Evaluation of Mobile Payment Systems for People with Disabiliti

The Digital Divide: Challenges People with Disabilities Face
Due To Rapidly Changing Payment Services Technology
Submitted by:
Dr. Gary Birch
Neil Squire Society
Suite 220-2250 Boundary Road
V5M 3Z3
Ph: 604-473-9263
FAX: 604-473-9364
EMAIL: [email protected]
Contributors: Harry Lew, Dan Leland, Dr. Gary Birch
Date: September 15, 2010
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Executive Summary
Handling money, bank cards and cheques present challenges for many people with
disabilities. The ability to conduct financial transactions independently has been
identified as a top priority need in previous studies and legal rulings here in Canada and
in other countries. While on-line shopping has opened up new avenues for purchasing
without having to physically handle cash it does not help the consumer wishing to
conduct on-the-spot transactions such as paying for restaurant meals. New Smart Card
and Near Field Communication based systems that allow users to make payments by
waving a card or fob at a target are gaining momentum. Unfortunately many
consumers, specifically those with disabilities, are unable to use these systems as they
require a person to visually locate a target, physically manipulate a device or card, and
react to an auditory cue.
Recently, mobile phone based financial applications are beginning to gain ground.
Applications exist that allow users to conduct financial transactions over their mobile
phones by calling an automated customer service representative, text messaging, or
accessing a mobile web application. These systems allow users to conduct a range of
financial transactions including buying products and services, banking, and transferring
money to other people.
Assistive technologies (ATs) aimed at improving the accessibly of payment services
technology (PST) have been developed to address the needs of some disability groups.
These include talking screen readers for people with vision impairments, hearing aid
compatible devices and voice activated applications for those with mobility impairments.
Suitably AT equipped PST could potentially provide accessible options for people
wishing to conduct payment service transactions independently, but the speed at
which technology is being deployed, the lack of consideration of the specific needs of
people with disabilities at the design stage and the lack of pro-active initiatives by
industry to address accessibility issues have created a “digital divide”. The digital divide
describes the unequal access to services, not only in the area of payment services, by
people with disabilities when compared to people without disabilities. The result is
“unequal” access to services considered fundamental to participation in the community.
This submission examines the systemic way the digital divide has widened in the last 20
years. It will examine significant deployments of evolutionary and revolutionary
technologies that have changed the ways Canadians conduct payment transactions and
the resulting digital divide that has been created, the band aid solutions that have been
applied to help people with disabilities try to catch up and the resultant lack of significant
initiatives by industry to pro-actively address existing and new issues in a meaningful
manner. This submission also examines some emerging technologies involving mobile
phones that have either been launched recently or are being considered for launch in
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the near future and the inherent lack of accessibility of these services will have if the
needs of people with disabilities are not taken into consideration.
Financial transactions are an essential part of everyday life. Not a day goes by where
someone doesn’t make a retail purchase, buy a ticket for a show, pay for a meal in a
restaurant, or pay for parking. Up until recently, the ability to handle money and bank
cards was critical to being able to conduct these types of transactions independently.
For many people with disabilities, using money and bankcards present challenges.
People with mobility impairments have a hard time physically manipulating cash and
cards. They may also face problems reaching the terminal or interacting with the
physical interface. People with vision impairments are faced with the challenges of nonstandardized bank machines and point of sale devices, identifying item pricing, billing
errors, and handling cash. Many people with hearing impairments may have difficultly
communicating their needs during a purchase.
The ability to conduct financial transactions independently has been identified as a top
priority need in previous focus groups conducted by the Neil Squire Society .[1] Focus
groups identified public services that presented the most challenges for people with
vision and mobility impairments. Financial transactions were rated amongst the top
three responses for both groups. People with disabilities participated in mobile payment
transaction simulations based on technology that was ‘mocked up’ for the lab setting.
The simulations focused on a restaurant scenario in which participants used a mobile
phone or handheld computer to access information (a restaurant menu) and conduct a
payment transaction (pay the bill). Participants agreed that these types of services
would be an improvement over what is currently available for them today.
Automatic Banking Machines
The financial services industry has historically been very slow to respond to the needs
of people with disabilities. Consumers who have a disability are often caught in a
“digital divide” as traditionally very little thought has been put into making new
technologies accessible to all users. This digital divide is prominently demonstrated in
the lack of accessibility of automated bank machines (ABMs). A 1994 study sponsored
by the Canadian Human Rights Commission showed a low level of accessibility across
most ABMs.[2] In late 1995, in response to this study, the Canadian Bankers
Association commissioned a report to look at the underlying need to develop standards,
find standards that existed in other countries, and determine the gaps that existed in the
knowledge base that would make developing appropriate standards difficult. The
resulting “Guidelines for Development of a Canadian Standard of Accessibility for
Persons with Disabilities and Seniors”, formed the basis of the Canadian Standards
Association standard for accessible banking. [3, 4] The consultation process took
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several years and shed light on the security, physical and technological constraints
inherent in modifying ABMs, and revealed consumers varying needs and preferences.
The process to get the initial findings to become a recognized standard took 6 years to
complete. Despite the fact that the standard was released in 2001, it is only in recent
years that ABMs which meet the standards are being deployed. [5,6,7,8,9,10,11,12] It
is important to note the standard is voluntary. It has no legal standing nor is there a
formal process to enforce compliance except through a human rights complaint to the
Canadian Human Rights Commission. This standard applies to machines installed in
new bank premises, new installations in branches the previously did not have any ABMs
or where the number of ABMs is being increased or premises that are undergoing
significant renovations (eg., moving walls, relocating the main entrance etc, as
opposed to giving the bank a new paint job.) . In addition the standard applies
only to the ABMs that belong to organizations that are subject to the Finance
Act, federally-regulated financial institutions. There are a large number of generic
machines deployed that do not have to meet these standards. As a result there are still
many locations where accessible terminals are not available. The length of time and
complexity of the process demonstrates the need to develop a knowledge base
necessary to start the discussion on potential accessibility standards for new
technologies as early as possible. It also demonstrates the lack of pro-active and
consistent effort by industry to engage the disability community to identify problems
early. It took a human rights complaint to get industry to respond and the reach of the
resulting standards is limited to only a specific segment of the industry.
Point of Sales Systems
We have seen a similar process play out in the deployment of point of sale terminals.
Point of Sale terminals have been around since 1994.
“Canada has a nation-wide EFTPOS system, called Interac Direct Payment. Since
its introduction in 1994, IDP has become the most popular payment method in the
country. Previously, debit cards have been in use for ABM usage since the early
1980s. In the early 1990s, pilot projects were conducted among Canada's six largest
banks to gauge security, accuracy and feasibility of the Interac system. Slowly in the
later half of the 1990s, it was estimated that approximately 50% of retailers offered
Interac as a source of payment. Many small transaction retailers like coffee shops,
resisted offering IDP to promote faster service. In 2009, 99% of retailers offer IDP as an
alternative payment form.
In Canada, the debit card is sometimes referred to as a "bank card". It is a client card
issued by a bank that provides access to funds and other bank account transactions,
such as transferring funds, checking balances, paying bills, etc., as well as point of
purchase transactions connected on the Interac network. Since its national launch in
1994, Interac Direct Payment has become so widespread that, as of 2001, more
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transactions in Canada were completed using debit cards than cash[13]. This
popularity may be partially attributable to two main factors: the convenience of not
having to carry cash, and the availability of automated bank machines (ABMs) and
Direct Payment merchants on the network.
In Canada, the bank cards can be used at POS and ABMs. Interac Online has also
been introduced in recent years allowing clients of most major Canadian banks to use
their debit cards for online payment with certain merchants as well. Certain financial
institutions also allow their clients to use their debit cards in the United States on the
NYCE network.”[14]
Canada still lacks a process to ensure accessibility of these devices. A recent Human
rights complaint in Quebec settled earlier this year highlights the lack of understanding
of even basic accessibility issues. [16,17] A customer in a wheel chair could not reach
the POS device because it was bolted to a base on the counter. Though this was done
to prevent the theft of the machine, the business did not provide an alternative method
of access. It is important to point out that this ruling applies only to one disability. Users
who are blind or have low vision often have difficult inserting the card in the card reader
and also in reading the information on the display of the device, while people with some
forms of mobility impairments may not be able to activate the keypad or insert their
cards at all. Most merchants in Canada do not supply alternative access, as there is no
regulation in Canada mandating the deployment of accessible POS terminals.
A 2009 study by researchers at the Georgia Tech Research Institute found that:
“POS machines pose a number of accessibility issues. The physical design of these
types of devices, which are often large and designed to be used by users in a standing
position, can result in difficulties for users with lower mobility impairments. Interacting
with the various components of POS machines can be difficult for users with upper
mobility impairments, and the lack of standardization in the layout of components
among machines can create difficulty for users with visual impairments. POS machines
sometimes have complex user interfaces that support a diverse range of functions, and
the complexity of the interface can pose problems for users with cognitive impairments.
Other aspects of the design of user interfaces for POS machines can cause problems
for users with impaired vision or hearing, as well.” [18]
The authors are aware of a study that pre-dates this work, 2004, that looked at the
accessible of POS terminals available in Canada, but it is not available publicly. This
work came to many of the same conclusions outlined in the George Tech report.
We have seen recent initiatives to address these inequities in regional jurisdictions such
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as California. In California, the disability community, most notably the blind community,
have been able to get the state government to enact legislation that addresses some of
the accessibility issues involving the accessibility of POS terminals. In September of
2005, after strong opposition from the business community, the governor signed into
law Bill AB2312. [19]
“California Bill AB2312 requires :
“that on and after January 1, 2009, a manufacturer or distributor of touch-screen
devices used for the purpose of self-service check-in to offer for availability devices
that enable visually impaired persons to use a self-service check-in device
independently and to process a transaction with the same privacy protection afforded to
persons who are not visually impaired. “[20]
Keep in mind the law is still silent on the accessibility issues encountered by people who
have mobility impairments, who are deaf and who have cognitive impairments. These
other groups, in some cases, lack the coordinated political effort of disability
communities such as people who are blind. Despite the new legislation to address the
accessibility of POS terminals, it is important to remember that this only represents one
jurisdiction. Recognizing the inequities of the current POS systems, the disability
community has pushed ahead in other jurisdictions via individual lawsuits against
specific retailers.[21, 22, 23, 24, 25, 26, 27, 28, 29, 30] Canada does not have the
same degree of activism or as litigious an environment, but this does not mean that
inequities do not exist.
Mobile Device Based Payment Systems
In recent years, alternative forms of payment have been gaining in popularity. On-line
purchasing has become ubiquitous. While the introduction of on-line shopping has
opened up new avenues for purchasing without physically handling cash, web-based
shopping does not help the consumer wishing to conduct an on-the-spot transaction
such as paying for a restaurant meal or buying a newspaper.
Near Field Communication (NFC) and Contactless Smart Card based payment systems
are gaining momentum for on-site payment scenarios. NFC-enabled mobile phones,
fobs or cards feature embedded chips that allow users to make payments by tapping or
waving the card or phone at a point-of-sale terminal reader. While these systems
provide an alternative method to cash or debit and credit cards, they still require
consumers to visually locate a target, physically manipulate the phone or card, and
react to audio cues. While a lot of work has gone into developing guidelines to improve
the accessibility of NFC and Smart Cards, these limitations make these systems
inherently not well suited for many people with disabilities. [31, 32 ,33, 34, 35, 36, 37,
38, 39, 40, 41, 42, 43, 44, 45]
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During the last 10 years, mobile phone services have been developed that allow
consumers to conduct a range of financial transactions including buying products and
tickets, making donations, doing their banking, and transferring money to other people.
Unlike NFC equipped phones that simply carry a smart chip and are detected by a
nearby reader, these services utilize the interactive capabilities of the mobile phone.
Depending on the system, the transactions can be conducted by sending a text
message, calling a 1-800 number and using an automated voice menu system, using a
mobile phone application, or using a web-based application. Some payment services
provide a choice of more than one access method. To make a transaction, users
typically pre-register for a particular service via telephone or on-line with a PC. Then
they simply log into the system via their mobile phone and enter transaction details.
Once the consumer has authenticated the purchase with a personal identification
number (PIN), the money is automatically transferred to the intended recipient.
Payment history and account balances can be stored on the phone or viewed online.
Some of the services launched in recent years are listed below. (as of Nov.2008)
Purchasing products using codes found directly in magazines (PayPal Mobile,
OboPay, ShopText, TextPayMe, MyTango, iPayText, BillMyCell )
Transferring money between friends (PayPal Mobile, ShopText, TextPayMe, OboPay,
MyTango, iPayText, BillMyCell)
Monitoring restaurant bills and paying at the table using a cell phone (PayWi,
Pre-ordering and paying for food at fast food restaurants (Gomobo - used by some
Dunkin Donuts/ Subway outlets in the US)
Banking (ClairMail/ Telus and Firethorn/ Verizon, M-wallet)
Purchasing digital tickets and receiving gift vouchers (BillMyCell,SwiftPass): Tickets
and vouchers can later be redeemed by scanning bar code sent to the phone and/or
verifying on web-based databases.
Purchasing movie tickets (Movietickets.com, amazon.com, MobileFandango.com,
MobilRelay, and MovieBoxOffice): These services allow consumers to use a webenabled mobile phone to look up movies and show times and then purchase tickets
directly on their phone.
Paying for parking (Verrus, Digital Payment Technologies): Users can receive a
message that parking is about to expire and can also add more time with their mobile
These services can essentially be divided into four types or methods of access; voice
call, web site access, or text messaging, and downloaded mobile phone applications.
The mobile phone “application” refers to a software program that people must download
to their mobile phones in order to access a particular service.
The advent of m-commerce (mobile) and the potential to perform financial transactions
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using mobile wireless technology, may offer people with disabilities an alternative
means to make purchases or possibly present another barrier, depending on how the
technologies and services are rolled out. The Neil Squire Society released a study
earlier this year that investigated the accessibility issues of several mobile phone based
payment systems and services. While some AT solutions exist that increase the
accessibility of mobile phones, the study looked at whether these accommodations
were sufficient given the tasks the users must complete to conduct a mobile payment
transaction. The study comprised a series of user trials including people with mobility
impairments and members of the Blind, Deaf and Hard of Hearing communities. The
study included a review of existing mobile phone based payment systems and services,
supporting assistive technologies and compatible mobile phones. The Neil Squire
Society collaborated with 3 other organizations including the Canadian National Institute
for the Blind (CNIB), the Canadian Association of the Deaf (CAD) and the Canadian
Hard of Hearing Association (CHHA).
Some examples of the services included in the study are presented below. The
researchers were unable to find a mobile application (that is downloaded to a phone)
that was actually in use so it was dropped from the study. Where the service was not
available in Canada, a simulation of the payment system was used for the study. As the
objective of the study was to study the underlying implementations of the systems and
the inherent accessibility issues these implementations created, the availability of the
services to Canadians at the time of the study was not critical.
1.) Voice Menu Based Service - Pay-By-Phone Parking
For most people, a 1-800 number retail purchase typically conjures up the Home
Shopping Network example. Even department store catalogue telephone shopping
is associated more with shopping from home. Pay by phone parking is gaining some
significant momentum among mobile users and many cities are offering parking meter
payment via mobile phone access. In a parkade scenario, a person simply calls a
number posted in the parking lot. First time users register on-line or on-the-spot by
supplying their credit card info and mobile phone number. Then they simply follow the
verbal instructions given by an automated voice menu system; enter the lot location
number, parking stall number, and the amount of time they wish to park. They can even
receive a mobile phone call if it is getting close to their expiry time. The service is also
available for taxicab payment in some areas.
2.) Web Based Service –purchasing tickets
Purchasing Movie Tickets is a type of mobile service that is also gaining popularity. The
advantages of purchasing a ticket for a movie or concert on a mobile phone may not be
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obvious to everyone, but the purchase of an electronic ticket for transit starts to make
sense. The movie ticket purchase is representative of almost any type of service that
requires a ticket purchase in general.
Basically, the service offers a web site with nation-wide theatre locations, movie listings,
and times, as well as the option to purchase an advanced ticket. Once a person
registers their credit card with the service on-line, they can then access a mobile version
of the web site anytime and purchase a ticket. Below is a screen shot of the home page
of one such service.
This is a screen shot of the remainder of the home page. The portion of the home page
the user sees depends on the width and height of the screen on their Smartphone.
3.) SMS Service -
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Text shopping allows people to buy items from advertisements predominantly
in magazines that are labelled with the service provider’s icon. They must first
register on-line. Then when they find an ad with that services logo, they text the
keyword from the advertisement to a 6 digit access number and receive a response with
details of the purchase and a request for the user’s PIN to complete the purchase
process. Finally, they receive a confirmation of the purchase via text as well. . Below
is what a screen shot might look like for the first reply that the user receives when the
user sends a text message containing the advertised word to the supplied phone
This is an example of a response the user might see when they reply to the SMS
message with an SMS message containing their PIN.
4.) Web Link and SMS Service –
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Services like PayPal provide transaction options for transferring money and purchasing
goods from eBay. They offer a web based application and an SMS or text messaging
application. Their Text-to-Buy application is similar to ShopText but combines SMS and
Web access. People register on-line and are then able to access the service through
their mobile phones. To make a purchase they text a Text-to-Buy keyword from an
advertisement to a 6 digit number and they receive a web link in return. By clicking on
the link they are taken to the PayPal product web page that displays the product
information. The remainder of the purchase process is completed on the web site.
This is an example of what a text response with a web link might look like.
These services represented the main mobile purchasing methods being used at the
time and were services that had the broadest distribution. It is likely that more
interesting and more practical services will appear in time as mobile services begin to
mature and catch on.
The study highlighted two inter-related issues that define the challenges surrounding the
creation of accessible payment services for people with disabilities. The first is basic
access to the features of the mobile phone themselves. Each disability group faces
unique challenges that need to be addressed by the hardware and appropriate assistive
technology. In some cases, those solutions currently do not exist or are no longer
available due to the quick pace of change in the mobile device market. The second is
the accessibility of the services themselves. In some cases, the technology is relative
new and accessibility standards currently do not exist for the technology. In other cases
the service providers have decided not to follow existing accessibility guidelines.
Compliance in many Canadian jurisdictions is not mandatory and many do not apply to
service providers that are not based in Canada.
Mobile Phone Accessibility
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In order for some people with disabilities to access the payment systems described
above, accessible mobile phone platforms must be available. As the needs of people
are varied, there is no single global solution for accessibility that will work for all
disability groups. However, the importance of communications for people with
disabilities is widely recognized and government regulations in countries such as the
United States have been successful in ensuring that assistive technologies (AT) have
been developed to meet the needs of some of these consumers. Lack of equal political
pressure from all disability groups means that some needs have been addressed while
others have not. Mobile phone manufacturers have been slow to respond to
government and disability organization pressure. As a result there are a restricted
number of phones that are designed to meet the needs of users with disabilities, most
notable for persons with hearing or vision impairments and some users with mild
mobility impairment that effect their dexterity. People with moderate to severe mobility
impairments and cognitive impairments have few options, or none at all, when it comes
to accessing anymore than the basic telephone features of a mobile phone. Also, the
product development cycles are too fast for third party AT developers to keep up with.
The CRTC recognized the challenges faced by people with disabilities in accessing
handsets and the role Canadian wireless service providers can play in its report of July
2009. It issued a directive for wireless service providers
“to offer at least one mobile handset for persons who are blind and/or have moderate to
severe mobility and/or cognitive disabilities by October 21 2009”
and to
“…provide reasonable technical and lifecycle support for the handset to address special
needs and assistive technologies”
The Canadian Telecommunications industry has been slow to react to this directive. No
Canadian wireless service provider currently complies with these directives. It is
important for this happen in order to ensure fundamental access to new payment
services. Correspondingly, a bill is working its way through the legislative system in the
United States, H.R. 3101: Twenty-first Century Communications and Video Accessibility
Act of 2009, that re-defines and broadens the services that should be accessible to
include digital services. [47] In the past the telecommunications industry has defined
accessibility to apply only to basic telephone services. The Twenty-first Century
Communications and Video Accessibility Act of 2009 recognizes the new class of digital
services that are available on mobile devices. It should be noted that the CRTC
definition of handsets under the directive already includes these and future applications
and services.
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On the services side, it should be noted that except for direct government services there
is no legislative mandate for commercial organizations to adhere to existing accessibility
guidelines such as the Web Content Accessibility Guidelines (WCAG) 2.0. [48] New
regulations written under the mandate of he Accessibility for Ontarian with Disabilities
Act of 2005 expands the definition of accessibility services to cover commercial
organizations in Ontario. [49] “The proposed Accessible Information and
Communications Standard outlines how businesses and organizations will have to
create, provide and receive information and communications in ways that are accessible
for people with disabilities. The proposed Accessible Information and Communications
Standard will require obligated organizations to:
•”provide information and communication to people with disabilities in a way that
accommodates their disability, and
•make websites accessible”
People with disabilities have traditionally had to play catch up, having to push for
change well after new technologies have become mainstream. Given the pace at which
new technologies are introduced and adopted, it is important for the disability
community to look ahead, identify emerging trends, evaluate new technologies before
they become mainstream, discover accessibility issues and, where possible, suggest
solutions. Many disability organizations lack the funding and the in-house technical
expertise to do this, but a few organizations such as the Neil Squire Society are trying. It
still requires a commitment from industry to recognize the issues brought forward and
make a commitment to solve the issues that are creating the inequalities. Historically,
industry has been slow to react due to the perception that any solution would add
unacceptable extra cost to the devices or services.
The study released by the Neil Squire Society has tried to do this in the area of cell
phone based payment system. Not mainstream yet, cell phone based payment systems
are an emerging trend that has the potential to change the way Canadians carry out
retail transactions. We have already seen similar initiatives in the banking sector. Most
of the major banks have a system to allow customers to check their balances and
transfer funds through their cell phones. Cell phone payments for products and service
have been slower to be adopted but, as noted above, we see systems to pay for
parking, buy a movie ticket and even buy a product from a magazine ad or an item on
auction via a cell phone.
The Neil Squire study looked at the primary methods of payment that seem to be
emerging in this sector. The study highlighted 13 key accessibility issues that affected
these transaction methods, including some of the following:
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o The voice menu system did not allow sufficient time for users with mobility
impairments and some users who are blind to enter the requested data on their
touchtone keypad.
o Deaf users were obviously not able to interact with the voice menu system and
no alternatives are currently offered.
o The web-based transaction systems studied did not adhere to all the Web
Content Accessibility Guidelines, which caused issues for users who were blind
and used screen-reading software. Correspondingly, format issues affected the
ability for people with severe mobility impairments to navigate through the
o The SMS based transaction system highlights the lack of support for embedded
links within a SMS message on some models of phones. Correspondingly no
screen reader compatibility standard exists for descriptive alternative text for
embedded links under any accessibility standard as embedded links within SMS
messages is a recent innovation.
It is an area where more work needs to be done. None of the services was without at
least one accessibility related issue. As pointed out previously it is difficult to create
one unique solution to all types of disability. The solution to this issue is to ensure
that multiple methods of access to the service are provided. Like consumers without
disabilities, individual needs are unique to each consumer. One consumer may
prefer to use an interactive voice activated system while another might prefer
internet or text messaging access. People with disabilities are no different in that
they have their own unique needs and preferences.
Privacy and Security
In the study, even though a number of participants expressed some concerns about
security and privacy, most participants were willing to reveal personal information during
the registration process if necessary. 78% of the blind participants, 70% of the deaf
participants and 100% of the hard of hearing participants said they were willing to reveal
personal information during the registration process if it was necessary. Only 43% of the
participants with mobility impairments were willing to reveal their personal information
during the registration process if it was necessary. Three of the participants have
personally experienced some form of identity theft or fraud. One of these participants
was deaf and two had hard of hearing conditions. 66% of the participants who were
hard of hearing expressed concerns about privacy and security. A smaller number of
participants in the other disability categories expressed security concerns. 28% of the
participants with mobility impairments and 14% of the participants who were blind
expressed similar concerns. It is a real concern, as during the course of this study, the
credit card that researchers opened to facilitate the setting up of transaction payment
accounts with the various service providers was compromised.
A recent Analytica study showed that:
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“Consumers remain very concerned about the security of online transactions.
- Of the 322 consumers in the study that had never purchased on the Internet, 43.5%
cited security concerns as the reason. This group expressed concern about exposing
account and personal information that could lead to identity theft.
- Among consumers that had purchased infrequently (fewer than three times annually)
on the Internet, 26% cited security as the reason they do not shop online more often.
Again, the potential for identity theft was a frequently mentioned concern.
- Of the frequent purchasers (more than three times annually) who identified PayPal as
their preferred method of payment, 59.1% cited security as the primary reason behind
their choice. Yet while security is important for many consumers — it is not the only, or
even the most important, consideration when choosing a payment method”. [51]
Reasons for using these transaction methods
The most cited reason for using one of these mobile transaction methods was
convenience. 62% of participants quoted this as a reason for using the system.
In the case of participants who were deaf, they also have the added benefit of not
having to interact with individuals that do not know American Sign Language (ASL).
55% of the participants commented that having to interact with sales people not fluent in
ASL was a frustrating experience for them.
The aforementioned Analytics study suggested some similar reasons among the
general consumer population.
“Consumers that purchase frequently on the Internet (more than three times per year)
cited the following reasons for their preferred payment method
Credit Cards
Convenience (47.9 %)
Security (20.9%)
Incentives (12%)
Debit Cards
Control Over Spending
Convenience (25.3%)
Directly From Chequing
Account (18.5%)
Security (59.1%)
Convenience (39.8%)
eBay Usage (9.8%)
Number of People with Disabilities in Canada
According to the 2006 Participation and Activity Limitation Survey done by Statistics
Canada, there are 3.621 million people with disabilities in Canada. Of that number,
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2.286 million have mobility and agility impairments, 506,000 people are deaf or hard of
hearing, 326,000 are blind or have a visual impairment and 503,000 have a cognitive
impairment. The disability rate in Canada increases steadily with age. The rate is 11.5%
among adults aged 15 to 64 and rises to 43.4% among persons aged 65 and over. In
fact, more than half (56.3%) of persons aged 75 and over reported having a disability.
Historically, people with disabilities have not been taken into consideration when new
technologies have been deployed in the payment service sector. This has been
demonstrated by the way ABM and POS systems have been deployed. It has only been
after formal complaints such as human rights complaints have been initiated that
industry has typically responded. The rate of which new technology is developed and
deployed has also accelerated in recently years. As a result, the digital divide has
grown. It is important that governments, industry and disability organizations work
together to pro-actively solve issues early on in the design process. Unfortunately, there
is no formalized process or funding mechanism to make that happen. Government has
a role to pay to in making this happen.
We would like to propose the following recommendations:
1) That a formal consultation process be developed so that governments, industry
and disability organizations can collaborate to identify barriers and to develop
solutions to those barriers before new technologies are deployed.
2) That a Disability Rights Office (DRO) ,similar to what has been implemented by
the Federal Communications Commission (FCC) in the United States to deal with
disability issues around telecommunications, be implemented here in Canada to
deal with Payment Service disability issues. The FCC DRO provides expert
advice and assistance, as required, to other Bureaus and Offices, consumers,
industry, and others on issues relevant to persons with disabilities. DRO initiates
rulemakings, where appropriate, for the development of disability policy; reviews
relevant agenda items and other documents and coordinates with Bureaus and
Offices to develop recommendations and propose policies to ensure that
communications are accessible to persons with disabilities, in conformance with
existing disability laws and policies, and that they support the Commission's goal
of increasing accessibility of communications services and technologies for
persons with disabilities. We also would recommend that the new DRO research,
or fund research, into disability related issues around Payment Services.
3) That industry adopt a universal design approach when it comes to the design of
new technologies.
Neil Squire Society
Neil Squire Society
The Neil Squire Society is the only national not-for-profit organization in Canada that
has for over twenty-five years empowered Canadians with physical disabilities through
the use of computer-based assistive technologies, research and development, and
various employment programs. Through our work, we help our clients remove barriers
so that they can live independent lives and become active members of the workplace
and our society. Specializing in education and workplace empowerment, the Society
has served over 20,000 people since 1984.
Neil Squire Society
[y1] Social Sciences and Humanities Research Council of Canada (SHRCC) funded
Innovation for a New Economy (INE) initiative.
[y2] Betty Dion Enterprises, Ltd. “Unequal Access” Canadian Human Rights Commision,
[y3] Fernie, Dr. Geoff.Centre for Studies in Aging. “Submission to the Canadian
Standards Association (CAS): Guidelines for Development of a Canadian Standard of
Accessibility for Automated Banking Machines (ABMs) for Persons with Disabilities and
Seniors. Steering Committee on an Accessibility Standard for ABMs. November 26,
[Y4] Canadian Standards Association. B65.1.1-01 (2001) Barrier-free design for
Automated Banking Machines."
[y5] 3)Betty Dion Enterprises, Ltd. “Unequal Access” Canadian Human Rights
Commision Report, 1994.4http://www.gdblegal.com/whatwedo.php?menuItem=36
[y6] 4) Settlement of litigation documents California Council for the Blind, the American
Council of the Blind, and the American Foundation versus Walmart; Point of Sales
[y7] 5) Settlement of litigation documents California Council for the Blind, the American
Council of the Blind, and the American Foundation versus Safeway; Point of Sales
[y8] 6) California Council for the Blind, the American Council of the Blind versus 7eleven: Point of Sale Terminals;
[y9] 7) Settlement of litigation documents California Council for the Blind, the American
Council of the Blind, and the American Foundation versus Radio Shack: Point of Sale
Terminals; http://www.gdblegal.com/pdf/RadioShack.pdf
[y10] 8) Neil Squire Society; Internal Report on Focus Groups on Retail and Public
Services, DIS-IT (Disability and Information Technologies) Research Alliance, 2006.
Social Sciences and Humanities Research Council of Canada -Innovations and the New
Economy Initiative.
[y11] 9) "Barrier-Free Design for Automated Banking Machines "; CAN/CSA-B651.1-01
(R2006) ; Canadian Standards Association.
[y12] 10) Gill, J.M. (ed) Proceedings of the COST 219 Seminar on Smart Cards and
Disability; COST 219 ISBN 1 86048 003 9; Nov 1994, 166 p;
[y13] http://www.ic.gc.ca/eic/site/oca-bc.nsf/eng/ca02096.html
Neil Squire Society
[y14] http://www.nyce.net/consumers/canadian/canadian_banks/index.htm
[y15] http://en.wikipedia.org/wiki/Debit_card
[y16] http://accesstechnews.wordpress.com/2010/07/16/pharmaprix-to-
[y18] Fain, B. (Unknown). POS Accessibility Monograph. Retreived from
[y19] Burns, N. (2005, February). California Legislation and Accessibility Issues. Braille
Monitor. Retrieved from http://nfb.org/legacy/bm/bm05/bm0502/bm050206.htm
[y20] http://info.sen.ca.gov/pub/05-06/bill/asm/ab_0751-
[y21] Law Office of Lainey Feingold. (2009, August 18). Trader Joe’s Point of Sale
Agreement and Amendment. Retrieved from http://lflegal.com/2009/08/trader-joes-posagreement/
[y22] Law Office of Lainey Feingold. (2009, July 30). CVS Accessible Web Site and
Point of Sale Settlement Agreement. Retrieved from http://lflegal.com/2009/07/cvsagreement/
[y23] Law Office of Lainey Feingold. (2009, May 14). Target Point of Sale Settlement
Agreement. Retrieved from http://lflegal.com/2009/05/target-settlement-agreement/
[y24] Law Office of Lainey Feingold. (2009, April 23). Staples Accessible Web Site and
Point of Sale Settlement Agreement
. Retrieved from http://lflegal.com/2009/04/stapl
[y25] Law Office of Lainey Feingold. (2008, December 10). Dollar General Settlement
Agreement. Retrieved from http://lflegal.com/2008/12/dollar-general-settlementagreement/
[y26] Law Office of Lainey Feingold. (2008, April 30). Rite Aid Tactile POS Agreement.
Retrieved from http://lflegal.com/2008/04/rite-aid-pos-agreement/
Neil Squire Society
[y27] Law Office of Lainey Feingold. (2007, August 31). 7-Eleven Point of Sale
Agreement. Retrieved from http://lflegal.com/2007/10/7-eleven-pos-agreement/
[y28] Law Office of Lainey Feingold. (2007, May 1). RadioShack POS and Web
Agreement. Retrieved from http://lflegal.com/2007/05/radio-shack-agreement/
[y29] Law Office of Lainey Feingold. (2006, September 30). Safeway POS Agreement.
Retrieved from http://lflegal.com/2006/09/safeway-agreement/
[y30] Law Office of Lainey Feingold. (2005, October 15). Wal-Mart POS Agreement.
Retrieved from http://lflegal.com/2005/10/walmart-pos-agreement/
[y31] Gill. J.M. Smart Cards: The Forgotten Customer. Proceeding of Smart Card '95.
February 1995.
[y32] Gill, J.M. The Importance of Smart Card for People with Disabilities; ”Proceedings
of Human Factors in Telecommunications Conference; Melbourne, March 1995; pp 383386.
[y33] Gill, J.M. and Currie K; “Smart Cards and Terminals”; In Roe P R W (ed)
Telecommunications ofr All. COST 219, Commission of the European Communities,
October 1995, pp 196-204.
[y34] Gill, J.M.;”Design of Smart Cards Systems to Meet the Needs of Disabled and
Elderly Persons”; Proceedings of the ECART3 conference, Portugal, ISBN 972 9301 18
2; October 1995, pp 314-316.
[y35] Gill, J.M.; “Smart Cards: Interfaces for People with Disabilities”; Royal National
Institute for the Blind; ISBN 1 86048 007 1, February 196, 16 pp.
[y36] Gill, J.M. and Carsons G. “Smart Cards: The Coding of User Interface
Requirements”; Royal National Institute for the Blind. July 1996, 12 pp.
[y37] Gill, J.M.”Saturn Case Study”; Saturn Project 1997.
[y38] Gill, J.M. “The Coding of Interface Requirements on Smart Cards for People With
Disabilities”; Smart Card Technology International, ISSN 1361 8283; February 197; pp
[y39] Gill, J.M.; “Smart Card Technology and the Disabled”; Card Forum International,
Vol 1; No. 4 November/December 1997, pp 33-35.
[y40] Jones D. amd Mearns C. “The Smart Card 1998”. SJB Services, ISBN 1 900118
03 3; 1997.
[y41] Comite Europeen de Normalisation Standard EN 726 Requirements for IC Cards
and terminals for Telecommunications use.
[y42] Comite Europeen de Normalisation Standard prEN 1332 Machine readable cards,
related device interfaces and operations: Part 2 Dimension and location of tactile
Neil Squire Society
identifier for ID1 cards.
[y43] International Organization for Standardization ISO/IEC 10536 Identification Cardscontactless integrated circuit cardsd
[y44] Gill, J.M. “The use of Electronic Purses by People with Disabilities: What are the
Needs”. August 1998.
[y45] Irish National Disability Authority Smart Card Accessibility Guidelines: Dr John Gill,
Royal National Institute for the Blind. Dick Clarke, Consult Hyperion.2007.]
[y46] http://www.crtc.gc.ca/eng/info_sht/t1037.htm
[y47] http://www.govtrack.us/congress/bill.xpd?bill=h111-3101
[y48] http://www.w3.org/TR/WCAG20/
[y51] Analytica Inc . “2008-2009 Consumer Internet Purchase Study:
Key Highlights May 2009”.
[y52] “Online Shopping Takes Off Over 875 Million Consumers in The World Have
Shopped Online The Number of Internet Shoppers up 40% in Two Years”
[y53] http://www.statcan.gc.ca/pub/89-628-x/89-628-x2007002-eng.htm
Neil Squire Society
Neil Squire Society
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