Guidelines to help banks meet the needs of older and disabled customers

Introduction

Under the Code of Banking Practice, we agree we’ll do our best to meet the needs of all our customers.

To help us achieve that goal under the Code we’ll also follow these guidelines, which we’ve designed to help us meet the needs of older and disabled customers.

We’ll follow these guidelines by 1 January 2020.

In these guidelines, ‘we’, ‘us’ and ‘our’ means your bank and ‘you’ and ‘your’ means you, the customer. These guidelines are also subject to the Code, including how the Code relates to bank terms and conditions.

Why these guidelines are important

We recognise that disabled and older customers should be able to access information, products, and services, in a way that’s fair, reasonable, and easy, and encourages their independence and control.

We also recognise the need to understand and consider older and disabled customers when developing processes, products, and services, so we reflect the diversity of customers and the accessibility challenges they may face.

These guidelines:

• provide information and resources to help us develop systems and processes that promote and improve access to banking products and services by older and disabled customers
• support our understanding of the needs of older and disabled customers, and
• reflect our goal to meet the rights and needs, including accessibility needs, of older and disabled customers under human rights laws and the UN Convention on Rights of Persons with Disabilities.

These guidelines aren’t exhaustive

It’s not possible for these guidelines to cover all the access and banking issues faced by older and disabled customers. We also recognise that not all disabilities are obvious and may still affect the way some people access information and banking services.

Banking services will also change over time to meet customer demand and to reflect new technologies, presenting new opportunities and challenges. We’ll continue to evolve these guidelines as banking services and technologies, and accessibility options, change.

Where appropriate, we’ll consult with older and disabled customers and communities as we consider banking issues that affect them. And we’ll use the resources listed in the attached Appendix, if needed.

In these guidelines, ‘reasonable accommodation’ applies

We recognise New Zealand has signed the UN Convention on the Rights of Persons with Disabilities, which is an important step in recognising the needs of disabled people. The Convention complements New Zealand’s human rights legislation.

In these guidelines, when we say we will or should do something, we’ll aim to make ‘reasonable accommodation’ under the Convention.

The Convention defines ‘reasonable accommodation’ as:

‘necessary and appropriate modification and adjustments not imposing a disproportionate or undue burden…to ensure to persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms’.

We’ll train our staff to understand and help

We’ll train relevant staff or provide processes to allow them to:

• understand and help meet the needs of older and disabled customers, including their communication needs
  know what products or services may best meet the needs of older and disabled customers
• recognise, escalate, and respond to possible financial abuse, while being sensitive to customer situations and wishes
• know how and when to use the New Zealand Relay services, if appropriate, and
• know what options are available to customers who may need independent advice.

We’ll consider older and disabled customer needs when we publish banking information

When we publish information about banking or products and services for older and disabled customers, we’ll consider:

• providing different formats like braille, New Zealand Sign, and audio if we can
• making documents easy to read, including by using large print or clear fonts and colours, and avoiding printing text over images
• making documents easy to understand, by using plain language, pictures, and diagrams, and
• limiting the information on a page.

We’ll consider older and disabled customer needs in physical banking spaces

When we’re designing physical banking spaces, we’ll consider:

• the Building Act standards for access by disabled people
• the need for quiet spaces for people who might feel anxious, confused, or need support to concentrate or communicate
• the need for clear and easy to read signage and design features that help people navigate a space, including people with vision and other impairments
• the need for well-lit spaces, with plain-coloured and even flooring, and for obvious seating areas and low tables
• the need for ramps where access is otherwise by stairs, and
• the need for power-assisted doors, meeting spaces, teller counters, and queuing aisles that allow wheelchairs.

If we manage queues by assigning a number, we’ll also consider calling out numbers as well as displaying them on a screen.

We’ll be sensitive to the needs of customers who may experience anxiety or other difficulties waiting in queues. If asked, and where reasonable, we’ll provide alternatives for those customers in our banking spaces.

We’ll consider older and disabled customer needs in banking products and services

We’ll work to help older and disabled customers to understand the range of banking products and services available, and how we can support customers as their needs change.

We’ll consider the needs of older and disabled customers when we’re:

• designing new products or services and related policies and procedures, and
• developing internal or public education initiatives.

We’ll work with older and disabled customers and communities to identify and address communication and language needs. In particular, we’ll welcome interpreters and support people if this is what customers want or need.

If a customer can’t use a product or service we offer due to age or disability, we’ll consider reducing the fee we charge them if they ask us to do so.

We’ll consider older and disabled customer needs in ATMs and electronic banking services

When developing ATM services, we’ll consider the need for:

• accessible and user friendly ATMs for older and disabled people
• alternatives, if possible, for older and disabled customers who can’t use ATMs
• ATMs with verbal prompts to complement on-screen instructions, if possible, being aware of the security risk of ‘shoulder surfing’
• clear and easy to use ATMs for people with vision and other impairments, including acceptable colour contrast
• the ability to increase text size, or having larger buttons for those with coordination difficulties
• a dot on key number five for people with vision and other impairments, and
• clear, onscreen prompts in plain language.

When developing electronic banking services, we’ll consider using the international W3C web accessibility best practice standard, the accessibility-related New Zealand e-government web standards, and recommendations, including the need for:

• user-friendly websites, compatible with browsers commonly used with assisted technology
  simple screens where possible that encourage and support the use of electronic banking by older and disabled customers
• easy prompts and access, and
• plain language information on how to use electronic banking.

Where appropriate, we’ll engage with organisations representing older and disabled customers to help tell them about changing technologies around ATMs and electronic banking.