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navigation Disability Rights

Electronic financial services - a review of progress

7 July 2005

Dr Sev Ozdowski OAM
Acting Disability Discrimination Commissioner

Introduction

In March 2000 the Human Rights and Equal Opportunity Commission completed an inquiry into access to e-commerce and information technologies for people with disabilities and older Australians. This report identified, amongst other things, the need to address access barriers to electronic financial services, specifically in the area of ATMs, EFTPOS, Internet, and telephone banking.

Following the release of the report the Commission worked with the Australian Bankers' Association (ABA) to jointly establish the 'Accessible E-commerce Forum' (the Forum). The Forum included representatives from HREOC, the ABA, Commonwealth Attorney-General's Department, Blind Citizens Australia (BCA), the Physical Disability Council of Australia (PDCA), the Disability Council of NSW, Council on the Ageing (COTA), Credit Union Services Corporation (Australia) Limited (CUSCAL), Australian Association of Permanent Building Societies (AAPBS), Internet Industry Association (IIA), Australian Information Industry Association (AIIA), Department of Family and Community Services, Australian Retailers Association (ARA), Property Council of Australia (PCA) and a number of industry service providers, including Telstra and IBM.

The purpose of the Forum was to look at ways to achieve change in the area through establishing partnerships between industry, community and Government.

Early in the life of the Forum the ABA made commitments through its Action Plan to developing a range of industry best practice standards covering ATMs, EFTPOS, Internet, and telephone banking.

The ABA established a number of working groups to develop these industry standards that included representatives from individual banks and the broader financial services industry such as CUSCAL and AAPBS, along with representatives from the disability sector, older Australians, the ARA, IIA, PCA and HREOC.

Following extensive consultation the industry standards on accessible ATMs, Internet, EFTPOS and telephone services were released in April 2002.

Since that time many financial institutions have publicly adopted the standards as best practice benchmarks and developed implementation strategies to move towards compliance.

Some, including the Commonwealth Bank of Australia , the National Australian Bank, ANZ and Westpac, have specifically included their commitment to implementing the standards in Action Plans submitted to the Commission and registered on our web site at http://www.humanrights.gov.au/disability_rights/action_plans/index.html .

At the time of release of the industry standards the ABA committed to a review of the technical content after financial institutions had had an opportunity to put them into practice. The Commission also committed to undertaking a review of the general uptake of the standards and their effect on the experiences of people with disabilities.

Because of resource limitations the Commission's review was limited to direct discussions with a number of major financial institutions and an open invitation to people with disabilities to describe their recent experiences in the area of electronic commerce.

Summary of review submissions

As part of its review of the uptake of the industry standards the Commission invited people with disabilities and community advocacy groups to provide feedback on their more recent experiences with electronic financial services since the standards were released.

Those wishing to provide comments were invited to consider questions such as:

As a result, the Commission received 29 submissions from a range of individuals and organisations, including a number of national Peak groups who had canvassed their members.

The submissions covered various topics, including awareness of the standards, communication by financial institutions and ongoing access issues. A number of themes emerged from an analysis of the submissions, and these are summarised below.

Awareness of the Standards

Many individuals and organisations indicated in their submissions that at best they only had a limited awareness of the voluntary standards, that they had received no information from their financial institutions about them, and that they were unaware that the finance sector had given any individual or collective commitment to introducing them. These comments are typical of submissions received:  

Not one of the clients or family member [represented by the organisation making the submission] is aware of commitments made by financial services regarding the standards.

Peak client body generally unaware of the Australian Bankers' Association ( ABA ) voluntary industry standards, and seem not to have been informed by their financial institutions of the standards or of their commitment to instigate strategies to improve accessibility.

Very few people were aware of the voluntary access standards for banking services as promoted by the Australian Bankers Association

I am not familiar with the industry standards, nor am I aware of any commitment made by any financial institution to adopt or implement the standards.  

Improvements in Accessibility

Probably the single most repeated comment in the submissions received was that there had been little or no discernible improvement in the accessibility of Automatic Teller Machines (ATMs):

Our members did not know of any location where audio ATMs are installed .

ATMs outside the banks are inaccessible due to the height they are installed at .

I have seen no changes occur at my local banks in relation to access to their ATM's and continue to find them inaccessible.

I am unable to use their ATMs because the container for unwanted receipts is in the way of my wheelchair getting close enough to the machines.

The ATM's are situated at a height that is impossible for me to reach the keypads, slot to swipe my card and buttons at the side of the screen are all too high for me in my wheelchair.

The height of keypads at ATMs is a huge problem. Many wheelchair users are unable to weight-bear at all, so the option of standing to utilize a keypad does not exist. This simply means those persons either need to have someone else key in the information, or they have to go into a bank-branch and see a teller - for which many banks charge! Utilising someone else is obviously a security risk.

I have heard of a number of trials of accessible ATMs, but they seem always to be in the city or a major shopping centre and not where people with disabilities like me actually live. If I want money on the weekend or after hours, I still have no access to ATMs.

Other submissions listed specific aspects of ATMs that were inaccessible, including the angle of ATM screens, and the height of the machines.

On a more positive note, one submission did point to an improvement in the accessibility of ATMs:

I have noted a vast improvement in the accessibility of ATMs. I recall in about 1992, I asked for a machine which was to be erected in the grounds of a hospital to be wheelchair accessible and was just able to reach. As my condition has deteriorated I doubt that I could do so now!  But things have improved and I can now use the local ATM easily. My only problem is in extracting the money and my card as my hand function is limited.

A number of submissions noted satisfaction with improvements in the area of internet banking:

I tend to use internet banking facilities . which I find very easy to use.

As a person who is blind, I rely on the Internet to do most of my banking. My bank's internet banking service is quite accessible, with only a few areas where there is scope for improvement.

While others indicated that there are still aspects of websites that are difficult or impossible to use:

The . [banks] websites change often but I can't say for the better.

Large font and clear screens are very important for many older people. It is therefore disappointing to note that of the six larger retail banks, only . [two named banks] websites enable older people to easily vary the font size.

I have tried several times to arrange access to Internet Banking, but because I cannot choose my own pin number, I forget the allocated one and have to start all over again. I have done this 3 times now and have given up.

A range of opinions was expressed about the accessibility of telephone banking including acknowledgements that:

Telephone banking is quicker than when it first commenced.

However, there was little indication that services had become more accessible since the standards were released:

I have huge problems with telephone enquiries because I am deaf and so I cannot hear on the phone; I have to use the [National] Relay Service but I do not like that way because I have to share my personal banking information. Lots of banks do not have any TTY for deaf customers .

As far as telephone banking is concerned, I find the instructions given do not allow sufficient time for me to process the information and begin to enter the required data and again this takes a long time, I have also had to re-dial into the phone number up to 3 times to get my banking done.  The very long strings of numbers required to process BPay often result in errors.

There was less comment about the accessibility of EFTPOS machines and services, but such comment as there was pointed to, if anything, less accessibility than previously:

Some of the members discussed the touch sensitive style of EFTPOS machines and how difficult they are to use. Also raised was that some machines do not have the Dot 5 to indicate where the 5 is in relation to the other numbers.

EFTPOS keypads are no longer fixed. 

I have noticed that a lot of the new EFTPOS machines don't have a dot on the 5 and this has meant that I have had to have people help me.

Two of the Peak bodies in the disability area concluded:

. in general, we have major concerns with the degree of take up and compliance with the Standards by the banking and financial services industry.

. we are not, largely, dealing with a situation where an industry is adjusting existing services to meet new obligations - these obligations have always applied to these ser vices.  

Other Issues

Quite a few submissions took the opportunity to comment on accessibility issues that, while not relating directly to the electronic banking standards, nevertheless have a significant impact on the accessibility of banking services generally.

Security

A recurring concern expressed in many submissions was that people with disabilities are especially vulnerable to attack when using ATMs, particularly those that are situated in open areas. Some people said that they would not use ATMs at all, while others expressed considerable reluctance to use them because of security fears.

Reforms need to consider issues of security raised by people with disabilities such as their reliance on carers and family on a regular basis to assist them with banking, and vulnerability to attack such as the extra time required by some people with disabilities to operate ATMs.

All of our members expressed concerns about personal security when using ATMs.

The other point I would like to make, is that of security. Even if the individual is able to weight bear or lever themselves up high enough to utilize the [ATM] keypad, they are very vulnerable to robbery/attack. This risk exists for the entire population, but is increased when disability is present, as these people are less able to protect and defend themselves. It seems to me that very few, if any, of the financial institutions have thought very much about that at all - or is it simply that they don't care?

The submissions show clearly that there are social factors that affect the way in which people respond to electronic services. Even if ATMs are accessible, people with disabilities may still not use them if they feel that their security is compromised and that they are in personal danger.

Security issues were also raised in connection with Telephone and Internet banking. Here, the overriding concern was not so much about personal safety but rather about the perceived risk of the theft of personal information. In part, this concern is a reflection of more widespread community concerns about the susceptibility of these services to fraud such as the Nigerian scams and the use of "phishing" techniques to steal personal information.

3 of the clients consulted said they do not do internet banking or telephone banking due to security fears.

An issue that emerged was that clients considered alternative banking such as use of internet and telephone banking as unsafe for security reasons. This may be reflective of the mainstream population's slow uptake of internet and telephone banking.

A few members use internet banking, most felt that security issues prevented them from using this service.

Regrettably, I am not in a position to support internet banking. Recently a relative of mine lost $10,000 due to internet banking fraud.

Physical access to Branches

Most of the people with physical disabilities who made submissions referred to the continuing presence of steps at entrances to Branches and the height of teller counters, both of which can make the Branch and the services offered within them inaccessible.

New technology

Some submissions also highlighted the inaccessibility of new technology that is not currently included in the electronic banking standards. One example is touchscreen ticket-dispensing machines that are used to manage queuing for teller services. These machines are inaccessible to people who are blind and there is no access standard covering them.

Specific services

A number of submissions also commented that staff in Branches and at call centres were largely unaware of specific services provided to people with disabilities. As a result, services such as reduced charges for people with disabilities who need to use over-the-counter services were not generally known:

Customer service supervisors are not conversant with Bank policy, subsequently the information doesn't filter down to the call centre operators

Summary

Although this review has only taken a snapshot of the current situation it does provide some useful information on the experiences of people with disabilities in relation to the adoption and implementation of the voluntary industry standards.

In general, there appears to be little knowledge of commitments or strategic directions towards implementation of the standards.

The review suggests that there are significant opportunities for financial institutions to promote the existence of the standards, and also their commitment to a phased implementation of them.

The review also highlights the problem of "bracketing out" the standards from other areas of financial service. Physical access to premises, security and the accessibility of new and emerging technology are critical to the overall delivery of financial services.

Industry consultation

After the Commission receiving feedback from people with disabilities on their experiences we met with the ABA and a number of its members.

Those discussions were informal but included issues such as:

Our discussions showed there was a broad and consistent commitment to adopting and implementing the standards by the ABA and its membership. While there were differences in priorities and strategies for implementation, there was no doubt significant effort and resources had been directed to addressing the standards.

Following this meeting I asked the ABA if it could provide an update on developments amongst its members and this information is now available at www.bankers.asn.au/access/reporttohreoc

This update provides a very encouraging restatement of the commitment of ABA members to implementation of the standards and a summary of a range of initiatives a number of ABA members have reported on.

As the standards were developed by the ABA this review focussed on the uptake of the standards within their membership. The Commission has, however, also been encouraged by the willingness of other organisations in the financial services sector, such as building societies and credit unions, to consider and work towards these standards.

What next?

It is inevitable that it will take some time for the standards to be implemented and for people with disabilities to experience direct benefits from the changes. This review indicates that those benefits are not yet being widely enjoyed, but it does indicate that many financial institutions are making considerable effort towards ensuring all their customers benefit from the convenience and efficiencies associated with electronic commerce.

As a result of our discussions and the comments made by participants in the review I will now invite individual banks and other financial institutions to provide me with links to their own web sites where customers with disabilities can obtain ongoing information about specific commitments and progress being achieved in relation to accessible financial services.

I will make these website addresses available through the Commission's website in order to encourage the more widespread availability of access related information.

I will also continue to work with the ABA to identify ways of making sure new technologies consider access issues at the developmental stage and to assist their members to achieve full implementation of the industry standards.

I would welcome any comments on this review and ideas on improving access to financial services from people with disabilities and financial institutions. Please forward your comments to disabdis@humanrights.gov.au