May 2018
APRA (Australian Prudential Regulation Authority) has just released the report of its inquiry into The Commonwealth Bank of Australia (CBA), finding the bank’s culture “insular” and an environment where learning from experiences and mistakes was ignored.
The bank’s board of directors also had “inadequate” oversight of emerging non-financial risks and its senior executives had a lack of ownership of key risks.
Blind Citizens Australia has first-hand experience of CBA’s unwillingness to take seriously risks to its customers’ financial independence, privacy and dignity, having spent the past eighteen months negotiating with the bank due to its failure to recognise that an EFTPOS terminal with a physical keypad is the only solution that will guarantee access for all Australians who are blind or vision impaired. It was this inability to consider the needs of its customers that led to the development of Albert: A touch screen only EFTPOS device that leaves many people who are blind or vision impaired with no other option but to divulge their PIN to a third party to complete a transaction. Under federal law all goods, services and facilities that are open to the public must be accessible to people with disability.
In 2016, Blind Citizens Australia supported several individuals who had been adversely impacted by Albert to lodge complaints with the Australian Human Rights Commission. The complaints alleged that the Commonwealth Bank had discriminated against the complainants by failing to ensure Albert could be accessed by people who are blind or vision impaired. CBA still fails to acknowledge that the inclusion of a physical keypad is the only measure that will ensure the Albert can be accessed independently, privately and seamlessly by people who are blind or vision impaired and continues to roll out its inaccessible Albert terminals to retailers, restaurants and other small businesses across Australia. The matter could not be resolved through conciliation, and the complainants were left with no option but to terminate their complaints and pursue the matter in the Federal Court.
APRA stated that a complex interplay of organisational and cultural factors has been at work and four common themes stood out; complacency, reactiveness, an insular culture and a lack of constructive criticism.
“It did not reflect on and learn from experiences and mistakes (its own and others), including at Board and senior leadership levels,” says the report. “CBA became insular. Lessons from previous incidents have not been readily captured or shared across CBA. A lack of intellectual curiosity and critical thinking about the ‘bigger picture’ and the full depth of risk issues inevitably limited CBA’s ability to learn, anticipate and adapt. CBA turned a tin ear to external voices and community expectations about fair treatment.”
Underpinning the Albert issue is the principle that a person should never have to disclose their PIN. It is a breach of privacy, as well as the agreement every customer has with their chosen bank. While the Albert terminal has an “accessibility mode”, it does not provide for seamless PIN entry as customers are required to learn an unfamiliar set of touch screen gestures via a tutorial before they can enter their PIN. This is impractical in a busy restaurant or retail environment and causes anxiety for the customer and frustration for other customers waiting in the queue.
“If you took the numbers of the screen of the Albert or any other terminal, this would not be acceptable to non-vision impaired people in a retail environment,” said one complainant. “No one would accept it. This is what CBA are expecting people who are blind and vision-impaired to accept.”
BCA continues to call on the Commonwealth Bank to immediately cease the rollout of its Albert device until such time that it can be fitted with a physical keypad. It is not acceptable to release products such as Albert without undertaking genuine consultation with consumers with disability in the design phase and it is hoped that other banks may learn from the CBA’s mistakes.