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Dr Scott Hollier - Digital Access Specialist Posts

Australian Banking Accessibility Principles: can we trust them after the ‘Albert’ fiasco?

In late 2018, the Australian Banking Association (ABA) released an update to its set of banking principles related to accessible design. The review was the first of its type in 15 years and was led by Dr Graeme Innes. The process involved the formation of an Accessibility Working Group with input from key disability sector stakeholders and technical experts. While the update was certainly a great achievement, few people in the disability community were celebrating. This was due to the the very same Dr Graeme Innes needing to fight a battle in Federal Court against Australia’s largest bank and prominent ABA member the Commonwealth Bank of Australia (CBA). The case related to their inaccessible ‘Albert’ Point Of Sale (POS) pay terminals that are now used by thousands of businesses around the country, preventing people who are blind or vision impaired from making payments of over $100.    

With the revelation that the case finally reached a settlement yesterday, it’s a good time to reflect on both the positive and the negative aspects of the banking industry. Given the irony of the ABA celebrating a job well done while one of its members was fighting blind customers in court, it’s worth asking the questions ‘How could this happen?’, ‘Does the settlement fix the problem?’ and ‘Will the new set of Principles ensure it never happens again?’


The ‘Albert’ POS terminal was first announced by the CBA in 2012 and promised much for businesses. Moving away from a physical keypad, the device features a 7” touchscreen with NFC, Wi-Fi and Bluetooth, allowing customers to pay anywhere in a store as the sales assistant can now bring the device to them. It also has an inbuilt camera that can be used to scan barcodes for on-the-spot redemption of loyalty cards. Furthermore, the screen can also be used for the promotion of goods and services while the checkout process is taking place, providing another opportunity for shops to advertise their products.  

While seemingly great for business, for people who are blind or vision impaired, the devices were effectively unusable. When a traditional POS device with physical keys is presented, there is usually a raised tactile bump on the number ‘5’ key which makes it relatively straightforward to orientate yourself and enter in the security code for card payments. However, in the case of Albert, the user is presented with a tablet that has no tactile indicators. With no physical buttons to tap on, a vision impaired person is unable to use the device as it’s presented as a flat screen. While this issue can be overcome using tap-and-pay for small payments, any transaction over $100 in Australia requires the entry of a PIN security code. In this instance the transaction becomes impossible as if you can’t see the screen, and can’t feel any buttons, you can’t enter the code. As a result, people who are blind or vision impaired are excluded from their purchase.

While people with vision-related disabilities grew in anger over the move away from accessible to inaccessible POS devices, the attitude of the CBA focused its efforts on embracing them. Believing that it was clearly on a winner with business, the CBA largely brushed aside disability concerns and marched on with the Albert rollout. However, as more Albert terminals appeared in stores and more people ran into problems trying to use them, the CBA realised it had a public relations disaster on its hands. Stories of shopkeeper’s demanding blind people whisper their PIN security codes to them so as to complete the transactions became commonplace, putting a vision impaired person in an impossible situation: do you publicly give out your PIN to complete the transaction, knowing that you’ve just breached the terms of use for your card, or do you hold up the queue at the shops demanding a payment option that works? Clearly a no-win situation for the person who likely expected the hardest part of shopping would be deciding what to buy rather than how to pay for it.


If by now you’re thinking to yourself that there must be a way to make Albert accessible, you’re right – there are many ways to improve the situation. At the heart of the Albert tablet lies the Google Android operating system, and as with all Android devices there’s a wealth of assistive technology features including the TalkBack screen reader. Would it be possible to enable TalkBack and allow someone to move their fingers around the screen, feeling the haptic tactile bumps of the virtual keypad and listen to the information via headphones? Absolutely. Would it be possible to go low-tech and just throw a rubber mat over the screen and restore the tactile nature of the Albert for people with a vision impairment? It’s certainly possible. However, neither of these options have been implemented.

In my accessibility work I was fortunate to cross paths with a legal expert who was able to shed some light on the issue with the rubber mat solution. There are apparently banking regulations that prevent any sort of overlay from being used on a POS device for security reasons. The argument here is that someone could put a skimmer or something between the mat and the tablet, stealing information. In practical terms I personally find this highly unlikely given the sales assistant would have the Albert device in their possession the whole time, but I’ve been reliably told that there’s no wiggle-room on this point so the rubber mat is out.  

In terms of Android accessibility, I’m not sure why Albert can’t be set up to work the same way as TalkBack generally works when using a dial pad to make phone calls, but the escalation of complaints to the Australian Human Rights Commission did at least seen movement in deploying text-to-speech functionality as a potential solution. This involved a number of trials by Vision Australia and also an Albert app for smartphones whereby you could try out their solution. This was based on the idea that wherever you put your finger on the touchscreen you would immediately be on a virtual number ‘5’, then you could slightly move up, down, left or right to find the other virtual numbers. This would rely on plugging headphones into the Albert like the way in which people who are blind or vision impaired can plug their headphones into an ATM.

Although this may sound like a suitable solution, there were two fundamental problems with it: firstly, there was little in the way of audio instructions so unless you had trained yourself using the app on the off-chance you would come across an Albert terminal, it would be very difficult to understand what to do. Secondly, the chances of having a sales assistant know anything about your need to put headphones into the machine was highly unlikely meaning you still had to have an argument about the need to use the Albert terminal differently to other customers.


As a result of the CBA being unwilling to make meaningful improvement’s, the case progressed to the Federal court where Dr Graeme Innes and Nadia Matarazzo challenged CBA to make Albert more accessible. After about a year, the CBA case has been settled with a commitment to introduce new training and a software update to enhance accessibility for people who are blind or vision-impaired. The software update will enable customers to enter an accessibility mode with an audio function that will provide voice directions through headphones to help use the virtual keypad.


Given that Albert complaints have been kicking around in one form or another for years, I’ve had a lot of time to consider the issues. My first Albert POS terminal encounter was when I took the family to a maze and mini-golf place in the south-west of Western Australia. I found myself praying that the cost for our family to enter would be under $100 otherwise I knew there was going to be a difficult and time-consuming conversation that would suck the happiness out of my two children standing next to me looking forward to the day’s activities. Fortunately for me it was under that price point, so I thought I’d casually ask if they’d had any trouble with the machines. The person was shocked that I would even consider saying a bad word about an Albert as from the business point of view it worked great and actively promoted their business at the same time.

This response goes to the heart of why I don’t see how the settlement will resolve the problem because unlike an ATM, you will always be at the mercy of the person behind the counter and there’s no way you can complete the process independently. With an ATM, you can walk up to the machine in your own time, put in your headphones, listen to the instructions, take your money and continue your day. With an Albert your experience will be completely reliant on the training of the person serving you. It’s great to see in the settlement that training will become a focus, but there’ll still be the need for that person to know that your experience will be very different to other customers and will take time, especially if it’s the first time a person who is blind has used it. The other issue is that unlike an ATM which is fairly consistent, there’s no way of knowing what type of device will be used for payment  – will it be one from the three other big banks which is completely accessible for my needs which doesn’t require headphones, or will it be the Albert that will take me significantly longer to complete my payment and put me in a vulnerable position? These are similar arguments made by most of the vision impaired people I’ve spoken to over the years about this issue along with organisations such as Blind Citizens Australia. The upshot is that a previously accessible and effective way of entering in payments has been replaced in select shops with an inaccessible time-consuming device that takes away your independence.

That said, in the wake of the settlement I look forward to being convinced otherwise: instead of hearing lots of people complaining about Albert, perhaps the settlement will lead to new stories whereby a person who is blind goes to buy something a few days before Christmas, gets to the front of the queue to pay for their item on an Albert terminal and the casual staff member employed just for that season knows exactly what to do while the 10 other people in the queue have absolutely no problems in waiting patiently for the first-time user to complete their transaction while trying to find a pair of headphones because the shop used to be accessible. I await such success stories with breathless anticipation.  


With the Albert case now settled, our attention turns to the future and whether the ABA’s new accessible banking principles can stop this type of issue from happening. Certainly the language used suggests the principles are on the right track. The Accessibility page on the ABA states that:

“When it comes to banking, every customer counts, and banks wanted to make sure that their apps, ATMs, online services, in branch services and any other banking related products were accessible to all Australians.” There’s also a supporting YouTube video.

While it’s easy to dismiss the principles considering the CBA case, they are well considered and quite detailed. To summarise them, they cover the areas of general accessibility, digital channels (websites and mobile banking), device design and use, telephone services, voice activated services or AI and specific areas related to customer authentication. I was particularly pleased to see reference to both WCAG 2.0 and WCAG 2.1 suggesting a bit of futureproofing as well.

While I’m sure it’s no coincidence that the need for this initiative coincided with the Albert mess and possibly the need for a good news story in the wake of the Financial Services Royal Commission which aired much dirty laundry on the nightly news throughout 2018, the principles offer great hope that things can get better – providing they are actually followed.  


The success of the banking accessibility principles essentially boils down to how much the banks want to fight the common Australian belief that ‘All banks are bastards’. Personally I strongly disagree with this statement as I’ve had a lot of good experiences with banks as a person with disability. The ANZ, for example, have actively implemented a very accessible online banking website and as such I’ve been a loyal internet banking customer since the 1990s. When the use of mobile apps for banking became a big deal, again ANZ put a lot of effort into ensuring that their apps were accessible for screen reader users. Likewise Bankwest (ironically owned by CBA) have put a lot of effort into addressing POS terminal accessibity with their Payment Ring which demonstrates there are great innovative solutions out there. The new banking principles are likely to enhance this effort and certainly raises awareness as to the needs of people with disability which is ultimately a good thing.

However one thing I looked long and hard for with the principles is whether it’s enforceable, and unfortunately I couldn’t see any language that said that banks ‘must’ do these things, and the Royal Commission has shown that sometimes even if the word ‘must’ is present it’s not followed anyway. The upshot is that if a bank wants to fight people with disability instead of helping them, there’s nothing in the ABA’s accessible principles to stop them. The thing that really bothered people about the Albert case is that most people understand that when you are innovating with technology, the first run will not be perfect and bugfixes will need to be undertaken to make the product work properly. Yet in the case of Albert, the CBA appeared to fix the issues faced by the broader community but intentionally skipped over the needs of customers who are blind or vision impaired. That’s the point where voluntary principles struggle: if an ABA member is more focused on fighting people with disability in court then improving its product offerings, it would be good for the ABA to also address this scenario in its principles so that there is some accountability for its members.   

It’s my hope going forward that the banks will continue to innovate with products such as Albert, but do so by making those devices accessible to international standards as is now outlined in the ABA principles. Let’s look to keep any future issues out of the courts and most importantly support the independence of the customers using it. If that becomes a reality then the banking accessibility principles may end up being far more important than they presently seem.

Registrations open for 2019 Perth Web Accessibility Camp

The time has come again when the Perth web accessibility community comes together for its annual web accessibility camp. The event will be held on 12 February at the VisAbility Victoria Park premises and registrations are now open.

Celebrating its sixth year, the Perth Web Accessibility Camp (PWAC) is a one-day event featuring a variety of presentations and other things relating to disability and technology.

I’ll be presenting on the day about my work with the W3C Research Questions Task Force as it relates to our updated W3C Note on the use of CAPTCHA. Other organisations presenting include Web Key IT and Intopia.

Additional information on registering can be found on the Eventbrite registration page. If you’d like to get a better understanding of how the day works you can also read my highlights article from last year’s PWAC event.

W3C WAI – 2018 year in review

There are many in the digital access specialist community that view 2018 as a standout year for the work of the World Wide Web Consortium (W3C) Web Accessibility Initiative (WAI). This is primarily due to its release of the first update to its flagship web accessibility standard in a decade. However, for the people inside W3C WAI, 2018 is more of a continuation of the work that’s been building over several years, and the ongoing preparation of the work still to come. That said, it’s important to stop and reflect on the achievements every now and then, so as usual at this time of year I’d like to look at the contribution the W3C WAI have made to the lives of people with disabilities in the pursuit of digital inclusion.

WCAG 2.1

The biggest announcement was undoubtedly the release of the Web Content Accessibility Guideline’s (WCAG) 2.1. This saw an additional guideline being added to WCAG 2.0 focusing on ensuring that the use of interfaces other than a keyboard be made accessible and the addition of 12 mostly mobile-focused Success Criteria. Highlights include the addition of responsive design, contrast guidance for elements such as buttons, ensuring the websites work in both portrait and landscape and ensuring that interaction of web content with sensors such as an accelerometer can also be achieved by other means. If you would like to know more you can visit a free WCAG 2.1 resource which can help to incorporate the new standard into work practices. This is a resource I created in partnership with the Centre For Accessibility.

While the standard itself is a significant step forward in addressing the accessibility issues related to the mobile web, a standard is only as good as its adoption. In this regard it’s been encouraging to see significant interest in WCAG 2.1 by governments and organisations in moving to the new standard including the European Union who have formally adopted WCAG 2.1, and an announcement by the Australian Government Digital Transformation Agency (DTA) that it will move to WCAG 2.1 at a future date.

From a digital access work perspective, there’s been a significant uptake in interest with people asking for advice, primarily from the government and education sectors with a notable standout being the Australian Taxation Office who have put a lot of time and effort this year into adopting the new standard. It’s great to see so much enthusiasm.

CAPTCHA note public draft update

While the WCAG 2.1 release has certainly been the headline of W3C WAI work this year, another update that has been receiving a lot of attention relates to a W3C Note on CAPTCHA for which I am one of the Editors. My role is with the W3C WAI Accessible Platforms Architecture (APA) Research Questions Task Force (RQTF) and the work we’ve done this year relates  to the update of W3C WAI advice on the inaccessibility of CAPTCHA.

The purpose of the Note is best described by W3C as follows:

“Inaccessibility of CAPTCHA has been a Working Group Note since 2005. It describes problems with common approaches to distinguish human users of web sites from robots, and examines a number of potential solutions. Since the last publication, the abilities of robots to defeat CAPTCHAs has increased, and new technologies to authenticate human users have come available. This update brings the document up to date with these new realities.”

In July we released our first public draft, and we are likely to release a second draft for comment early in the new year.

As this is the first time I’ve been an Editor for a W3C Note, I’m grateful to my RQTF colleagues who have been supportive as I’ve found my feet during the year and very much looking forward to the continued work as the Note is completed.

Digital Access Business Case resource

The last highlight I’d like to draw your attention to has only just been released. It is a resource titled The Business Case for Digital Accessibility, designed to highlight the rationale for addressing digital access issues within an organisational strategic context.

In the official announcement e-mailed to the WAI Interest Group mailing list, the primary purpose of the resource is to provide guidance on the “…direct and indirect benefits of accessibility, and the risks of not addressing accessibility adequately.”

Features of the resource include guidance on the following topics:

  • Drive Innovation
  • Enhance Your Brand
  • Extend Market Reach
  • Minimize Legal Risk

Given how difficult it can be to argue the case for digital access, this resource is likely to make a tremendous difference for people inside organisations that want to make a case for digital access improvements but struggle to find the best way to do so within a corporate context. The Education and Outreach Working Group are to be commended for such a well-structured, detailed and helpful resource.

The WAI work listed here is by no means a complete list but does give you some idea on the great things taking place in the international community to help people with disabilities get access to online content along with all the benefits that access provides. Many thanks to all the hard-working people involved in W3C WAI and I’m looking forward to continuing my involvement in 2019.

New resource helps people with vision disabilities navigate the NDIS

VisAbility, one of Australia’s service providers for people who are blind or have low vision, recently launched a new resource titled My vision, My Choice to help people with a vision disability navigate their use of the National Disability Insurance Scheme (NDIS).

My Vision My Choice website screenshot

The official VisAbility press release describes the My Vision My Choice website as “…a comprehensive online one-stop-shop, where you can access all you need to know about the NDIS if you live with vision impairment or blindness, are a family member, carer or provider. [the website] successfully brings together everything a person with vision impairment needs to make an informed choice about their NDIS plan in one place.”  

The website contains a large amount of information including:

  • Access to the NDIS planning booklet
  • Sample plans
  • Comprehensive list of Service Providers roles
  • Personal stories and podcasts.

As the project progressed, I had some involvement through the creation and implementation of a community consultation programme to determine what content people would need from the resource. It was great to be involved in the design and implementation of this process which included focus groups and an online survey.

Since the launch of the resource there’s been great feedback in the community that the website is effectively meeting its need as people with vision disabilities continue to work their way through the NDIS process.

Many thanks to VisAbility for the opportunity to work on the project. The My Vision My Choice resource can be found at

OZeWAI 2018 conference highlights

The OZeWAI 2018 conference, hosted by the ABC in Sydney, has now ended and a great time was had by all. The three-day event is held every year as Australia’s dedicated national conference for digital access specialists and is renowned for its great community atmosphere and presentations with this year being no exception. Here’s some of my personal highlights from the three days.

Scott at OZeWAI 2018

The keynote was delivered remotely by Nic Steen out from Knowbility titled No Rights, No Responsibility. The speaker made the point that it is important to ensure that people with disability are included in the digital access processes and that training is critical in making sure that effective digital access is achieved.  

Another great presentation was Here comes WCAG 2.1! by Amanda Mace from Web Key IT and Julie Grundy from Intopia. There was some great discussion across the new WCAG 2.1 Success Criteria, explaining the importance of things like reflow and ensuring that content on mobile devices needs to work effectively for people that may not be able to move their device to activate various sensors. With this year marking the WCAG 2.1 release it was a great introduction as to how the new extensions build on the legacy WCAG 2.0 requirements.   

Just before the lunch break on the first day it was my turn to present, discussing the W3C work on inaccessible CAPTCHA. In the presentation I talked about how traditional CAPTCHAs such as the use of text on bitmapped images and audio-based CAPTCHAs are not only inaccessible but also not secure. I also provided an update on the advice our group has been putting together as part of the CAPTCHA advisory note. It was great to have a chance to share the information.

Another session that I really enjoyed was Andrew Downie’s presentation titled The Graphics Divide – When the alt Attribute does not Suffice. I’m frequently asked in workshops as to what is best practice when using alternative text, and Andrew illustrated the point well using popular landmarks and providing relevant text descriptions. The key takeaway from his talk is that it’s relatively easy to use alternative text for WCAG compliance, but that doesn’t mean it’s accessible.

A presenter I always enjoy is Greg Alchin, and he did a great job in discussing the importance of ePub. In a PDF-obsessed world, Greg made the point well that there are a lot of tools and readers available to make the most of the ePub format which is essentially web pages compiled into a document format. While there’s still no WYSIWYG editor that works well for the ePub format and this was a point acknowledged as a current restriction, it’s encouraging to hear that there are plans for it to be included in the Office suite in the future which will go a long way to addressing this issue.

On the second day I featured in a second presentation hosted by Sean Murphy from Cisco Systems whereby we discussed the accessibility implications of Artificial Intelligence and the Internet of Things. When Sean invited me to join him, he said it’d be great to structure it like a fireside chat, so we had an agreement whereby he would bring the questions, and I would bring the fire. As such, I had my laptop next to me playing a YouTube video of ‘HD fireplace with crackle’ while we discussed the implications. Sean made several great points about how the quality of data will heavily determine the effectiveness of our AI perceptions and how issues such as security still have a long way to go. I also talked about my Curtin research as it related to the IoT needs of students in tertiary education.

The last presentation that really had an impact on me was Making Chatbots Accessible by Ross Mullen. Until this presentation I had always assumed that chat boxes were largely a no-go zone for accessibility, but Ross explained that if an effort is made then both conversational support and accessibility can be achieved.

In addition to the presentations it was also great to catch up with lots of familiar faces at the breaks and conference dinners. I also really enjoyed making new friends and meeting many of the Alumni from the Professional Certificate in Web Accessibility course.

Special thanks to the OZeWAI committee for putting on such a great conference. If you were unable to get to OZeWAI, you and watch all the session recordings which are now available on YouTube.