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Submitted to Australian Bankers' Association
January 2002
Council on the Ageing (COTA) commends the Australian Bankers' Association (ABA) for its initiative with the Human Rights and Equal Opportunity Commission (HREOC) in developing industry standards for electronic bank services. They are a critical step towards making these services more accessible to everyone, and in particular to older people and people with disabilities. The working groups are to be congratulated for the detailed research and information on best practice.
COTA has had a strong advocacy and policy role in addressing issues of the digital divide, and is a member of the ABA/HREOC Accessible E-commerce forum from which the standards arose. COTA is one of the community groups which has worked closely with government and industry over the past year on a range of measures, particularly in developing the draft standards which aim to improve access to banking and financial transactions for older Australians and people with a range of disabilities.
As COTA's previous work on improving access to banking and technology is already a matter of public record* this response will make only brief comments on the draft standards (online at www.bankers.asn.au) from feedback received. (*See for example submissions, conference papers, press releases and articles available online under Banking; E-commerce and technology access on the COTA website at http://www.cota.org.au/whatsnew.htm).
We would comment that in COTA's view insufficient time was allowed for public comment and consultation between the release of the standards on 29 November 2001 and the deadline for responses of 31 January 2002. The short time-frame was made even more difficult by being over the Christmas period and was insufficient for community organisations to properly consult with their members or to meet publishing programs of member newsletters. Despite this, COTA distributed information on the draft standards on behalf of the ABA very widely throughout our extensive networks and media, and invited responses direct to the ABA. We would seek further information and feedback from the ABA on the extent and content of responses received.
The documents provide a valuable compendium of information and research on best practice. However feedback to COTA from both policy workers and consumers on readability was that most of the information was "too technical for me". This is important considering that Section 9 Scope states that each "Industry Standard is intended for use by developers, suppliers, designers and users…". While acknowledging the depth of work and sound intentions involved, comments ranged from "most people would find this as informative as the back of an airline ticket" to "Could we have a plain English, non technical version? Or could someone show us what a conforming ATM looks like, or what best practice in plastic card swiping might be? Or do we just have to have faith in the good intentions of the writers and experts?"
The Definitions sections (no. 8) do provide useful and necessary clarification. However it is important to spell out abbreviations - what for example is an RFI or RFP? (section 5, Disclaimers, paragraph 2)
We note and support the specific comments on particular draft standards made by Gerard Thomas in the submission on behalf of the Australian Pensioners' & Superannuants' Federation (section 8, p13ff). We therefore do not repeat them but add the following additional comments.
Considering that COTA representatives were on all four working groups and publicly acknowledged as having a major input, the phrase and older people should be added to the end of the sentence in para.2 ending 'organisations of and for people with disabilities'. This applies to all four standards.
The documents clearly state in section 7 that compliance with the Industry Standards is voluntary, not mandatory, and that adoption is " a matter for individual decisions by financial services institutions."
COTA and other submissions (Combined Pensioners, Ombudsman) to the ABA disability action plan lodged at HREOC in May last year argued that a standards based approach does not address issues about implementing the standards once they are agreed upon, apart from the commitment to meet WC3 Internet industry standards for Internet banking. We were disappointed then that these concerns did not result in any changes to the draft plan. These concerns are still not addressed as the draft standards do not indicate any measures for monitoring or reporting on the compliance of financial institutions, nor for remedying situations or dealing with complaints where they fail to meet standards. COTA accepts that the ABA cannot impose mandatory adoption of the standards but point out that consumers are sceptical about relying on good will, and question whether major financial institutions which function quite independently for competitive reasons will be committed to adopting the new standards. ANZ for example is currently replacing 80,000 merchant credit card terminals with chip-enabled Multi-POS terminals which comply with the Europay Mastercard Visa standard for secure transactions at the point-of-sale. (Australian Banking and Finance, Nov 15 2001, p3). Consumers need to see a process which indicates that these and other products are compliant with the Australian (currently draft) standards. The process should also address the above mentioned issues of monitoring, breaches, complaints and redress and public reporting.
COTA and other consumer organisations generally prefer and use the terms older person/people or seniors, rather than elderly.
The standards variously describe categories of disability. From a marketing point of view it would be advisable to talk in terms of products not only being "disability friendly" but "age-friendly" since most older people do not rate themselves as having a disability, even if they are deaf or have very poor vision. Although approximately 50% of people over 60 have some form of disability, older people are more likely to see a disabling condition as part of growing older, not being "a person with a disability". Lack of access to training or a computer or an attitude of mistrust toward technology are as much barriers to use of electronic banking as are disabilities related to natural processes of ageing like decreased vision, arthritis or short-term memory loss. Such disabilities may reduce older people's ability to easily access some forms of electronic banking, but evidence shows that older people readily accept new technology where it is demonstrated that it meets their needs (ie is useful, convenient and safe), and is explained effectively.
To assist take-up of electronic services, investigation, development, and funding of practical, innovative, grass roots education and access programs is needed. Funding, sponsoring or partnerships should come from the banking and finance industry and government. There is great potential for projects to extend the IT training currently being provided by groups like COTA, Australian Seniors Computing Clubs Association and U3A to include electronic financial services, for example by producing and testing learning materials on online and self-service banking. Involving older people's input into design, trialling and market testing of products and services is important. COTA recommends that users with a range of capabilities and limitations be involved in testing all new products and equipment before installation, not just as recommended in section 11 for EFTPOS.
The above remarks on education and user trialling apply to all the sections in the standards which outline learning, user support and documentation.
A more useful way of describing design standards is by using the term universal design (defined in the ATM standard) rather than focusing on disability or age.
11.1.2.4: Rule P: Responses: 'sufficient time' needs to be specified
11.2: Testing accessibility
The meaning of 'user accessibility trials' needs to be specified, eg piloting with users? Consumer groups need to be approached to work cooperatively - for example COTAs in NSW, Western Australia and Victoria run computer training classes which may be able to test banking web sites.
11.3.1 mentions 'flashing pictures' - section A1.3.1 says that this is not good for epileptics
11.3.3 Consistency
COTA supports greater consistency between providers - this applies to all standards. We argued in our submission to the Disability Action plan for standardisation in presentation of data on bank web sites for individual accounts, citing the following respondent:
"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!"
This should not preclude the user having the ability to customise Internet banking accounts e.g. user attributing specific names to different accounts - "Sam's savings account", "Joint Mortgage account", "Mary's credit card account".
11.3.4.5: Provision of Information: Printouts from the web must not lose information. Older people prefer to print information and read it, and often printing loses information at the side of the screen display.
Appendices A1.1.1. Vision:
A1.2.2. Dexterity: paragraph 2 -suggest greater use of up/down keys
COTA strongly endorses the statement made in 10.2 Design principles that "As a first principle, older Australians or people with a disability should not be financially disadvantaged by needing additional functionality".
11.4 Input and navigation
11.4.1: Shorter IDs: one respondent noted: ''It is generally accepted that people can remember 7 +/- 2 items of information - this implies that personal number codes should be 5 digits."
11.4.2 &3 allow for the option to speak to an operator, and automatically transfer to an operator when the customer doesn't respond, without financial penalty. These are important and welcome considerations for those older people, particularly those who may be confused or anxious about the technology.
This is one issue not sufficiently recognised in the standard for ATM and EFTPOS. In its submission to the ABA Disability Action Plan in 2001 COTA stressed 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, as also noted by the HREOC inquiry in 1999. COTA notes that the Victorian State Government is developing guidelines on ATM safety, considering such measures as "premium ATMs" with better lighting and electronic surveillance.
11 Requirements: COTA endorses the recommendation that users with a range of capabilities and limitations be involved in trialling terminals, and would like to see this extended to testing all new products, equipment and services.
Electronic banking services along with other information and communication technologies are becoming an integral part of daily life. Use of the necessary access tools will be a pre-requisite skill for participation in Australia's society and economy. By specifying how electronic banking services are to be designed and used the draft standards are a vital step in addressing access for people on the wrong side of the digital divide. The next steps are to make sure that the standards are adopted by all financial institutions and that all consumers are enabled by appropriate information, assistance and education to become confident users.
Copyright © 1997 Council on the Ageing.
All rights reserved.
Revised:19 February 20022
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