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?’
WHAT IS ‘ALBERT’ AND WHY IS IT A PROBLEM?
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.
WHY CAN’T ALBERT BE ACCESSIBLE?
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.
THE CASE IS SETTLED BUT INDEPENDENCE IS LOST
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.
WILL THE BANKING PRINCIPLES HELP?
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.
NOT ALL BANKS ARE BASTARDS – SO DON’T BE ONE
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.