thank you madam for your initiative to take this issue to the higher officials
On 11/08/2020, Vaishnavi Jayakumar <[email protected]> wrote: > When the form to complain about inaccessible CAPTCHAS in net banking, > itself has an image-only CAPTCHA! > > http://about.me/vjayakumar > > > ---------- Forwarded message --------- > From: Vaishnavi Jayakumar <[email protected]> > Date: Tue, 11 Aug 2020 at 20:52 > Subject: Re: FW: SBI CAPTCHA issue: India's Deafblind & CAPTCHA related > denial of service > To: Scenta Joy <[email protected]> > Cc: Balu K <[email protected]> > > > Dear Ms. Scenta, > > The SBI personal banking website today still offers only image and audio > options CAPTCHAs for login, thus denying the most basic access to > deaf-blind customers for over a year now. > > Despite this issue being raised repeatedly by affected stakeholders, there > has been no resolution. > > Please let us know the way ahead so this can be sorted amicably. There's > been no response for 18 days since this request reached you. > > I would also like to flag a similar concern expressed by a blind customer > who when trying to complain about this issue to RBI, faced an > insurmountable barrier at the end of the complaint form - an image CAPTCHA. > I have personally tested the same > <https://cms.rbi.org.in/rbi/VividFlow/run/rbi#RBI%20Application%20Detail> > today (screenshot attached) and discovered there are approximately 18 > instances of inaccessible CAPTCHAs on the RBI portal. > > [image: RBI CAPTCHA epic fail.jpg] > > I would like this deficiency rectified and the complaint management system > revamped on a war footing to reflect internet and mobile app banking > concerns that are not branch specific as the form is designed. Addition of > "Accessibility for disabled customers" with subcategories of whether > barriers are physical, electronic or virtual would help complainant ease in > the future. > > Regards, > > Vaishnavi Jayakumar > > http://about.me/vjayakumar > > > On Fri, 24 Jul 2020 at 10:54, Balu K wrote: > >> Ms. Scenta, >> >> >> >> I am forwarding the mail from Ms. Vaishnavi Jayakumar of Disability >> Rights >> Alliance, India, >> >> Which is self explicit for your information and necessary action. >> >> As a part of our awareness work, I had two occasions to meet up with the >> members of DRA last year. >> >> >> >> With best regards. >> >> >> >> >> >> डॉ बालु के / Dr. Balu K >> >> मुख्य महाप्रबंधक एवं आरबीआई लोकपाल / Chief General Manager & RBI >> Ombudsman >> >> आरबीआई लोकपाल का कार्यालय / Office of the RBI Ombudsman >> >> भारतीय रिज़र्व बैंक / Reserve Bank of India >> >> चेन्नै / Chennai - 600 001. >> >> दूर / Tel : 044 2539 5964 >> >> >> >> >> >> >> >> *From:* Vaishnavi Jayakumar >> *Sent:* 23 July 2020 23:58 >> *To:* Balu K <> >> *Cc:* Disability Rights Alliance, India <>; Zamir Dhale (SEDB) <> >> *Subject:* SBI CAPTCHA issue: India's Deafblind & CAPTCHA related denial >> of service >> >> >> >> Dear Mr. Balu, >> >> >> >> *15 June 2019* was the compliance deadline for both government and >> private websites as mandated by (*section 46 : Time limit for >> accessibility by service providers)* RPWD Act 2016 >> <http://disabilityaffairs.gov.in/upload/uploadfiles/files/RPWD%20ACT%202016.pdf> >> and >> (*section 15c : Rules for Accessibility - Information and Communication >> Technology)* of the RPWD Rules 2017 >> <http://disabilityaffairs.gov.in/upload/uploadfiles/files/Rules_notified_15_06.pdf>. >> (*Read http://bit.ly/design-for-diversity >> <http://bit.ly/design-for-diversity> for the relevant extracts.)* >> >> >> >> *WHAT THE LAW SAYS* >> >> >> >> *Rights of Persons with Disabilities Rules 2017 (notified 15 June 2017)* >> >> >> >> *15 (c) Information and Communication Technology-* >> (i) *website standard* >> as specified in the *Guidelines for Indian Government* *Websites*, >> <https://web.guidelines.gov.in/assets/gigw-manual.pdf> as adopted by >> Department of Administrative Reforms and Public Grievances, Government of >> India; >> (ii) *documents * >> to be placed on websites shall be in Electronic Publication (ePUB) or >> Optical Character Reader (OCR) based pdf format >> >> >> >> *Rights of Persons with Disabilities Act 2016 (RPWD Act)* >> >> >> >> *46. Time limit for accessibility by service providers.—* >> The service providers whether Government or private shall provide >> services in accordance with the rules on accessibility formulated by the >> Central Government under section 40 within a period of two years from the >> date of notification of such rules >> >> >> >> Yet in August 2019, State Bank of India introduced an inaccessible >> security measure (Image CAPTCHA - as sole option, inaccessible to blind >> customers) on its netbanking website. After uproar from the very vocal >> blind community >> <https://www.mail-archive.com/[email protected]/msg121077.html> >> in India, an audio CAPTCHA option (as sole option, inaccessible to deaf >> customers) was hastily added within a fortnight. Sadly this piecemeal >> approach to a universally designed UX failed to consider the needs of >> deaf-blind customers. Team SEDB >> <http://sedbindia.org/mr-zamir-dhale-the-founder/> (Society for >> Empowerment of DeafBlind India) has written to Govt authorities on the >> need >> for plain text alternatives for CAPTCHAs and other content, to no avail. >> >> >> >> [image: SBI Login CAPTCHA FAIL Screen capture 23-07-2020 081343 PM.jpg] >> >> >> >> To that end, I reached out on 26th August 2019 to Ms Jaya D Pai who had >> been in touch with the blind community for troubleshooting their >> accessibility issues. While her initial response was heartening (see >> thread >> at end), subsequent follow up has yielded a sustained denial of service >> to >> deaf-blind Indians to even login to their own account, leave alone >> transact >> online for close to a YEAR. >> >> >> >> Here's what the RPWD Act mandated GIGW (Guidelines for Indian Government >> Websites) prescribes <https://web.guidelines.gov.in/6-6-images> for this >> particular accessibility issue : >> >> >> >> *WHAT THE GIGW 2.0 GUIDELINE SAYS* >> >> *(Page 78 of GIGW 2.0 >> https://web.guidelines.gov.in/assets/gigw-manual.pdf >> <https://web.guidelines.gov.in/assets/gigw-manual.pdf> *:) >> >> *6.6.3 Images and other non text content MUST be made Accessible *. >> . >> >> *(v) CAPTCHA: *If the purpose of non-text content is to confirm that >> content is being accessed by a person rather than a computer, then text >> alternatives that identify and describe the purpose of the non-text >> content >> are provided, and alternative forms of CAPTCHA using output modes for >> different types of sensory perception are provided to accommodate >> different >> disabilities. >> >> >> >> As already pointed out, while a text-based logic type CAPTCHA may solve >> the issues of the deaf-blind constituency, a more wholistic solution >> catering to varied needs of people would entail offering *multimodal >> options leaving choice to the consumer* : i.e. >> >> - Image CAPTCHA >> - Audio CAPTCHA >> - Text based logic CAPTCHA >> - SMS OTP CAPTCHA >> - EMAIL OTP with click link to verify CAPTCHA. >> >> I look forward to your support in resolving this issue at the earliest. >> >> >> >> Thank you, as always for being a steadfast ally to India's disability >> movement. >> >> >> >> Sincerely, >> >> >> >> *Vaishnavi Jayakumar * >> >> Member *Disability Rights Alliance* >> >> >> >> http://about.me/vjayakumar >> >> >> >> ---------- Forwarded message --------- >> From: *Vaishnavi Jayakumar* <> >> Date: Fri, 13 Sep 2019 at 14:47 >> Subject: Re: SBI CAPTCHA issue: Deafblind and CAPTCHAs >> To: Zamir Dhale >> Cc: Namita Jacob >, WE the PwD Egroup <>, Meenakshi Balasubramaniam , >> pradip SEDB, Vickram Crishna <>, Amar Jain >> >> >> >> Hi, >> >> >> >> I sent a reminder about the text CAPTCHA support to Ms. Jaya D Pai on 5th >> September. There is still no solution for deaf-blind a month after SBI >> introduced image CAPTCHA. Audio CAPTCHA was provided speedily. >> >> >> >> A formal letter from SEDB stating problems faced by this community would >> be essential at this stage along with a reminder of statutory compliance. >> >> >> >> Please email the same to [email protected] asap. >> >> >> >> Regards, >> >> >> >> Vaishnavi >> >> >> >> On Thu 29 Aug, 2019, 4:18 PM Zamir Dhale, <[email protected]> wrote: >> >> Hi Namita, >> >> I have gone through and read mail from Vaishnavi madam. As far as you are >> aware that Pradip has been sent to CCPD and SW delhi last few months >> against captacha inage. No Deafblind or Blind is using any application >> online with this Captacha support. Shall I request Pradip to resend >> letter >> to them? Please advise. >> >> Warmly, >> >> Zamir Dhale >> >> The Founder Advisor >> >> www.sedbindia.org >> >> >> >> *From:* namita jacob >> *Sent:* 27 August 2019 9:42 >> >> Thanks Vaish and all at Equals. This is a big barrier and having SBI >> complying is the beginning of the longer battle of all public service >> websites. >> >> >> >> On Mon, 26 Aug, 2019, 17:54 Vaishnavi Jayakumar, wrote: >> >> *Update on SBI login CAPTCHA issue - they have committed to a text based >> logic one* >> >> >> >> *First read this* : >> https://www.mail-archive.com/[email protected]/msg121077.html >> >> >> >> So contacted Ms. Jaya D. Pai - here's the conversation.* I still don't >> know what will happen to people with learning disabilities, but deafblind >> should be ok.* >> >> >> >> [26/08, 5:06 PM] Vaishnavi Jayakumar: Hi, my name is Vaishnavi Jayakumar >> >> I'm a member of Disability Rights Alliance. >> >> Just saw your reply in the Access India forum and have some concerns re >> CAPTCHA usage. >> >> Please replace image-only CAPTCHAs across SBI websites with *multimodal* >> ones to enable use by all citizens with disabilities i.e. Image + Audio + >> Text based logic + SMS OTP + EMAIL OTP. >> >> >> >> Blind customers get stopped by this current inaccessible visual-only >> human-verification CAPTCHA. >> >> >> >> Adding an audio CAPTCHA alone would not be totally inclusive as deafblind >> customers would get excluded. >> >> >> >> Please refer page 78 of GIGW 2.0 >> https://web.guidelines.gov.in/assets/gigw-manual.pdf : 6.6.3 Images and >> other non text content MUST be made Accessible >> >> (v) CAPTCHA: If the purpose of non-text content is to confirm that >> content >> is being accessed by a person rather than a computer, then text >> alternatives that identify and describe the purpose of the non-text >> content >> are provided, and alternative forms of CAPTCHA using output modes for >> different types of sensory perception are provided to accommodate >> different >> disabilities. >> >> >> >> GIGW 2.0 compliance which extends to mobile apps is now required under >> the >> RPWD Act. Details are available at http://bit.ly/design-for-diversity >> >> >> >> Alternatively you could explore ReCaptcha v3 as a quick fix solution till >> such time you streamline providing a multimodal interface.Here's some >> more information regarding this. https://www.24a11y.com/2018/recaptcha/ >> >> DRA's technical consultants would be happy to speak to SBI counterparts >> to >> advise on this matter. >> >> >> >> [26/08, 5:33 PM] Jaya D Pai SBI Internet Banking: Thank you for the >> feedback and sensitising me to the various technological challenges >> faced >> by our differently abled friends and customers >> >> [26/08, 5:34 PM] Jaya D Pai SBI Internet Banking: I agree. We are >> working >> out a text based logic solution >> >> >> >> [26/08, 5:38 PM] Vaishnavi Jayakumar: >> >> Great, thanks! >> >> >> >> >> ------------------------------ >> >> Caution: The Reserve Bank of India never sends mails, SMSs or makes calls >> asking for personal information such as your bank account details, >> passwords, etc. It never keeps or offers funds to anyone. Please do not >> respond in any manner to such offers, however official or attractive they >> may look. >> >> >> Notice: This email and any files transmitted with it are confidential and >> intended solely for the use of the individual or entity to whom they are >> addressed. If you are not the intended recipient, any dissemination, use, >> review, distribution, printing or copying of the information contained in >> this e-mail message and/or attachments to it are strictly prohibited. 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