June 5, 2015<\/p>\n
Lisa Pezzack
\nFinancial Sector Policy Branch
\nDepartment of Finance Canada
\n90 Elgin Street, 13th Floor
\nOttawa, ON K1A 0G5<\/p>\n
Via e-mail: paymentsconsult@fin.gc.ca<\/a><\/p>\n Re: Balancing Oversight and Innovation in the Ways We Pay<\/p>\n Dear Ms. Pezzack:<\/p>\n On behalf of CNIB and the individuals\/organizations cited herein, please find This submission has been prepared by CNIB with invaluable suggestions, Access for Sight Impaired Consumers<\/p>\n Alberta Society for the Visually Impaired<\/p>\n Guide Dog Users of Canada<\/p>\n Regroupement des aveugles et amblyopes du Qu\u00e9bec<\/p>\n One of Canada\u2019s oldest charities, CNIB passionately provides community- To do that, our dedicated specialists work with people of all ages in their rehabilitation support they need to see beyond vision loss, build their In addition to our community-based services, we also work alongside Canada is facing a growing yet preventable crisis in vision health. A Over the past years there has been progress made with respect to the 1. Three key elements in the polymer notes are designed to help blind and partially-sighted Canadians recognize bank As cited in the supporting material to this public consultation, cash is no In Canada today there are no regulations governing point-of-sale terminals.2 Unfortunately, a complete absence of any accessibility features for these or 2 http:\/\/www.fin.gc.ca\/activty\/consult\/onps-ssnp-eng.asp#ftn6<\/a> \u2013 retrieved May 2015<\/p>\n See annex 2, Regulatory landscape- Payment Cards Act.<\/p>\n 3 http:\/\/www.fin.gc.ca\/consultresp\/fcpf-cpcpsf\/fcpf-cpcpsf-eng.asp<\/a><\/p>\n In 2014, CNIB and the Neil Squire Society provided responses to the These recommendations were:<\/p>\n 1. Financial statements must be made available in alternate formats such 7. A consumer code must include rules and guidelines which protect the While we continue to stand behind all seven of these recommendations, for Recommendation: The need for accessible online and mobile payment Accessible systems are those which are usable by the largest number of 4 http:\/\/www.deafblind.com\/display.html<\/a> – retrieved May 2015<\/p>\n https:\/\/www.nbp.org\/ic\/nbp\/braille\/eb\/eb_computerhardware.html<\/a><\/p>\n 5 http:\/\/www.w3.org\/Consortium\/<\/a> – retrieved May 2015<\/p>\n Online payment systems<\/p>\n The guidelines and standards \u2013 WCAG or Web Content Accessibility better serve and benefit both Canadians with vision loss as well as the To better understand the reach and benefit of accessibility guidelines, one Mobile devices as payment methods<\/p>\n Android and iOS, the operating systems which lie at the core of Google and 6 https:\/\/msdn.microsoft.com\/en-us\/library\/windows\/apps\/dn596092.aspx<\/a> Microsoft guide on testing for accessibility<\/p>\n Recommendation: The need for accessible point of sale terminals<\/p>\n In taxis, at coffee shops, movie theatres, and grocery stores, inaccessible POSs distributed under the auspices of Canadian chartered banks fail to A POS is rendered inaccessible through the combination of a lack of In today\u2019s retail market, self-serve kiosks are becoming increasingly CSA Group standards regarding accessible POSs and kiosks have existed 7 http:\/\/shop.csa.ca\/en\/canada\/accessibility\/cancsa-b6512-07-r2012\/invt\/27026262007<\/a> retrieved May 2015<\/p>\n This Standard specifies requirements for making electronic (including electro-mechanical) and mechanical self- disabilities. It has been developed to fulfill an expressed need for a national technical Standard covering a broad https:\/\/www.otc-cta.gc.ca\/eng\/publication\/implementation-guide-regarding-automated-self-service-kiosks8<\/a><\/p>\n by subject matter experts and are reviewed periodically. Most importantly, We realize that much needs to take place before widespread deployment of 1. Keyboards MUST have real buttons, rather than touchscreen keys; We would like to reiterate that the above are the absolute minimum required As with design standards for online payment systems and mobile apps, the Finance Canada Consultation<\/p>\n As individuals who are blind or organizations of the blind, our ability to Question: Are the identified risks posed by \u201cnational retail payment systems\u201d Response: Although the consultation paper speaks at length to risks facing Canada must strive to best serve all its citizens, especially those who are Question: Are there other measures that should be considered to address Response: In short, yes. Standards for accessibility have existed for many Question: Should oversight be based on a functional approach, where risks Response: Focusing only on the consumer side of the equation, a functional other words, the current system does little to protect consumers, maximize Question: What should be the key priority areas in developing oversight for Response: We strongly suggest that accessibility for Canadians with vision
\nour response to the Department of Finance\u2019s recent call for consultation on
\n\u201cBalancing Oversight and Innovation\u201d in the ways we pay.<\/p>\n
\ncomments and input from both individuals as well as organizations
\nrepresenting Canadians who are blind or those who are living with significant
\nvision loss. We are grateful to Mr. Chris Stark of Ottawa for his insights and
\nsuggestions which have helped make this a stronger document. Mr. Stark
\nhas played a significant role in advocating for Canadians living with vision
\nloss for many years. We would also like to recognize the contribution of Mr.
\nCraig Nicol of Toronto. Mr. Nicol is an active member of the Canadian
\nStandards Association, providing input into the standards cited in this
\ndocument. Mr. Barry Abbott of Halifax has also contributed to this document.
\nIn addition, the following organizations of persons who are blind support the
\nrecommendations made herein:<\/p>\n
\nbased support, knowledge and a national voice to ensure Canadians who are
\nblind or partially sighted have the confidence, skills and opportunities to fully
\nparticipate in life.<\/p>\n
\nown homes, communities or local CNIB offices \u2013 providing the personalized<\/p>\n
\nindependence and lead the lives they want.<\/p>\n
\nCanadians who are blind or partially sighted to advocate for a barrier-free
\nsociety, and we strive to eliminate avoidable sight loss with world-class
\nresearch and by promoting the importance of vision health through public
\neducation.<\/p>\n
\ndemographic shift caused by our ageing population has led to a mounting
\nepidemic of vision loss and a growing human and resource crisis in vision
\nhealth care. The population of Canadians 65 and older is expected to double
\nin the next 25 years. Coupled with the increasing incidence of key underlying
\ncauses of vision loss, such as obesity and diabetes, the number of Canadians
\nliving with sight loss is expected to dramatically increase over the same
\nperiod. In fact, by 2024, the prevalence of vision loss in Canada is expected
\nto increase by nearly 30 per cent.<\/p>\n
\naccessibility of financial services for Canadians living with vision loss. The
\nrecent introduction of Canada\u2019s new polymer bank notes1 and the availability
\nof talking bill identifiers represented milestone improvements. Many of
\nCanada\u2019s federally regulated financial institutions have been providing
\nalternate format statements (braille, large print and accessible electronic
\ndocuments) for more than 15 years. As well, the majority of chartered banks
\ncontinue to deploy accessible automated banking machines and many
\norganizations have begun to recognize the importance of creating accessible
\nwebsites. While these developments have had a positive impact on the
\nability of Canadians living with vision loss to independently manage their
\nfinancial affairs, Canada\u2019s payment system has yet to experience an equally
\ndramatic shift towards accessibility.<\/p>\n
\nnote denominations by touch (tactile feature), sight (large numerals) or electronic signal (bank note reader).<\/p>\n
\nlonger a dominant payment method. Debit\/credit cards have gained ground
\nin the retail sector with a rapid divergence of payment methods on the
\nhorizon.<\/p>\n
\nTouchscreen technology is becoming more prevalent and at the same time
\nthe interfaces on these terminals are becoming increasingly complex.<\/p>\n
\nother emerging payment systems creates significant challenges for
\nCanadians living with vision loss. The result is for individuals unable to
\nindependently interact with these devices; they must turn to strangers in
\norder to complete even the most basic of transactions. Although we have no
\nevidence of persons with vision loss being victimised by having to rely on
\nperfect strangers to complete purchases, this is clearly unacceptable as well
\nas a contravention of most consumer debit and credit card agreements.<\/p>\n
\nFinancial Consumer Protection Framework consultation.3 The Neil Squire
\nSociety focused on the impacts on persons with mobility, cognitive and
\nhearing disabilities, while CNIB focused on the impacts for individuals with
\nvision loss. In our submission, CNIB provided seven recommendations which
\nif implemented would improve the security, confidence and accessibility of
\nfinancial management and interactions to Canadians living with vision loss.<\/p>\n
\nas braille, large print or accessible electronic documents;
\n2. Websites, online payment systems and mobile payment apps must be
\nmade accessible to people relying on assistive technology such as
\nscreen readers, refreshable braille displays or large print;
\n3. Point of sale terminals must enable consumers with vision loss to
\ncomplete transactions independently and they must be able to verify
\ntheir purchase amounts;
\n4. Automated Banking\/Teller machines need to be accessible by persons
\nwith vision loss;
\n5. Financial institutions operating retail outlets must be accessible to all
\npersons with disabilities including those with vision loss;
\n6. Frontline and customer contact centre representatives should receive
\nadequate training on how to best serve customers with disabilities;<\/p>\n
\ninterest of and insure the full participation of Canadians with
\ndisabilities.<\/p>\n
\nthe purposes of this consultation we would like to strongly reiterate
\nrecommendations two and three. This paper will focus its comments on
\nindividuals living with vision loss and accommodations required for their
\ninclusion and benefit. However, it is imperative that accessibility for all
\nCanadians regardless of disability be an integral part of the conversation
\nbeing initiated by Finance Canada.<\/p>\n
\nsystems<\/p>\n
\npeople regardless of how they interact with them. People with vision loss
\nrely on a variety of techniques and assistive technologies to either enlarge
\nthe text on their systems – large print – or to have the information spoken
\naloud using synthetic text-to-speech software. While these two subgroups
\nrepresent the vast majority of technologies regularly used by individuals
\nliving with vision loss, there are other devices \u2013 refreshable braille displays –
\nmost commonly used by people who are both deaf and blind.4<\/p>\n
\nGuidelines – required to make online payment systems accessible are robust
\nand have kept pace with each iteration of HTML, the language web browsers
\nuse to display content. These guidelines are maintained by the World Wide
\nWeb Consortium, an international community which maintains some of the
\nstandards pertaining to how internet applications and content work.5 Online
\npayment systems adhering to these standards will go a long way to
\nmaximize the accessibility for all Canadians, especially those who rely on
\nassistive technology. As with many disability accommodations, the benefit of
\nadhering to WCAG is that this adherence leads to a product that has
\nincreased usefulness for a broader range of users. WCAG-adherent products<\/p>\n
\nbroader community \u2013 an effect often referred to as the \u2019disability dividend\u2019.<\/p>\n
\nneed only consider automatic doors, kneeling buses, ramps and cut curbs.
\nInitially designed to increase accessibility for persons using mobility devices,
\ntoday these accommodations are common place and facilitate access for the
\ngeneral public. Yet another example is the availability of closed captioning,
\nnow available with practically every television program. Again, this
\naccommodation initially intended to enable persons who were deaf to have
\naccess to mainstream programming, but now enables viewers without
\nhearing loss to consume media produced in languages other than their
\nmother tongue. Accommodations such as these have become the norm
\nacross the country, integrating WCAG guidelines into web and online app
\ndevelopment is the next logical step in ensuring Canada is an accessible
\ncountry for all its citizens and visitors. Indeed, failing to integrate
\naccessibility into online systems and mobile apps would only further
\nmarginalize Canadians living with vision loss.<\/p>\n
\nApple mobile devices, offer extensive guidelines on how to design and build
\napplications which can be used by people living with vision loss. As the
\nnumber of mobile devices available to Canadians continues to grow, it is
\nextremely likely that mobile payment apps will continue to become more
\nprevalent. The need for standards to make these devices accessible to
\npeople having diverse needs is becoming more and more glaring. These
\nstandards do exist with many mainstream manufacturers of mobile devices
\n(for example, Apple, Android, and Black Berry)6, yet are far too often
\nignored; this willful disregard of the standards must cease.<\/p>\n
\nhttp:\/\/docs.blackberry.com\/en\/developers\/deliverables\/11936\/Intro_to_Accessibility_API_791538_11.jsp<\/a> retrieved
\nMay 2015<\/p>\n
\npoint of sale terminals (POS) are becoming increasingly prevalent. Even<\/p>\n
\nincorporate any accessibility guidelines. Making matters worse is the
\nproliferation of white-label terminals in the POS market. These devices are
\noperated by commercial enterprises independent of chartered banks and are
\nthereby at the periphery of Canada\u2019s consumer protection regulatory
\nframework. This results in a growing number of completely inaccessible
\ndevices entering Canada\u2019s payment system market place, which serves only
\nto increase the barriers faced by Canadians who have vision loss as well as
\nother disabilities.<\/p>\n
\nstandardization around its development, coupled with an absence of
\naccommodation features. Few POS devices adopt similar command
\nsequences; the order of interactions with them varies between manufacturer
\nand distributer. Thus, particularly for consumers who are blind or deafblind,
\ncompleting a transaction often requires having a stranger assist with
\nentering a Personal Identification Number, or PIN. Not only does this place
\nconsumers with vision loss at increased risk of fraud should their PIN be
\naccessed by others; but it contravenes the terms and conditions of service
\nissued when debit\/credit cards are issued – that the holder of such cards is
\nrequired to keep their PIN confidential. This also means individuals living
\nwith vision loss are unable to verify the amount being charged to their debit
\nor credit cards. When relying on another person to verify a transaction, it is
\nfar too easy for errors to be made. Without the ability to independently
\nverify transactions, consumers with vision loss may only discover these
\nerrors long after they have completed their transaction and must then go
\nthrough a time-consuming dispute process<\/p>\n
\ncommon place. Despite the presence of voice output on some of these
\nterminals, they are for the most part of little use to Canadians with vision
\nloss. The need to interact with the terminal via touchscreen technology and
\nthe absence of full speech output likens these devices to the early versions
\nof automated banking machines which had braille on the keypad but no
\nspeech or large print output.<\/p>\n
\nsince 2007.7 CSA standards are recognized around the world, are developed<\/p>\n
\nservice interactive devices accessible to and usable by people with a range of physical, sensory, and cognitive<\/p>\n
\nrange of interactive devices.<\/p>\n
\nthe standards are developed at arm\u2019s length from manufacturers and are
\ndesigned to have the broadest possible reach when implemented. We believe
\nthat were these standards to be adhered to within the POS landscape,
\nCanadians with vision loss would no longer risk having their security and
\nprivacy compromised by having to rely on others for assistance.<\/p>\n
\naccessible POSs takes place. In the interim, we believe that a POS should
\nadhere to the following:<\/p>\n
\n2. Pushing a button MUST generate a confirmation beep, and the volume
\nof this beep should be adjustable, and this function must not have a
\ndeactivation option;
\n3. The number \u201c5\u201d button MUST have a raised dot, and the \u201cOK\u201d button
\nMUST have a raised circle;
\n4. Usage methods MUST be standardized, from the order of operations to
\nthe placement of buttons on the keyboard;
\n5. Visual displays must provide adequate contrast and stylized fonts must
\nbe avoided.<\/p>\n
\nfor Canadians with vision loss to be able to independently and with a modest
\ndegree of confidence complete transactions using a POS device.<\/p>\n
\n\u2018disability dividend\u2019 for POS devices would extend far beyond the community
\nof individuals living with vision loss. The ease of completing POS transactions
\nin poorly lit environments, requiring a consistent transaction interface and
\neliminating touchscreen devices are only a few examples of how adherence
\nto CSA standards would benefit all and not just those who are part of the
\nvision loss community. Implementation of accessibility standards would not
\nbe unprecedented. In fact, the Canadian Transportation Agency has already
\ntasked airline and terminal operators to have accessible self-serve kiosks in
\nplace by December 2016.8<\/p>\n
\ncomment on the questions set out in this consultation is limited only to areas
\naround vision loss. Thus, the comments above and the following discussion
\nis limited strictly to the impact we perceive on Canadians with vision loss.<\/p>\n
\ncomprehensive. Should other risks be included?<\/p>\n
\nthe Canadian payment system, we would like to suggest that more research
\nbe undertaken to better understand the risks facing consumers living with
\nvision loss. As referenced earlier in this response, the number of Canadians
\nliving with vision loss is set to increasingly expand in the very near future.
\nAs such, accommodations made to better and more efficiently serve the
\nvision loss community are becoming more and more essential.<\/p>\n
\nliving with a disability or otherwise marginalized. No system, irrespective of
\nhow well designed or accessible, will completely eliminate all risks. However
\na complete absence of the consideration of the needs of vulnerable
\npopulations is definitely not the answer.<\/p>\n
\nthese risks?<\/p>\n
\nyears but adoption and adherence is sparse at best. CNIB would welcome a
\npayment system that\u2019s fully accessible without compromising consumer
\nprotection. New technologies should not be adopted simply because they
\nexist. Rather, leading edge technology and accessibility should be at the
\nforefront of Canada\u2019s payment system. Institutional stakeholders must be
\nheld accountable to ensure that only systems and devices usable by the
\nlargest number of Canadians make their way into the payment system
\nlandscape.<\/p>\n
\nare assessed by payment activity and treated similarly regardless of the
\nprovider?<\/p>\n
\napproach would insure the greatest level of inclusion for all Canadians. In<\/p>\n
\nefficiencies and provide retailers with cost effectiveness. The proliferation of
\npayment solutions does not mean that all should be present in the
\nmarketplace. A better approach would be imposing well-defined, well-
\nresearched and regularly updated standards against which all payment
\nsystems in Canada must be measured. These standards, including those
\ndealing with accessibility, should form the measurement against which
\ncurrent and future retail payment systems are evaluated and embraced.<\/p>\n
\nretail payment systems?<\/p>\n
\nloss must be an integral component of Canada\u2019s retail payment system. It is
\nabundantly clear that guidelines are not adequate as they are rarely and
\ninconsistently adopted. The US has witnessed landmark legislation, with the
\n21st Century Communications and Video Accessibility Act, being the most
\nrecent example.9 This legislation, passed in 2010, requires that accessibility
\nbe incorporated into emerging technology.<\/p>\n