient and desirable, face-to-face is still a desired additional option. Humans are still better than automated telephone services for answering non-standard questions, and for advice.
A useful modification to IVR would be to make the option to speak to a person the first rather than the last option i.e.
"If you would like to talk to a human being please press 1"
"If you would like telephone banking please press 2".
As one respondent illustrates: "I recall my father in law just a month ago having a very deep conversation with 'a lovely lady' for several minutes only to be confused when he was abruptly cut off - when I re-dialed the number I found he had been talking to a machine!"
Additional difficulties for telephone users in rural areas have been noted in a report on non-metropolitan older people and technology (Foskey 2000). Examples are unreliability of line connections, or lack in some areas of the touch-dial telephones required to access automated services. The report provides a useful outline of issues and suggested solutions to do with automated telephone services, banking, technology access and education.
Accessibility barriers associated with web sites are well documented, for example in the literature arising from the HREOC inquiry. Ensuring bank compliance with the World Wide Web Consortium's guidelines is a logical and achievable objective to address the difficulties faced by older people, particularly the approximately 50% over 60 who have some form of disability.
Older members have suggested standardisation in presentation of data on bank web sites for individual accounts. For example one wrote:
"On the Westpac site I can see my balances and, for account transfers, each account is identified as cheque account with account number, credit card with credit account number etc. The ANZ site is more difficult. It shows simply cheque, cheque and credit card (I have 2 cheque accounts and 2 credit card accounts) and I have to guess which one is which by the balance that is shown on the side of the screen. I find that I can easily make errors in E transfers on ANZ!"
Internet banking facilities also need to have the ability to be customized by the user e.g. specific names attributed to different accounts by the user - "Sam's savings account", "Joint Mortgage account", "Mary's credit card account" etc.
If banks want to keep customers online, they need to make sure their electronic systems are excellent. Consumers need to see that online transactions are secure, that servers do not crash, and that sites do not rely on high speed connections and up to date computers.
Inconvenience caused by software or hardware glitches are no longer acceptable if selling a product or service, especially if there are fees for using the online service, which is now the case.
The plan does not address issues of providing IT access and education for marginalised groups, such as older people living in non-metropolitan areas, with limited education, low literacy and low incomes, or of non-English speaking or indigenous background. Neither does it address facilitating take-up of the tools provided; providing tools does not ensure adoption. Use of the Internet does not mean automatic take-up of e-commerce transactions either, as pointed out by AARP (previously American Association of Retired Persons) in a national survey on computer users aged 45 and over (Market Facts 2000).
As one of our members said:
"No matter how far the good intent goes and how much quality assurance is put into place, it is nought to a large percentage of the older population who fall victims of the digital divide."
Organisations providing electronic services take it for granted that they must train staff but do not extend this logic to training their customers. Current short-sighted and discriminatory practices of not making work-placed IT training available to older workers, or laying them off first, further disadvantages older people.
COTA urges banks to use every means to publicise services for older people, people on low incomes or with disabilities, and to provide resources to educate its customers. The Commonwealth Bank publicises initiatives through COTA News but is the only bank to do so. Since the Self-Service Banking and Older Australians government/industry/community partnership during International Year of Older Persons in 1999, thousands of clubs have benefited from a Commonwealth Bank and COTA clubs education program on self-service banking. Retired bank officers act as peer educators to teach older people in club seminars the benefits of self-service banking. They show how to use electronic devices by bringing demonstration equipment such as ATMs. A video called "Banking with Helen" looks at the use of EFTPOS and telephone banking, and is available for loan. A large print brochure on non-reflective paper is also supplied.
The success of the program was due to resourcing by the Commonwealth Bank. Bank state coordinators organised the program and the Commonwealth Bank resourced COTAs to provide access to clubs in rural as well as metropolitan areas. Community groups cannot afford to, nor should they be expected to, subsidise commercial organisations by free provision of information, expertise, or marshalling a constituent audience via their networks. This was acknowledged by the Self Service Banking and Older Australians Project Management Committee report in June 2000.
Further investigation, development, and funding of practical, innovative, grass roots education and access programs is needed if electronic delivery of services is a stated goal. Funding, sponsoring or partnerships should come from the banking and finance industry and government. The National Office of the Information Economy is currently touring the country holding round tables about the digital divide and looking for future directions. Applicants for its Networking the Nation funding have complained that very little went to programs for older people.
The "peer educator" model has proved successful in COTA's medicine and IT education programs (COTA 1999). There is great potential for extending the IT training currently being provided by COTA and other groups such as the Australian Seniors Computer Clubs Association and U3A to include electronic financial services.
COTA's previous recommendations for involving older people's input into design, trialling and market testing of products and services (COTA 1999; Scott 1999) have been echoed by the Australian Telecommunications User Group. Again, organising involvement requires funding and development of community and business partnerships.
The ABA is to be commended for the consultative process of developing the E-commerce Industry Action Plan and industry standards for electronic bank services.
It is important to address service and design standards from a trans-generational and universal perspective, rather than as add-ons or separate services. It also makes good business sense. User input is needed in design and trialling.
The next important stage in the process is implementation of the measures developed. A vital part of that process will be community awareness and training programs and a commitment by government, industry and community sectors to collaborate to ensure an inclusive technology environment.
Copyright © 1997 Council on the Ageing.
All rights reserved.
Revised: 31 May; 31 October2001
COTA National Seniors Policy Secretariat [formerly Council
on the Ageing (Australia)
Level 2, 3 Bowen Crescent, Melbourne Vic 3004
Tel (03) 9820 2655 Fax (03) 9820 9886
email cota@cota.org.au