SBI CAPTCHA issue: Deafblind and CAPTCHAs Fwd: [AI] UDID portal-audio captcha status

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Vaishnavi Jayakumar

unread,
Aug 26, 2019, 8:24:29 AM8/26/19
to WE the PwD Egroup, Egroup DRA, Amar Jain, Meenakshi Balasubramaniam, Namita Jacob, pradip, Vickram Crishna, Zamir Dhale, Parag Namdeo, Akhil S. Paul, sac...@senseintindia.org
Update on SBI login CAPTCHA issue - they have committed to a text based logic one


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. 



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!


On Mon 8 Apr, 2019, 3:02 PM Zamir Dhale, <zamir...@gmail.com> wrote:

Dear Amar and Vishanavi,

Please see the attached, it prepared and supported Pradip Sinha, SEDB by Ms. Meenaskhi, to send you accordingly. We are heavily busy scheduled, find it a difficult to work, but I am very thankful to Equalis, Chennai, who worked with us for SEDB.

Thanks and hope it is okay. Please send this to Ministry.

Best,

Zamir

 

From: Vaishnavi Jayakumar [mailto:jayakumar...@gmail.com]
Sent: 08 April 2019 11:44
To: Amar Jain <amar...@amarjain.com>; Meenakshi Balasubramaniam <meen...@equalscpsj.org>
Cc: Zamir Dhale <zamir...@gmail.com>; namita jacob <jacob....@gmail.com>; pradip <pra...@sedbindia.org>
Subject: Re: Deafblind and CAPTCHAs Fwd: [AI] UDID portal-audio captcha status

 

I forgot to mention that even the WCAG group is struggling with this issue though it's recently come out with a working draft. https://www.w3.org/TR/turingtest/ 

 

That's why a range of options is best - (image + Audio + Text based logic + SMS OTP + EMAIL OTP) - a text-based logic CAPTCHA may be accessible for blind, deaf and deafblind, but could pose significant difficulty to a person with learning disability.   

 

On Mon, 8 Apr 2019 at 11:37, Vaishnavi Jayakumar <jayakumar...@gmail.com> wrote:

Adding Meenakshi to the conversation as she is helping with some of the writing.

 

The official DARPG Twitter account keeps posting updates on the GIGW2 meetings - they seem to be chaired by this additional secretary :  V. Srinivas Additional Secretary 402 23741004 23741005 (Telefax) vsri...@nic.in 9560939977

 

Apart from UDID (the irony!), NVSP, UIDAI and countless others, I have noticed that even choosing an HDFC portal to pay for IRCTC train tickets goes through a 3rd party private site called FSSTech - which offers only mage CAPTCHAs.

 

I think we should ask Mr Srinivas of DARPG to send out a circular mandating a default range of CAPTCHA options to be used going forward. The problem is so serious that it deserves not to be clubbed along with other STQC / GIGW correspondence.

 

Here is a list of over 100 government websites using CAPTCHAs that need fixing for a start.

 

P.S. Meenakshi & Namita, I just realised that FSSTech is headquartered in Chennai on the OMR. Let's visit and get change cracking.

 

 

 

On Mon, 8 Apr 2019 at 04:49, Amar Jain <amar...@amarjain.com> wrote:

Hi guys,

 

I will be filing an appeal against the RTI reply to ensure that the captcha is made accessible for deaf blind users. And I need you to raise same concerns.

 

Regards,

Amar Jain

Sent from my iPhone


On 07-Apr-2019, at 4:30 PM, Zamir Dhale <zamir...@gmail.com> wrote:

Dear Vaishnavi,

Thanks for sharing the information. I am copying Pradip Sinha, Society For the empowerment Of The Deafblind(SEDB) India as our Hon Chairman, he is also a person with Deafblindness, working at Dell as IT team. He has good profificient in Techonogies supporting. SEDB is very young and first organization created by a person with Deaflbind same as me for Deafblind people in the country. We will work on this  tomorrow. Please support SEDB as we are Deafblind team running independently. We are doing hardwork without anyone,s help.

Thanks and regards,

Zamir

 

From: Vaishnavi Jayakumar (Inclusive India) [mailto:vaishnavi...@inclusiveindia.info]
Sent: 05 April 2019 17:41
To: Akhil S. Paul <ak...@senseintindia.org>; Parag Namdeo <parag...@gmail.com>; Namita Jacob <namitajden @chetana.org.in>; Zamir Dhale <zamir...@gmail.com>; sac...@senseintindia.org
Cc: Amar Jain <amarja...@gmail.com>
Subject: Deafblind and CAPTCHAs Fwd: [AI] UDID portal-audio captcha status

 

Hi all,

Amar and I have been banging on with IRCTC, UIDAI, UDID, Elections etc about image-only CAPTCHAs usage - which is default on almost all government websites. Government adds an audio CAPTCHA after months and thinks work is done despite us giving a proper brief like below :

ECI Complaint Details
  Complaint ID : NGS-857528
  Date of Lodging Complaint : Feb 27 2019 8:03AM
  Subject : ECI LEVEL
  Brief Description about complaint : Please replace image-only CAPTCHAs across ECI websites with multimodal ones to enable use by all citizens with disabilities i.e. Image + Audio + Text based logic + SMS OTP + EMAIL OTP. In the NVSP form to search for voter links to electoralsearch.in - blind people get stopped by this current inaccessible visual-only human-verification CAPTCHA. Even this grievance website has the same problem.

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.

 

 

It would help if the deaf-blind community joined us in keeping the pressure on.

Please see Amar's update below. 

 

Regards,

 

Vaishnavi

---------- Forwarded message ---------
From: Amar Jain <amar...@amarjain.com>
Date: Fri, 5 Apr 2019 at 17:11
Subject: [AI] UDID portal-audio captcha status
To: <acces...@accessindia.org.in>


After getting fed up in telling Mr. Rao that the portal had a captcha, I had filed RTI. Seems they have addressed the issue by providing audio captcha which still leaves deaf-blind people behind.

Request people to test and confirm.

Regards,
Amar Jain

Vaishnavi Jayakumar

unread,
Sep 13, 2019, 5:17:57 AM9/13/19
to Zamir Dhale, Namita Jacob, WE the PwD Egroup, Meenakshi Balasubramaniam, pradip, 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 dgmi...@sbi.co.in asap.

Regards, 

Vaishnavi

On Thu 29 Aug, 2019, 4:18 PM Zamir Dhale, <zamir...@gmail.com> 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 [mailto:jacob....@gmail.com]
Sent: 27 August 2019 9:42
To: Vaishnavi Jayakumar <jayakumar...@gmail.com>
Cc: WE the PwD Egroup <weth...@googlegroups.com>; Meenakshi Balasubramanian <meen...@equalscpsj.org>; pradip <pra...@sedbindia.org>; Vickram Crishna <vvcr...@gmail.com>; Zamir Dhale <zamir...@gmail.com>; amar...@amarjain.com
Subject: Re: SBI CAPTCHA issue: Deafblind and CAPTCHAs Fwd: [AI] UDID portal-audio captcha status

 

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.

Vaishnavi Jayakumar

unread,
Jul 23, 2020, 2:36:02 PM7/23/20
to Egroup DRA, WE the PwD Egroup, Zamir Dhale, Namita Jacob, Meenakshi Balasubramaniam, pradip, Vickram Crishna, Amar Jain, Zamir Dhale (SEDB)
FYI

---------- Forwarded message ---------
From: Vaishnavi Jayakumar <jayakumar...@gmail.com>
Date: Thu, 23 Jul 2020 at 23:57
Subject: SBI CAPTCHA issue: India's Deafblind & CAPTCHA related denial of service
To: Balu, Dr. K <kb...@rbi.org.in>
Cc: Disability Rights Alliance, India <DisabilityRig...@gmail.com>, Zamir Dhale (SEDB) <za...@sedbindia.org>


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 and (section 15c : Rules for Accessibility - Information and Communication Technology)  of the RPWD Rules 2017. (Read 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, 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 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 (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.

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 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 :) 

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



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.

Vaishnavi Jayakumar

unread,
Aug 11, 2020, 11:28:00 AM8/11/20
to Egroup DRA, WE the PwD Egroup
When the form to complain about inaccessible CAPTCHAS in net banking, itself has an image-only CAPTCHA!



---------- Forwarded message ---------
From: Vaishnavi Jayakumar <jayakumar...@gmail.com>
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 <scen...@rbi.org.in>
Cc: Balu K <kb...@rbi.org.in>


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 today (screenshot attached) and discovered there are approximately 18 instances of inaccessible CAPTCHAs on the RBI portal.

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 


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 and (section 15c : Rules for Accessibility - Information and Communication Technology)  of the RPWD Rules 2017. (Read 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, 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 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 (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.

 

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 for this particular accessibility issue :

 

WHAT THE GIGW 2.0 GUIDELINE SAYS


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

 

 

---------- 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 dgmi...@sbi.co.in asap.

 

Regards, 

 

Vaishnavi

 

On Thu 29 Aug, 2019, 4:18 PM Zamir Dhale, <zamir...@gmail.com> 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

 

 

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!

 




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RBI CAPTCHA epic fail.jpg

K Raghuraman

unread,
Aug 11, 2020, 10:30:13 PM8/11/20
to disabilityri...@googlegroups.com, WE the PwD Egroup
Taking the essence of Smitha, there should be seriously a strong
action taken at the national level
regards
raghu

On 11/08/2020, Smitha Sadasivan <smitha.cit...@gmail.com> wrote:
> Stop crying and START LAUGHING. Common sense is NEVER COMMON.
>
> Don't get angry or hurt unnecessarily and let's not damage our mental
> health.
>
> Now we need to start thinking of new strategies as our usual strategies are
> not working. Let's print wall posters and post it around the area of the
> office which is acting insensibly. As they tear it we need to keep pasting
> it until they finally comply with Accessibilty standards. Nothing like a
> visual opposition even in the digital era.
>
> Smitha
>> <https://cms.rbi.org.in/rbi/VividFlow/run/rbi#RBI%20Application%20Detail>
>>> *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/acces...@accessindia.org.in/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*
>>> *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/acces...@accessindia.org.in/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.*
>>> ------------------------------
>>>
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>> --
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>> To unsubscribe from this group and stop receiving emails from it, send an
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>


--
best regards
raghu

Vaishnavi Jayakumar

unread,
Jul 6, 2021, 1:26:30 PM7/6/21
to Egroup DRA, WE the PwD Egroup


---------- Forwarded message ---------
From: Disability Rights Alliance, INDIA 
Date: Tue, 6 Jul 2021 at 22:49
Subject: Fwd: SBI CAPTCHA issue: India's Deafblind & CAPTCHA related denial of service for 1.5 years despite repeated complaints
To: <dinesh khara>
Cc: <chairman SBI>, <a bhatia>,


6 Jul 2021

Sir,

We are constrained to point out that there has been no action taken on our representation dated 9 Dec 2020. 

Even our 2 year old proposed 'compromise' workaround to deploy SMS OTP for deafblind citizens' netbanking access has been placed at the second level of authentication, leaving deafblind Indians hapless when confronted with the initial screen which only holds image and audio CAPTCHAs.

Please rectify this access violation (as indicated in representation below) at the earliest.

Sincerely,

Vaishnavi   Jayakumar 
Member Disability Rights Alliance
SBI 2021 Violation of Disability Law.jpg
---------- Forwarded message ---------
From: Disability Rights Alliance, INDIA <>
Date: Wed, 9 Dec 2020 at 14:02
Subject: SBI CAPTCHA issue: India's Deafblind & CAPTCHA related denial of service for 1.5 years despite repeated complaints
To: <chai...@sbi.co.in>


Dear Mr. Khara,

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 and (section 15c : Rules for Accessibility - Information and Communication Technology)  of the RPWD Rules 2017. (Read 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, 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 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 (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.

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 over 1.5 years. 

Here's what the RPWD Act mandated GIGW (Guidelines for Indian Government Websites) prescribes for this particular accessibility issue :

WHAT THE GIGW 2.0 GUIDELINE SAYS

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.

Sincerely,

Vaishnavi   Jayakumar 
Member Disability Rights Alliance



---------- 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 dgmi...@sbi.co.in asap.

Regards, 

Vaishnavi

On Thu 29 Aug, 2019, 4:18 PM Zamir Dhale,  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.

SBI 2021 Violation of Disability Law.jpg
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