Blind Citizens Australia (BCA) knows that touchscreen technology compromises the independence of people who are blind or vision impaired in many areas of public and private life. Unfortunately, we do not have the capacity to advocate on all these issues at once, so our focus is currently on banking accessibility, with an emphasis on inaccessible touchscreen EFTPOS terminals that are increasingly being used across the retail and hospitality industries.
What to do if you encounter an inaccessible touch screen
If you encounter an inaccessible touchscreen device (other than an EFTPOS terminal), there are a few steps you can consider taking to address the matter. Note that it’s important to do these steps in order. For example, what if you encounter an inaccessible touch screen panel in a hotel lift?
Step 1
Complain directly to the business or company responsible for the device, in this case hotel management and/or the management group if the accommodation is part of a chain.
Step 2
Find out who regulates the type of business or company responsible for the device. In this case you could consider contacting the Australian Competition and Consumer Commission (ACCC) for further advice about lodging a formal complaint against the hotel.
Step 3
Lodge a complaint of disability discrimination with the Australian Human Rights Commission, or with your state-based anti-discrimination body. This is a free process.
Step 4
If you are unsure of what to do, contact us for further information or advice.
You might also like to keep up to date with the work that is being undertaken by the Digital Gap Initiative (DGI). The Digital Gap Initiative aims to contribute to efforts in Australia and internationally to promote inclusive digital accessibility. DGI’s focus is centred on advocating for legal, policy and other systemic reforms that would help reduce the barriers that people with disability and other minority groups face when using digital technology – online services, mobile apps, touch screen devices, ATMs and other automated services, digital TVs and radios, cloud technology and intranet systems in work places and educational establishments, many of which are inaccessible because they have not been designed with accessibility and inclusion in mind. You can learn more about the Digital Gap Initiative here.
Touchscreen Devices
About touch screen EFTPOS terminals
You might have already come across a touchscreen EFTPOS terminal when trying to pay for a product in a shop or settle the bill at a restaurant. If not though, you’re bound to come across one in your travels sometime soon.
These devices do not have a physical keypad with buttons like the older EFTPOS terminals we are used to using. Even though steps may have been taken to try to make these products accessible, their touchscreen-only interface makes it either difficult, or impossible for most people who are blind or vision impaired to enter their PIN independently. This has resulted in many people who are blind or vision impaired having to tell their PIN to someone else just to be able to make a payment.
BCA’s position is that a keypad with physical buttons is the only legal and accessible way for people who are blind or vision impaired to pay.
Although steps may have been taken to build an accessibility mode into a touchscreen device, this approach still falls well short of the needs of people who are blind or vision impaired for the following reasons:
- Touchscreen interfaces with variation in their use can cause confusion for people who are blind or vision impaired; not only do they need to identify which device they are presented with, they also need to remember the gestures specific to that device in order to be able to use it. This does not provide a logical and accessible solution to a device that is used in daily life, which should comply with the principles of universal design.
- If using a touchscreen device with accessibility mode for the first time, the customer is required to listen to a tutorial so they understand how to interact with the device. It is unrealistic to expect a customer to listen to a tutorial for a common public payment facility that others in the community can access without training.
- Devices with an in-built accessibility mode require users to carry headphones with them in order to hear the speech output from the device in a retail environment. Sighted consumers are not subject to these same requirements.
- Even when using headphones, it can be difficult for users to hear the audio feedback from the device in a noisy and crowded environment. This challenge proves even greater for people who have a hearing impairment in addition to blindness or vision impairment.
- The fact that the only option for PIN input is via a touch screen is discriminatory and falls well short of the needs of some customers. The majority of people who are blind or vision impaired are over the age of 65. Touchscreen technology is relatively new, and many older people do not use smart phones or other accessible touchscreen devices. This means they may be unfamiliar with the basic concepts underlying gesture-based technology. A tutorial alone will therefore not be sufficient to enable them to use it.
- The touchscreen EFTPOS and banking terminals are used by staff working in retail to complete business, banking and operational tasks. Those working in a retail environment who are blind or vision impaired must be able to access these features in order to carry out their roles.
Read our full Position Statement here.
What’s happening at a national level?
- Review of existing banking accessibility standards
- Royal Commission into misconduct in the banking, superannuation and financial services industry
Review of existing banking accessibility standards
In 2002, The Australian Banking Association (ABA) developed a set of voluntary accessibility guidelines for banking services. These guidelines are now very outdated and cannot be applied to new and emerging technologies like touchscreen EFTPOS terminals and ATMs. We have continued to lobby for the ABA to develop a new, more enforceable set of standards for banking services to ensure financial institutions do not continue to roll out products that are not accessible to people who are blind or vision impaired.
In November 2017, former Disability Discrimination Commissioner, Mr Graeme Innes AM, was appointed by the ABA to head up a review of existing electronic accessibility standards. The review is looking at existing standards, accessible authentication principles, existing bank accessibility plans, and domestic and international best practice.
BCA has been consulted extensively in the development of the new standards and we will continue to report back on new developments relating to this project.
Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
On 14 December 2017, the Australian Government established a Royal Commission to inquire into and report on misconduct in the banking, superannuation and financial services industry.
The terms of reference for the Royal Commission state:
“All Australians have the right to be treated honestly and fairly in their dealings with banking, superannuation and financial service providers. The highest standards of conduct are critical to the good governance and corporate culture of those providers.
And these standards should continue to be complemented by strong regulatory and supervisory frameworks that ensure that all Australian consumers, including business, have confidence and trust in the financial system.”
Read BCA’s submission to the Royal Commission, which demonstrate how the continued roll out of inaccessible touchscreen banking products which compromise the privacy, dignity and independence of Australians with disability falls well below community expectations.
Help us raise awareness of the issues associated with touchscreen EFTPOS Terminals
While we are undertaking extensive advocacy work on this issue at a policy level, we need your help to get the message out to businesses in your local community. Below are a few simple things you can do to help raise awareness of this issue:
Challenge 1
Whenever you come across an EFTPOS terminal that has physical buttons, you might like to start a conversation with the customer service representative about how important this is. You could also consider asking to speak to the Manager to thank them for continuing to use a device with physical buttons, or phone the store back and do this later.
Challenge 2
Whenever you encounter an inaccessible touchscreen device in your travels, you might like to provide the customer service representative with one of our EFTPOS accessibility postcards. Each postcard includes the BCA logo and contact details, as well as the tag line: “Use touch screen EFTPOS devices, lose touch with your customers”.
The back of the postcard includes the following text:
“I want to pay you, but I can’t use your EFTPOS terminal because it does not have physical buttons. The touch screen design means that people who are blind or vision impaired like me cannot enter their PIN independently. I don’t want to share my PIN with you or anyone else – nor should I have to. Please give this card to your manager. Ask them to tell your bank to stop rolling out EFTPOS machines which can only be operated using touch screens and to give you a device with a keypad with buttons instead. This is the only legal and accessible way for a person who is blind or vision impaired to pay.”
Each postcard has a hole cut out of one corner to assist with orientation. When you are holding the postcard with the front facing towards you, the hole will be in the top left hand corner. If you are holding it with the back facing towards you, it will be in the right hand corner.
These postcards are available to you at no cost, all you have to do is contact us and ask for some to be sent to your nominated address. To assist with our work on this issue, we’d also really appreciate you getting in touch to let us know when and where you’ve used a postcard.
Challenge 3
You could contact your local community radio station and ask them to run a segment on the problems associated with inaccessible touchscreen EFTPOS terminals. You could also find opportunities to raise this issue on talkback radio. If you aren’t quite sure what to say, you can obtain a one-page fact sheet from BCA that may help.
Challenge 4
You could write a letter to the editor of your local newspaper to help draw attention to the issues associated with inaccessible touchscreen EFTPOS terminals. If you aren’t sure what to include in your letter, you can contact us for further information or advice.
Help us demonstrate consumer demand for accessible banking services by lodging a complaint
- Lodge a complaint under the e-Payments Code
- Lodge a complaint under the Disability Discrimination Act
Lodge a complaint under the e-Payments Code
The e-Payments Code is a voluntary code of practice that applies to banks operating in Australia. It regulates all electronic payment transactions, including ATM and EFTPOS transactions.
All four of Australia’s major banks have subscribed to the code, including:
- Australia and New Zealand Credit Group (ANZ)
- Commonwealth Bank of Australia (CBA)
- National Australia Bank Limited (NAB)
- Westpac Banking Corporation
You can find a more comprehensive list of financial institutions who have subscribed to the code here.
Clauses 12 and 13 of the code set out a few requirements relating to privacy. Clause 12.2 A, for example, stipulates that:
“A user must not voluntarily disclose one or more pass codes to anyone, including a family member or friend”
If your encounter with a touchscreen EFTPOS terminal has resulted in you having to breach the e-Payments Code by telling your PIN to someone else, there are a few steps you can take. By following these steps, you will be supporting our work by helping to demonstrate the widespread nature of this problem.
Step 1: Lodge a complaint with the Financial Ombudsman Service
In order to do this, you will need to know which bank was responsible for issuing the touchscreen EFTPOS terminal you encountered. You can obtain this information by speaking to staff at the business where you encountered the device.
If your credit or debit card has been issued by the same bank that issued the touchscreen EFTPOS device, your case may be much stronger. Even if your card was issued by a different bank, you can still lodge a dispute with the Ombudsman. If the Ombudsman determines that they cannot investigate the matter themselves, they may refer it elsewhere. Importantly though, the Ombudsman is required to track any systemic trends that are emerging through its dispute resolution service and report on these accordingly. This will help to support the work BCA is doing at a national level by demonstrating just how many people are being negatively impacted by touchscreen EFTPOS terminals.
When lodging a dispute, it might help to make specific reference to:
- Clause 12.2 A of the e-Payments Code, which stipulates that: “A user must not voluntarily disclose one or more pass codes to anyone, including a family member or friend”
- Section 24 of the Disability Discrimination Act 1992 (Cth), which requires banks to provide goods and services that are accessible to people with disability.
You can contact the Financial Ombudsman Service on 1800 367 287, or visit the website.
You can learn more about the Ombudsman’s process for resolving disputes here.
Step 2: Notify the Australian Securities and Investments Commission about your experience
The Australian Securities and Investments Commission (ASIC) is Australia’s corporate, markets and financial services regulator. They are responsible for the administration of the e-Payments Code, including compliance monitoring.
The Commission also has broader responsibilities relating to:
- maintaining, facilitating and improving the performance of the financial system and entities in it
- enforcing and giving effect to the law
- taking whatever action they can, and which is necessary, to enforce and give effect to the law.
You can notify the Commission whenever you come across an inaccessible EFTPOS terminal that forces you to breach the e-Payments Code. Again, you might like to make specific reference to:
- Clause 12.2 A of the e-Payments Code, which stipulates that: “A user must not voluntarily disclose one or more pass codes to anyone, including a family member or friend”
- Section 24 of the Disability Discrimination Act 1992 (Cth), which requires banks to provide goods and services that are accessible to people with disability.
You can contact the Australian Securities and Investments Commission on 1300 300 630, or visit the website.
Lodge a complaint under the Disability Discrimination Act
Section 24 of the Disability Discrimination Act says that businesses must not discriminate against people with disability in the provision of goods and services. This requirement applies to banks and other financial institutions.
If you have encountered an inaccessible touchscreen device that has prevented you from entering your PIN independently, you can lodge a complaint under the Disability Discrimination Act. Your complaint will be investigated by an officer at the Australian Human Rights Commission who will attempt to help you resolve the complaint. This is a free process.
You can lodge a complaint by using the online complaint form here.
Alternatively, you can download a Word copy of the Commission’s complaint from here. Once completed, you will need to submit the form by email or by post using the following details:
Email: complaints@humanrights.gov.au
Post: Director, Investigation and Conciliation Service
Australian Human Rights Commission
GPO Box 5218
Sydney NSW 2001
If you require assistance to prepare your complaint, you can contact the Commission’s National Information Service on 1300 656 419.