- From: Gregory J. Rosmaita <oedipus@hicom.net>
- Date: Sat, 4 Aug 2007 20:04:34 -0400
- To: www-archive@w3.org
note: this is a copy of a post to a member-only list, which does not contain any member-confidential information, therefore, i have posted it to www-archive so as to make it available in a public archive ---------- From: oedipus@hicom.net Date: Tue, 31 Jan 2006 16:12 +0000 To: [eddress deleted] Subject: Accessibility Issues with BoA Online Banking Interface [FWD] dear ms. [name deleted] - thank you again for your assistance this afternoon. i am placing the message i sent to mr. reeves and carbon-copied to accessiblebanking@bankofamerica.com in the body of this emessage - if any of the HTML/XHTML code contained herein is corrupted by the web mail interface i am emailing you from, please let me know, and i will resend the emessage as an attachment. again, i cannot thank you enough for your patience, understanding, and responsiveness. as i indicated during our conversation, i have been attempting to get these issues addressed since BoA bought out fleet bank, where i had an account by virtue of fleet having bought out my original banking institution, summit bank. i truly appreciate the seriousness and gravity with which you are treating this matter, and "look" forward to working with BoA to address slash redress the issues outlined below, which, as i stated during our conversation, address the most egregious accessibility issues with BoA's web interface, and have included specific programmatic suggestions where possible, including reformatted forms and tables. however, since once one is logged into BoA's online banking interface, the user's ability to obtain the source code underlying the web document (the web document's DNA, so to speak) is blocked, so i could only provide specific examples of accessible code where i could obtain the document source. however, i did attempt to address the design and implementation decisions that are at the root of the inaccessibility of BoA's online interface, such as: * the lack of separation between style and content; * the invalidity of the code used to construct the pages (the first step towards accessible web documents is to ensure that the code used to construct them validates against a recognized and peer-reviewed standard); * the lack of and/or misuse of structural and contextual markup which would inestimably assist ALL users; * the use of invalid form controls which make it difficult, if not impossible to ascertain what submission links belong to what form controls; * the use of ambiguous hyperlink text; as well as other related issues which i hope to discuss in greater detail with whomever is responsible for the oversight and implementation of BoA's online interface. so, while the following is not a comprehensive list of issues which need to be addressed, it does address the most egregious accessibility problems with the BoA web site, and was (and is) intended to open a dialog with those responsible for BoA's web interface on both a policy level, as well as a very technical level. thank you again for your attention to this very serious matter, gregory j. rosmaita phone: 1 973 746 1192 email: oedipus@hicom.net AND unagi69@concentric.net --- FORWARDED EMESSAGE --- From: oedipus@hicom.net To: [Name and Eddress Deleted] CC: accessiblebanking@bankofamerica.com Date: Thu, 26 Jan 2006 20:02 +0000 Subj: Accessibility Issues with BoA Online Banking Interface dear mr. [name deleted]: i am emailing you because i was given your email address as a contact for addressing accessibility problems with the bank of america site. if you are not the correct person to whom to address such issues, please forward this emessage to whomever is charged with overseeing the accessibility of the BoA web site. if it does fall within your purview, please feel free to circulate this emessage to whatever colleagues you deem appropriate and/or necessary. as a blind user, it is essential that -- in order to retain my autonomy over my finances, not to mention my privacy -- i have complete and unfettered access to your web-based interface. while i commend BoA's stated commitment to accessibility, and i most certainly appreciate the roll-out of accessible ATMs at BoA branches, the BoA web site presents a host of insurmountable problems for the any user who isn't fortunate enough to have use of his or her eyes, the ability to correctly process visually presented information in accordance with the intentions of BoA's web designers, and the capacity or capability to point-and-shoot one's way through a web site. despite BoA's claims of complying with the W3C's guidelines, such as that found on: http://www.bankofamerica.com/accessiblebanking/index.cfm? template=ab_web_access the site most definitely does NOT comply with any of the W3C's guidelines, nor does the source code used on the site validate; i happen to know a bit about both accessibility and validity, having been an "invited expert" to the W3C since 1997. if the BoA site did comply with any of the W3C guidelines, or any of the other universal design guidelines which have been promulgated in the last decade, this emessage would be uneccesary. however, my experience as a blind individual, a BoA account holder, and an "invited expert" to the W3C compel me to make yet another attempt to provide BoA with the detailed feedback necessary for it to actually live up to its self-proclaimed commitment to: quote continually enhancing our Web environment to increase accessibility and usability for all of our customers. These enhancements are based on universal design and priorities one and two of the World Wide Web Consortium (W3C). unquote ISSUE 1 - BillPay Problems: 1. selecting the "Go to Add Payee" hyperlink does NOT take one to the form whereby one adds a Payee, but to the following string of text: To add a new payee, click _Show_. with the word demarcated with underscores, "show", as the actual hyperlink. this is NOT sufficient from an accessibility point of view, nor is it logical from a design standpoint. first, why is the hyperlink text not: "add a new payee" which is unambiguous, rather than "show" which is not only ambiguous, but which is used twice on the same page as hyperlink text; despite the use of identical hyperlink text on multiple links, each hyperlink leads to a different destination. it is essential, not only from an accessibility standpoint, but for general useability's sake, to ensure that identical hyperlink text points to identical targets. not only should hyperlink text explicitly indicate the nature and identity of the target of the hyperlink, thereby eliminating such ambiguous hyperlink text as "here", "this", "click here", "click this", or "show" from consideration when designing and implementing a site; especially a site where accuracy and precision are essential to the user. second, why does not the "Go to Add New Payee" link actually take one to the "Add New Payee" interface? it is not an unreasonable expectation that a link which explicitly states that it will enable the user to "Add a New Payee" actually takes the user to an interface that allows him or her to do precisely that -- add a new payee; rather than taking the user who wishes to add a new payee to a hidden form which will only be exposed if one can either (a) make sense of the ambiguous hyperlink text, (b) is willing to follow multiple links to locate the link one actually needs to activate, or (c) parse the document's source and scripting in order to ascertain which is the correct hyperlink and destination combination necessary to perform what was once, and should remain, a simple task: adding a payee. obviously, this constitutes an "undue burden" on the individual user, whereas ensuring that the BoA interface uses valid source code and conforms to the accessibility guidelines promulgated by the World Wide Web Consortium (W3C - consult http://www.w3.org/WAI/) is not only simple, but has the benefit of ensuring that the BoA site is useable by all BoA account holders, regarless of their situation, circumstances, or the technology they use to access information. accessibility is but an aspect of useability; ensuring that the BoA site is accessible will also make the site itself easier for every account holder to use. ISSUE 2 - Forms: 1. please use valid form controls and valid form labeling mechanisms (LABEL, LEGEND, FIELDSET, etc.) on ALL forms; there is, for example, no reason why the Accessible ATM locator, located at: http://www.bankofamerica.com/accessiblebanking/ isn't encased in a FIELDSET, with "Find a Talking ATM" as the LEGEND defined for that FIELDSET; it would not only serve to separate this form from the "Search" form which also appears on the page, but would make it clear to the blind user that the LABELed fields "Street", "City", "State" and "Zip Code" pertain to finding an accessible ATM. at the very least, rather than using a null value for the "summary" attribute of the TABLE that contains the "Find a Talking ATM" form, you should use this attribute for its intended purpose: to provide contextual information about the contents of the table it summarizes -- in this case summary should equal "Find a Talking ATM" in order to be in compliance not simply with the W3C's guidelines for web content accessibility, but, to be compliant with HTML 4x and XHTML 1x, quote summary = text [CS] This attribute provides a summary of the table's purpose and structure for user agents rendering to non-visual media such as speech and Braille. unquote [source: http://www.w3.org/TR/html401/STRUCT/tables.html#adef-summary 2. please use form controls to submit or cancel submission of the data entered into a form, rather than the javascripted links that currently substitute for form controls on the BoA site. why? 2a) using standard form controls for the submission or resetting of form data allows a user to differentiate between multiple forms which appear on a single page -- my screen reader allows me to generate a list of form controls, but without including the submission slash clear form controls within the form as form controls, it is impossible to easily discern (without recourse to document source) where one form ends and another begins. 2b) substituting hyperlinks for form controls adds to the identical hyperlink problem which is rampant on the BoA site -- how do i know which "Go" or "Cancel" link is associated with which form if there are multiple "Go" links, each associated with a different form, on a single page? 2c) you should NOT use TABLEs to visually slash graphically slash spatially format pages, using invalid code, empty columns and rows, and spacer images; TABLEs are a visual construct that only have meaning inasmuch as the user can discern the relationship between disparate pieces of data and their relationship between an item of data and the labelling/contextual information associated with that item of data on the X and Y axis, which is why TABLE-ized information MUST use the programmatic features built into HTML since version 4.0 (and which are built-into XHTML), such as the "summary" attribute (to describe the TABLE); the THEAD (Table Header), TFOOT (Table Footer) and TBODY (Table body) elements; if the use of TABLEs for formatting is deemed necessary by BoA, then there MUST be a strict separation between TABLEs that contain data (whether numeric or textual) and those that control formatting, rather than the sloppy mixing and matching of TABLEs that currently characterizes the BoA web site. (consult the next item for more detailed information) 2d) you can also demarcate the start and end of a FORM encased in a TABLE (as are almost all of the forms i've encountered at the BoA web site) by using the THEAD and TFOOT elements to indicate the start and end of a TABLE-ized FORM. for example: <TABLE border="0" cellspacing="0" cellpadding="0" width="187" summary="Use this four field form to find the Talking ATM closest to you."> <THEAD> <TR><td style="display:none;">Find a Talking ATM</td></TR> </THEAD> <TFOOT> <TR><td style="display:none;">End of Find a Talking ATM form</td></TR> </TFOOT> <TBODY> <!-- insert rest of table-ized form here, keeping the pseudo-title an H2 - -> </TBODY> </TABLE> Note that the use of the "summary" attribute should be universally applied to every TABLE on the BoA site that is used to visually demarcate a block of text or controls that are related, and are essential to a full understanding of the contents of a document which is formatted using the TABLE element for stylistic reasons, and not limited merely to TABLEs that contain FORMs. an example of this can also be found on http://www.bankofamerica.com/accessiblebanking/ <!-- begin extant document source --> <table border="0" cellspacing="0" cellpadding="0" width="187" summary=""> <!-- end extant document source --> <!-- begin corrected document source --> <table border="0" cellspacing="0" cellpadding="0" width="187" summary="Layout Table Containing Links to Accessible Banking Information"> <thead><tr>Accessible Banking Information Center"></tr></thead> <tfoot><tr>End of Accessible Banking Information Center</tr></tfoot> <tbody> <!-- extant document source would go here --> </tbody> </table> <!-- end extant document source --> why is the use of the "summary" attribute so important? because aside from providing contextual information about the nature, function, intent, and size of a form, it is recognized by the major screen reading products on the market, whereas THEAD and TFOOT have been spottily implemented by browser manufacturers, which is why i suggested the use of the CSS value "display: none;" so that the information will be passed along aurally to those experiencing the page aurally, whilst it will be invisible to those experiencing the page visually. for fully functional examples of a BoA form, reformatted for accessibility, please consult the following: index: http://www.hicom.net/~oedipus/temp/BoA/atm_locator_gjr.html option 1: http://www.hicom.net/~oedipus/temp/BoA/atm_locator1.html option 2: http://www.hicom.net/~oedipus/temp/BoA/atm_locator2.html (note: of the 2 options, i would strongly recommend the second, however, i accomodated the tablization of the FIELDSET form in option 1, in keeping with the current design structure of the BoA site, which uses TABLEs for layout, rather than controlling layout through the use of the DIV element in HTML/XHTML and the use of CSS to control placement, flow, etc. - i would strongly encourage you to consult sites such as the W3C's site [http://www.w3.org], the Web Accessibility Initiative's sub-site [http://www.w3.org/WAI/], and the site of the American Foundation for the Blind [http://www.afb.org/] for "real-life" examples of the use of valid and accessible markup) 3) this is not an accessibility problem, per se, but why is there a limit on the number of characters that one can enter into the "Company Name" text-entry field? how can one have an electronic check cut for a company whose full name doesn't fit in the "Company Name" field? the check MUST have the full name of the company on it to be valid, but the hard cap on the number of characters allowed in the text entry field for "Company Name" often precludes this. ISSUE 3 - Timeout: when one is blind or visually impaired, there is no overall, all-encompassing, gestalt view of a web document; rather, the blind or low vision user experiences the document serially and linearly. this is one of the reasons why unambiguous hyperlink text is so important, and why it is so important that when identical hyperlink text is used each of the links points to the same target. the aural and highly-magnified experience of a site such as BoA's, therefore, is extremely time-consuming, as the site's designers have attempted to put as much functionality into each page as possible. moreover, simply listening to a page, obtaining a list of links on a page, obtaining a list of forms on a page and ascertaining the individual form elements that comprise each form does not, from a browser's or server's programmatic point-of-view constitute activity, leading to premature time-outs. while the site is set to generate an operating system warning that the session is about to time out, such a warning may not be announced by a users' screen reader, or caught by a user's screen magnification program. worse, if the user is switching between a browser displaying the BoA web site and another program, such as NotePad, where the user keeps his or her banking information, or which a user is using to make a text image of a statement or an account's recent activity, such pop-up warnings can be inadvertantly cleared by a keystroke intended for the application being used for note-taking, or the warning (which in my personal experience does NOT come to the forefront of the desktop) may be imperceptable to the user until he or she attempts to return to the browser instance in which the user's BoA information is displayed, forcing the user not only to start whatever task he or she had begun over again from the beginning, but to re-login to the BoA system. even when the warning is generated and perceived by someone like myself who is operating in an eyes-free environment, due to the association of a system sound with the system alert dialogs, one cannot always get to the alert in time to stop the server from logging one out. i fully understand WHY BoA times-out sessions after a specified period of inactivity, and i appreciate that it does so from a security point of view, but as a blind user, i find that the annoyance of having to relogin and restart whatever task i had begun from the beginning - on occasion multiple times - far outweighs my appreciation for this particular security measure. is there no way to allow a user to choose a longer timeout period? the onus would be squarely placed on the user whether or not to extend (or shorten) the timeout period, and the ramifications of the user's action in this regard would be his or her responsibility slash liability. if offering user-control over session time-outs is deemed impractible or unadvisable by BoA, could not some accomodation be made for those users who are known to BoA, or who identify themselves to BoA, as having special technological needs (such as the use of a screen reader, a screen magnification program, speech input, an eyeball- tracking mouse, an on-screen keyboard, etc.) to extend the time out period? this isn't as impractical as it may sound on first reading, as BoA is forcing its online users to use the SiteKey system, for which an ambiguous promise of accessibility for those who cannot process visual information (a group that includes not only the blind and visually impaired, but those with certain types of cognative impairments) has been made. surely, if there is a way for me to verify my SiteKey non-visually, there should be a way for the BoA server to programmatically note that i need to tailor the server's default timeout period. whilst i will address specific problems i have encountered with the SiteKey mechanism so far in a separate section, it should be noted that since my session timed out whilst i was attempting to set up my SiteKey, i have not been able to log back into BoA's online banking services, as i am prompted for my "online ID", which i never had the chance to create, since i was carefully reviewing the SiteKey instructions, and attempting to use the SiteKey help to ascertain precisely how the SiteKey mechanism -- not to mention the SiteKey registration interface -- is supposed to function when one cannot perceive the visual SiteKey. as a result, i cannot currently log back into the BoA site, for whilst the "where do i enter my passcode" hyperlink states: quote NOTE: If you have not yet created your personalized SiteKey, you will be prompted to do so before you can sign in to Online Banking. unquote [source: http://www.bankofamerica.com/privacy/sitekey/EnterPasscodePopup.cfm] the BoA site has NOT prompted me to create a personalized SiteKey since i was timed out, despite having shut down my browser, and even rebooting my computer. which leads me to the final issue i wish to address in this emessage: ISSUE 4 - SiteKey Sign-Up Problems: first of all, why is BoA using a turing-type test as a security measure, rather than using signed certificates, and other non-intrusive digital security measures? second, in attempting to use the BoA site, i was confronted by the SiteKey introductory page, which raised the following issues: 1. there is insufficient information (aside from a brief mention in the introductory text that an accomodation has been made for those who cannot see images) for a blind user to: a) choose an image (the ALT text assigned to each image is archival in nature, not contextual, and does NOT provide any REAL information about the contents of the image) b) entitle the image (if i don't know what the image is, how can i title it?) 2. when my session timed out, i could not return to the SiteKey Sign-Up interface to complete my attempts at obtaining a SiteKey and testing its accessibility, as outlined in the last paragraph of the preceding issue statement; why did my sesssion time out? because, as i indicated, i was attempting to be cautious, as it behooves anyone when handling one's business affairs, using whatever assistance was provided to find out as much as i could about SiteKey, as well as attempting to keep a log of the problems with the interface that i experienced whilst attempting to obtain a SiteKey. please address these issues (a) seriously, (b) comprehensively, and (c) immediately, as there is nothing more important to an individual than his or her autonomy, and nothing more detrimental to that autonomy than losing direct control over and knowledge of one's finances, which is precisely the result of the accessibility problems at the BoA site for those of us unable to process visual information. sincerely, gregory j. rosmaita phone: 1 973 746 1192 email: oedipus@hicom.net BoA Reformat Options and Related References (note that the "o" in "BoA" is lowercase): http://www.hicom.net/~oedipus/temp/BoA/atm_locator_gjr.html DateStamp for the construction of this emessage and the accompanying examples: 1/22/2006 [10:40AM to 6:29PM] 1/23/2006 [12:33PM to 4:07PM] ------------------------------------------------------------------ ACCOUNTABILITY, n. The mother of caution. Ambrose Bierce, _The Devil's Dictionary_ ------------------------------------------------------------------ Gregory J. Rosmaita: oedipus@hicom.net Camera Obscura: http://www.hicom.net/~oedipus/index.html VICUG NYC: http://www.hicom.net/~oedipus/vicug/index.html Read 'Em & Speak: http://www.hicom.net/~oedipus/books/index.html UBATS - United Blind Advocates for Talking Signs: http://ubats.org ------------------------------------------------------------------ Originally received on Wednesday, 15 November 2006 21:36:50 GMT
Received on Sunday, 5 August 2007 00:04:39 UTC