The Eight-Step Plan for Financial Digital Accessibility Compliance
Key takeaways from TPGi’s Finance Digital Accessibility Plan
This plan is meant to help financial institutions provide the best customer experience to their audience and customers. Accessibility is an ongoing process, but all companies start at different levels based on their maturity. Before embarking on your accessibility journey, it’s important to conduct an internal review to assess where your organization stands, and where you should begin.
The accessibility ecosystem involves many departments and roles across an organization. If accessibility efforts are siloed, the overall impact may be diluted, with the possibility of duplicated efforts and missed opportunities. This plan works best when you have a dedicated champion (either internally or through an external partner) who can help align efforts and keep discrete projects moving forward.
(1) Understand and document your most critical customer journeys through personas
There are several questions you can ask yourself to help identify key journeys and uncover potential barriers:
- Who needs access to your digital content? Employees, customers, lawyers, bankers, analysts, representatives, etc. These are all individuals who may need to interact with your website for one reason or another. Work out your key user personas and use their needs to dictate the critical paths.
- When someone lands on your website or digital application, what information do they need to access? A customer may need to talk to one of your representatives, deposit checks, pay bills, transfer money, or access information about their account. Identifying these needs and the steps users will need to take to accomplish each task will help define your key user journeys.
- How would a prospective or current consumer utilize important information such as resources, memberships, bank accounts, and other financial-related information? Forms are the gold standard for submitting information online. Whether it’s applying for an account, credit, loan, or bill pay, your services will need to be usable for everyone. When you include forms as part of the user journey, how do you evaluate if all elements are accessible?
- Consider in-person services. Does your organization use Virtual Teller Kiosks to help users access account information?
(2) Document the systems, pages, processes, forms, or other inputs/outputs that are involved in the higher priority flows
A spreadsheet is helpful when documenting your critical flows, as you will want to create multiple rows to track several layers of each critical item. For example, website or digital application software may require 3-4 web pages, forms, email verification, phone number validation, etc. If the software sends reminder emails, make sure to include that as part of your flow, as emails are commonly overlooked.
(3) Prioritize the critical paths, screens and user flows in the user journey
Start by focusing on public-facing and consumer experiences. Is scheduling payments or paying bills through your website a high-frequency, high-value flow that requires all individuals to have equal access? What help is available if someone gets stuck? Some items will be more critical than others; still more may be outliers. Use this information to ensure the greatest impact for your time and effort applied.
(4) Assess the individual components of each critical flow for accessibility
If your organization relies on any third-party systems like online banking or financial portals, you take on responsibility for their accessibility, full stop. Even if your website is reasonably conformant, you’ll still be held liable if one of these tertiary systems has accessibility barriers. Document and assess these third-party components for accessibility if they are part of a critical user flow.
There are two primary methods for assessing accessibility:
-
- Manual Review/Assessment – The most comprehensive and accurate method for evaluation, but also the most time-consuming. An assessment provides a more holistic accessibility assessment that evaluates much more than conformance to guidelines. A good reviewer will also check an individual’s ability to use, consume, or complete items using a screen reader or some other assistive technology..
- Automated Accessibility Testing – This provides the fastest and most cost-effective method to determine the magnitude of issues or violations against the WCAG standards both on a website as a whole, and for individual user flows. You’ll get great directional insight on a range of accessibility issues that can impact a user’s to utilize the digital content. With TPGi’s automated accessibility testing solution, ARC Monitoring, you’ll also get a WCAG Density Score, a key metric you can use to help assess your legal risk.
Before you gather all this data, however, you need to identify the primary technical “owner” of each system and work out a process for change requests. Document all this information and. house links to relevant items in a centralized management location.
(5) Determine the remediation/implementation plan and roadmap for high-priority items
Once you’ve accumulated all this information on accessibility barriers, you need to plan how to resolve these issues. First, prioritize. Are there any low-hanging-fruit opportunities? Are there any glaring show-stoppers you need to fix immediately? This may seem overwhelming, you can get a free website accessibility scan that will highlight such issues and give you a great place to start.
(6) Remediation and Resolution
Feed the relevant information to the appropriate technology owners and schedule the implementation work. Ensure the developers have access to accessibility code libraries, resources, and experts who can support them. TPGi’s HelpDesk is a rapid-response support solution where teams can get accessibility help for tough problems, coding techniques, and other methods for creating accessible code solutions. Developers can also benefit from our KnowledgeBase, a repository of accessibility techniques that double as a learning resource. Are you able to integrate directly with CI/CD processes or submit tickets as bugs/ideas in aha, Jira, or other development project management software?
(7) Review and Validation
Once your team has completed remediating the accessibility barriers, verify the fixes have resolved the issues. After every section of code has been approved, document it in your tracking log. At this point, it’s beneficial to secure documentation from a third-party consulting company to confirm the fixes were correct. Part of the verification process can include a VPAT that proves that the new code conforms to accessibility requirements. This information will be critical in the event your organization becomes the target of a lawsuit.
As part of your review and verification process, engage individuals who use screen readers to test out your handiwork. If this is not feasible, try a tool like JAWS Inspect, a software solution that turns JAWS audio output into text. You can actually see how a JAWS reader would experience the site without using the screen reader software as a testing agent (which can be difficult to learn).
(8) Ongoing Monitoring for Changes
Consistently document statuses in your records for all your related work and remediation effort. Automated testing software is invaluable for this, as it automatically tracks changes in your website’s accessibility. If the testing shows your accessibility has declined, you’ll be able to quickly see the impact on your site and know where to go to find out what has been done to date. If you are facing litigation, your record-keeping efforts here will be helpful to defend your case (and your job!).
If you start this step at the beginning of a cycle, you will be able to use it as a baseline for measuring success. Alternatively, if you set it up towards the end, know that accessibility does have a cyclical or recurrent nature, so you’ll be able to use the insights you’ve gathered to identify the next set of items to shepherd through these stages.
Taking the next step
This may seem oversimplified, but we fully understand the devil is in the details. Building an accessibility roadmap that will get your organization to a desired level of accessibility depends on a lot of factors, including your organization’s “accessibility maturity” stage, size of investment in accessibility conformance, buy-in from key partners and stakeholders, and the age and complexity of your integrated systems.
However, use these steps as a loose guide to acquire a better sense of how you perform throughout the cycle, your potential trouble areas, and how you can start to make a positive impact.
Are you curious about your website’s level of legal risk?
As always, TPGi is here to support your efforts. Schedule a demo of ARC to find answers, insights, and prioritized recommendations you can act on immediately to lower your risk.
The Eight-Step Plan for Financial Digital Accessibility Compliance
Use the following information to gain a better understanding of what to expect as you identify, document, and gain control over your financial institution’s digital accessibility.