Written evidence submitted by Royal National
Institute of Blind People (RNIB)
1. INTRODUCTION
1.1 As the largest organisation of blind
and partially sighted people in the UK, RNIB is pleased to have
the opportunity to respond to this inquiry.
1.2 We are a membership organisation with
over 10,000 members who are blind, partially sighted or the friends
and family of people with sight loss. 80 per cent of our Trustees
and Assembly Members are blind or partially sighted. We encourage
members to be involved in our work and regularly consult with
them on government policy and their ideas for change.
1.3 As a campaigning organisation of blind
and partially sighted people, we fight for the rights of people
with sight loss in each of the UK's countries. Our priorities
are to:
— Stop people losing their sight unnecessarily.
— Support independent living for blind
and partially sighted people.
— Create a society that is inclusive of
blind and partially sighted people's interests and needs.
1.4 We also provide expert knowledge to
business and the public sector through consultancy on improving
the accessibility of the built environment, technology, products
and services.
2. EXECUTIVE
SUMMARY
2.1 The proposal is for cheques to be phased
out by 2018 but only if alternatives are developed. RNIB is concerned
that although there are alternatives, listed below, they are not
fully accessible or fully available to users. It would therefore
be a very high risk strategy to start planning towards removal
of cheques by 2018 without these alternatives being in place.
2.2 Many blind and partially sighted people
rely on cheques for the payment of bills and to access cash.
2.3 In terms of trends over time, if the
alternatives were available and accessible right now, then the
UK Payments Council, Banks and organisations like RNIB could support
people moving over to them. However, they are not available now
and the timescales are unlikely to be long enough to have them
in place. The continuing issues around adoption of Chip and Signature
by industry, manufactures and end users is an example of how difficult
it can be to move people to different payment methods.
2.4 Whilst cheques are not totally accessible,
they are something with which people are familiar, a trusted payment
method, which can be completed in a person's own home. This is
helpful for people who do not feel confident going out alone,
and enables them to ask friends or family to post the cheque,
enabling them some independent control of money. The familiarity
of cheques gives those people using them the confidence to manage
their own money independently.
2.5 Phasing out cheques completely could
take away this independence and would be a step backwards in terms
of independent living and choice for many blind and partially
sighted people. This is because the alternatives discussed below
are not developed enough to replace cheques for the foreseeable
future.
2.6 In short, if cheques are to be phased
out, then before this happens we need the industry and groups
concerned to be fully supported by the Treasury to put alternatives
in place. This is not something we believe is likely to happen
fully enough by 2018. We are concerned that if cheques were phased
out, we would find many more blind and partially sighted people
taking a step backwards in terms of being able to control their
own money.
Detailed responses to the questions the Committee
set out in its press release announcing the inquiry:
3. QUESTION 2
The disadvantages of abolition—the impact
on blind and partially sighted people.
3.1 Some of the reasons that blind and partially
sighted people use cheques rather than other payment methods need
to be reflected in alternative systems. Some of these benefits
can be seen in the alternatives listed. However, other concerns
about accessibility negate the benefits offered by the alternative
methods.
4. BENEFITS OF
CHEQUE USE
FOR BLIND
AND PARTIALLY
SIGHTED PEOPLE
Verification
4.1 You may not be able to see enough to
verify the cheque amount yourself, but you can ask a trusted friend,
family member or colleague to do this for you. A cheque is a very
portable and flexible way of doing this—you can't carry
a computer screen or ATM around with you.
Records
4.2 You keep a record in your cheque book
that is easy to access at any time. Again, these can be verified
by a trusted party if necessary.
Sense of control
4.3 Because cheques are manually processed
by the bank, it is possible to cancel a cheque after the event,
so it gives a sense of control over stopping a payment by visiting
the bank or making a quick phone call.
Physical nature of the cheque
4.4 The act of physically handing a cheque
over to someone is a physical manifestation of handing over money.
Part of this benefit is in the confidence of feeling certain about
the transaction which links to feeling confident about who you
are paying and how much. The other aspect to this is that by physically
signing the cheque yourself you have a feeling of independence
and control over signing off the transaction yourself and not
relying on others.
5. QUESTION 3
The development of alternative payment mechanisms
5.1 The possible alternatives outlined below
have drawbacks for blind and partially sighted people. Many payment
methods and systems are partly or totally inaccessible to some
blind people. Any alternative that is adopted needs to be fully
accessible and, as noted above, needs to provide blind and partially
sighted people with the same benefits of using cheques, in terms
of control, verification and security.
5.2 Chip and PIN or Chip and Signature
5.21 Summary: This is the method where people
use credit and debit cards with a choice of a PIN number or signature
within a retail setting (for example, a shop or restaurant).
5.3 Benefits
5.3.1 Widely available: There are many places
where PEDs (portable pin pad device) are used as the primary method
of payment, so it is widely available.
5.3.2 Easy to change payment: Arguably,
a transaction can be cancelled or amended but it's not easy to
do this in practice.
5.4 Drawbacks
5.4.1 Not fully accessible: Designs vary,
but many are accessible enough to enable the person to put their
own number into the PED. However, you don't get verification of
what is on the screen, and the receipt is also in small print.
Asking for verification of what is on the screen compromises privacy
and security.
5.4.2 Chip and signature confusion: We are
still receiving feedback that people are having problems.
5.4.3 More limited than cheques: If you
want to pay a private individual, you can write them a cheque.
If you want to pay using a card then you would need to use an
ATM, cashback or online banking to reach the same end, adding
a layer of difficulty to the process.
5.4.4 Privacy and security: Chip and PIN
users have fed back concerns about other people seeing their number.
Shielding products such as ViewSafe help to protect the view of
the keypad to assist with key entry. However, not being able to
verify the amount on the screen still causes concern if the customer
doesn't wish the amount to be read out, for example in restaurants
where a Tip may be added.
5.5 ATMs (Cash Machines)
5.5.1 Summary: There are currently 64,000
ATMs in the UK that are connected to LINK. Over 38,500 of these
are free to use. Although there are design guidelines, these machines
are still almost impossible for a blind person to use.
5.6 Benefits
5.6.1 Variety of services: The ATM network
is extensive and now enables people to top up mobiles, pay in
money and check their balances as well as withdraw money.
5.6.2 Available evenings and weekends: ATMs
are there to be used outside of business hours.
5.6.3 Smart cards: The use of smart cards
has been outlined as a concept. In theory, using them with an
ATM could enable the display to adjust to the user requirements
for screen layout but this is not something that the industry
is ready to adopt and is therefore not going to be a solution
ahead of 2018.
5.6.4 Extensive network: Because of the
extensive network, it is likely that a cash machine will be as
close as the nearest post office or letterbox and closer than
the nearest bank.
5.7 Drawbacks
5.7.1 Too many to replace by 2018: Even
if we had a fully accessible ATM design today, it would be unrealistic
to expect a comprehensive network roll out by 2018. There are
just too many of them that would need to be replaced to make this
an effective alternative in these timescales.
5.7.2 Inaccessible screen: It's not just
a question of font and visual contrast. Further issues arise with
the screen order, where advertising is slotted in and different
screen layouts also make it impossible for a user relying on patterns
of button presses where there are no useful visual or audible
cues.
5.7.3 Inaccessible hardware layout: The
layout of the hardware is different for each machine, with the
money slots and clear, cancel and enter buttons slightly different.
5.7.4 Audible cues: There are now a few
machines with audio output, although we haven't put them through
any RNIB trials with our product design or innovation areas. One
concern would be that if someone is listening with headphones
that they would not hear anyone approaching them so offer a security
risk. This could be a possible solution within a bank but then
the times of use are limited to working hours.
5.7.5 Privacy and Security: Blind and partially
sighted people have reported that they prefer not to use ATMs
because they can't tell who is behind them. Even if machines were
accessible, the use of them is still limited and could not therefore
replace cheques.
5.8 Cashback
5.8.1 Summary: If someone is using cheques
to get money out of their accounts, or to pay small sums of money
to other people, then the ability to get cash back at a shop may
be an alternative.
5.9 Benefits
5.9.1 Convenience: If someone is already
going shopping then asking for a small extra sum should not cause
inconvenience.
5.9.2 Established: This is an established
method of getting money out.
6. DRAWBACKS
6.1.1 Limited use to card users: Someone
would need to be paying by Chip and PIN or Chip and Signature
to get cashback. Therefore they may not be a heavy cheque user
anyway. We've also found instances where a shop will not give
cashback because they have an ATM outside and do not want to hold
additional cash even if that's just for Chip and Signature users.
6.1.2 Fixed location: Someone would need
to be able to get to a shop that gave cashback in the first place.
Cheques can be written in the comfort of the home, so are less
location dependent.
6.2 Contactless payment systems
6.2.1 Summary: This is where a person pays
by holding a pre-paid card near a locator.
6.3 Benefits
6.3.1 Prepaid cards: If you have card that
is prepaid, with a fixed amount and you can only spend that amount,
then that limits the amount that a mistaken payment would cost
you.
6.3.2 No record: You don't need to sign
or key a number into a keypad, but you do need to be able to find
the locator that your card is read by.
6.4 Drawbacks
6.4.1 Lack of accessibility: There are huge
accessibility issues with these systems. There is limited take
up in London and we have yet to see it spread out, so adoption
is still in early stages with sighted users.
6.4.2 Adding difficulty through prepaid
cards: There is also the question of how the cards are paid for
in advance. Top up methods for mobile phones through retailers
and ATMs just add another level of difficulty.
6.4.3 Mobile phones: Using mobile phones
rather than contactless cards is no better because the mobile
phones that are needed to do this are not widely available or
accessible to blind and partially sighted people.
6.4.4 Lack of record: As this is contactless,
you do not have the security of a record of proof to know what
you have spent, when and with whom.
7. ONLINE BANKING
7.1.1 Summary: Most banks now offer online
banking facilities where you can pay into other bank accounts,
keep updated with your own account balance and transactions, set
up regular payments and apply for other account services.
7.2 Benefits
7.2.1 Home location: If you have the technology
and access at home then you can do your online banking in the
comfort of your own home.
7.2.2 Proof of transaction: If these websites
were accessible then there would be a way of seeing which transactions
were being undertaken. However, due to the drawbacks listed below,
this is not a viable alternative.
7.3 Drawbacks
7.3.1 Not fully accessible: Because of the
security measures adopted by the banks to protect customers from
fraud and other crimes, online banking is not fully accessible.
This means that even people who would have been able to see enough
to write a cheque, are unable to use them. A review of bank websites
by a PhD student demonstrated a shocking lack of accessibility
throughout Europe.
7.3.2 Computer based: Not everyone has a
computer. Many people who are using cheques will be in older age
groups and less likely to have access to a computer in a location
where they are safe, such as home or a private office. Libraries
may have computers but they are not private enough to enable people
to use them for personal data. Therefore, even if the accessibility
issues were overcome, availability of computers in private and
secure locations would still be an issue.
8. CONCLUSION
8.1 Whilst RNIB welcomes the undertaking
that cheques won't be phased out unless a viable alternative method
is available, we are concerned that an alternative method will
not be fully accessible for blind and partially sighted people.
Using cheques enables many blind and partially sighted people
to pay bills and manage their money independently. Any alternative
method must provide the same level of independence and security.
March 2010
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