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-----Message d'origine----- De : AccessIndia <accessindia-boun...@accessindia.org.in> De la part de Blind Graduates' Forum of India Envoyé : 17 mars 2019 11:09 À : accessindia <accessindia@accessindia.org.in> Objet : [AI] Draft representation to RBI on Accessible Digital Currency, please share your inputs by 19th March noon Dear all, In line with our efforts on Accessible Indian Currency, Blind Graduates Forum of India is continuing to engage with RBI on Accessible Digital Currency. We recently had a meeting with a committee formed by RBI on Deepening Digital Payments which is chaired by Mr. Nandan Nilekani. The response from the committee has been positive. We are sending our representation to the committee for them to consider incorporating the same in their report shortly. Pasting below the draft of the representation. Many of you have been working closely with the banking industry, accessibility and relevant areas. Please review in detail and share your inputs if any by coming Tuesday, 19th 12 noon. Your inputs and feedback at this stage might prove to be valuable. Representation on deepening Digital Payments and accessibility for Persons With Disabilities. Please note that this representation doesn’t focus on physical currency, ATM’s, POS machines and self service machines as per the scope defined by the committee. And we are engaging with RBI and government on the same separately. Policy The following recommendations will deepen the accessibility of digital payments for Persons With Disabilities. Digital payments accessibility for this segment can be driven through adoption of Universal Design principles and standards for Information and Communication Technology accessibility impacting websites, mobile apps, softwares, documents, etc. as elaborated below. • All tenders, procurement and contracts (including third party contracts) for development, maintenance and upgradation of each regulated entity must include clauses on compliance of accessibility standards to ensure accessibility of Information and Communication Technology. • All regulated establishments to make their websites and mobile apps accessible for Persons With Disabilities by ensuring compliance with “Guidelines for Indian Government Websites, 2018”. These obligations are prescribed for all government, private and other entities under Sections 40 and 46 of the Rights of Persons With Disabilities Act, 2016 read with Rule 15 of the Rights of Persons With Disabilities Rules, 2017. • Each regulated entity to Factor the needs of Persons With Disabilities throughout the product, process and service lifecycle including for research, procurement, design, development, testing, operation, marketing, customer service, maintenance and upgradation. Only accessible products and services must be procured by each regulated entity from the third parties. • Each regulated entity must allocate budgetary resources to ensure there is sufficient fund available for accessible Information and Communication Technology. • Each regulated entity must dedicate a link / tab on its website for accessibility policy highlighting compliance of accessibility standards and provisions made for Persons With Disabilities. • RBI to setup a centralized team to inculcate the culture of accessibility and inclusion of Persons With Disabilities. Responsibility of the team to include liaising with various departments of RBI and regulated entities for financial inclusion, accessibility policy, spreading awareness, monitoring, addressing issues of customers with disabilities, etc. • RBI to conduct an annual review of the policies and accessibility standards for the inclusion of Persons With Disabilities in line with the technological progress and updates to international standards such as EN301549. Also ensure they are notified and periodically communicated to all the entities under RBI’s purvue. • Adopt solutions which follows Universal Design principles, and which cater to internationally accepted accessibility standards. • User groups, accessibility consultants certified by International Association of Certified Professionals, and other experts representing Persons With Disabilities should be involved while formulating accessibility standards. • RBI to issue appropriate directives to all regulated entities to drive compliance of accessibility standards. The obligation to ensure compliance is upon RBI as the regulator as per the Rights of Persons With Disabilities act 2016 and rules mentioned above. Monitoring • All regulated entities must submit a board-approved self-certificate wedded by an independent accessibility auditor having the necessary certification from the International Association of Accessibility Professionals, by end of first quarter of every financial year stating that: 1. They have created an accessibility policy and have added the information on their websites and mobile apps about the accessibility compliance and facilities available to Persons With Disabilities. 2. They have trained all employees working on Information and Communication Technology in line with the curriculum approved by the International Association of Accessibility Professionals, on the need, benefits, sensitivities and legality of accessibility. 3. They have trained accessibility testers and identified accessibility consultants certified by the International Association of Accessibility Professionals who will ensure accessibility of Information and Communication Technology - websites, apps, softwares, documents and communication. 4. They have set up and trained customer service department / help desks to accept grievances and assist customers with disabilities. Also report the number of complaints received on inaccessibility and the action taken thereon. • RBI to conduct quarterly review of all the regulated entities on the above parameters to ensure adherence of accessibility standards and recommend appropriate actions. • RBI to conduct annual accessibility audits of all regulated entities on Information and Communication Technology Accessibility and issue observations for compliance as part of its inspection. Grievance redressal • The regulator is responsible for driving compliance among entities under its purview under Rule 15 of the Rights of Persons With Disabilities Rules 2017, Therefore, RBI to issue directives through the powers given to it under various legislations. In case of noncompliance, RBI to penalize the entity. • The Digital Ombudsmen scheme must be amended to include Information and Communication Technology inaccessibility as one of its redressal mechanism, providing the end users a platform for easy redressal of inaccessibility. • RBI to incentivize or penalize entities based upon their compliance and efforts to make digital payment – Information and Communication Technology inclusive and accessible for Persons With Disabilities. This can be done through recognitions, certifications, penalties, etc. • Each regulated entity must amend its grievance redressal policy to include inaccessibility as a complaint parameter along with the timelines for resolution of such complaints. PROCESS The following process flows must be implemented while designing, procuring, developing or implementing any mode of digital payments by the regulated entities. Similar processes should be defined for end to end experience for the inclusion of Persons With Disabilities as and when introduced: Accessible Design: • A human-centered design approach needs to be adopted while strategizing and prototyping designs for products that enable digital payments. All the regulated entities must incorporate "accessibility" or "universal design" right from the design phase instead of building first and tweaking for accessibility later. • If the design involves use of any off-the-shelf or third-party components/ libraries, only the ones which meet the universal design standards must be a part of the design. • If the needs of Persons With Disabilities are difficult to comprehend for the system being conceptualized, then such needs must be gathered by means of a survey or directly involving relevant stake holders in the design process. Accessible Development and Implementation: Every user interface component must be usable by Persons With Disabilities. For instance, blind users cannot solve a visual CAPTCHA challenge, therefore an alternative in the form of audio, voice call, text-based or Email CAPTCHA must be presented like the one provided by HDFC Bank. • Every feature of the system must be developed considering users with all type of disabilities. For instance, the time interval for entering OTP if too short, would be difficult to meet by someone with a locomotor disability. • Alternate modes of payments like Electronic Cheques must be standardized and included in all banking systems. These means have the potential to ease the challenges faced by Persons With Disabilities with the physical currency. For instance, a blind person finds it difficult to write a physical cheque, a web cheque can be an accessible alternative for this mode of physical payment like the one provided by ICICI Bank. • Any physical forms like contracts/ legal documents that a user needs to read and sign must be made available in accessible formats through the system. • All the sources of information like user manuals, FAQs, bank statements, etc. must all be available in accessible formats. • The general system must be made accessible instead of creating a special accessible system only for users with disabilities. Such systems are not cost effective, have failed in the past and can't keep up with the ever-evolving technologies. • Mechanisms like cards that facilitate digital payments must have important information like card number, expiry and CVV in a format perceivable by all users with or without disabilities. • The feedback provided by every system component must also be universally accessible. For instance, a validation error by highlighting a field in red cannot be perceived by a blind user, a textual warning must accompany the visual warning. • Every system or associated service introduced by the regulated entities including phone banking, mobile wallets, mobile apps, websites and any existing or futuristic modes of conducting financial transactions must be developed/ implemented in a manner that fosters equal access to everyone. Testing for Accessibility: • Every update to the system must be tested for accessibility. • The severity of accessibility related change requests must be considered high as it inhibits access for a section of the system's users. End-user usability testing: • A sample of users across different disabilities must be involved in beta testing the systems before they become main stream. • Banking systems are meant to be used by everybody, therefore, Persons With Disabilities from different demographics and backgrounds must be involved in evaluating the system as well as giving feedback before the system goes into production. End of representation Thanks in advance for all your inputs and feedback. Regards Team Blind Graduates Forum of India Website: www.bgfi.in Facebook: http://tinyurl.com/bgfifacebook Search for old postings at: http://www.mail-archive.com/accessindia@accessindia.org.in/ To unsubscribe send a message to accessindia-requ...@accessindia.org.in with the subject unsubscribe. To change your subscription to digest mode or make any other changes, please visit the list home page at http://accessindia.org.in/mailman/listinfo/accessindia_accessindia.org.in Disclaimer: 1. Contents of the mails, factual, or otherwise, reflect the thinking of the person sending the mail and AI in no way relates itself to its veracity; 2. AI cannot be held liable for any commission/omission based on the mails sent through this mailing list.. Search for old postings at: http://www.mail-archive.com/accessindia@accessindia.org.in/ To unsubscribe send a message to accessindia-requ...@accessindia.org.in with the subject unsubscribe. To change your subscription to digest mode or make any other changes, please visit the list home page at http://accessindia.org.in/mailman/listinfo/accessindia_accessindia.org.in Disclaimer: 1. Contents of the mails, factual, or otherwise, reflect the thinking of the person sending the mail and AI in no way relates itself to its veracity; 2. AI cannot be held liable for any commission/omission based on the mails sent through this mailing list..
