ATM ADA Guidance

Client Communication June 18th 2011 CDS Compliance & Security

Stuart Mackinnon Columbus Data Services Columbus Data Services

ATM ADA Guidance Client Communication

Columbus Data Services

Table of Contents
Document Purpose ....................................................................................................................................... 3 2010 ADA Standard for Accessible Design Summary.................................................................................... 4 ADA Compliance Timelines ........................................................................................................................... 5 CDS ADA Compliance Initiatives ................................................................................................................... 5 Client ADA Compliance Initiatives................................................................................................................. 5 ATM Model Specific Guidance ...................................................................................................................... 6 Next Steps ..................................................................................................................................................... 7 Sample Letter for Merchants ........................................................................................................................ 7

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ATM ADA Guidance Client Communication

Columbus Data Services

Document Purpose
The recent changes to the ADA (Americans with Disabilities Act) standards resulted in new requirements for ATM deployers. For many types of ATMs, the regulations affect only the ATM itself. For ATMs that receive operating and configuration information from the processing platform (commonly known as States & Screens terminals), achieving compliance may require both ATM and Processor level upgrades. This document provides a brief introduction to the 2010 ADA Standards for Accessible Design and includes recommended actions to ensure your devices are compliant with the standard. It is important to understand that software changes to the CDS processing platform are just one part of the compliance requirements you may also need to invest in ATM hardware and software upgrades. This is an activity that you need to plan/budget for, and may wish to consider outsourcing. This document does not constitute legal advice. CDS encourages clients to consult with legal advisors if they have any questions with regards to the new regulations.

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ATM ADA Guidance Client Communication

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2010 ADA Standard for Accessible Design Summary

The 2010 STANDARDS FOR TITLES II AND III FACILITIES: 2004 ADAAG, specifically CHAPTER 7: COMMUNICATION ELEMENTS AND FEATURES (in section 707: Automatic Teller Machines and Fare Machines) outlines the requirements of the new ADA standards as it relates to ATMs. These changes are summarized as follows in the Department of Justices Guidance on the 2010 ADA Standards for Accessible Design:

Section 707 of the 2010 Standards adds specific technical requirements for speech output, privacy, tactilely-discernible input controls, display screens, and Braille instructions to the general accessibility requirements set out in the 1991 Standards. Machines shall be speech enabled and exceptions are provided that cover when audible tones are permitted, when advertisements or similar information are provided, and where speech synthesis cannot be supported. The 1991 Standards require these machines to be accessible to and independently usable by persons with visual impairments, but do not contain any technical specifications. (http://www.ada.gov/regs2010/2010ADAStandards/Guidance2010ADAstandards.htm) Additional Information: http://www.ada.gov/ http://www.ada.gov/2010ADAstandards_index.htm (includes links to both the new ADA Standards as well as Guidance on the new standards) http://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm (more easily readable version of the 2010 ADA Standards, assembled by the Department of Justice)

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ATM ADA Guidance Client Communication

Columbus Data Services

ADA Compliance Timelines

September 15, 2010: Final rules published in the Federal Register March 15, 2011: Revised 2010 ADA standards come into effect March 15, 2012: Compliance to the 2010 ADA rules becomes mandatory Refer to http://www.ada.gov/regs2010/factsheets/title3_factsheet.html and http://www.ada.gov/regs2010/ADAregs2010.htm for more information

Effective Date: The rule will become effective March 15, 2011. On March 15, 2012, compliance with the 2010 Standards will be required for new construction and alterations and barrier removal. In the period between September 15, 2010 and March 15, 2012, covered entities may choose between the 1991 Standards and the 2010 Standards. Covered entities that should have complied with the 1991 Standards during any new construction or alteration of facilities or elements, but have not done so by March 15, 2012, must comply with the 2010 Standards. (http://www.ada.gov/regs2010/factsheets/title3_factsheet.html) You should verify independently your own obligations and the dates associated with the ADA regulations.

CDS ADA Compliance Initiatives

CDS will be performing upgrades to the core processing platforms during the month of August 2011. Test systems will be available for client level testing from September 2011 onwards. Production availability is currently scheduled for October 2011. For those clients that operate terminals which require a mutual engagement, CDS client contacts will begin scheduling client consultations in September 2011. The level of engagement and support you require from CDS will depend entirely on the ATM models you currently use or plan to upgrade to. The table on the following page provides details on the level of support required.

Client ADA Compliance Initiatives

You should be beginning to undertake the following initiatives to ensure your business is prepared and protected;
Have an action plan for each terminal in your portfolio. Communicate the requirements to all of your merchants Make certain you have contacted your manufacturers to pre-order ADA upgrade kits and have them available for installation before the March 15, 2012 deadline. Make certain you have sufficient technicians lined up to complete the installations on all deployed terminals prior to the deadline. If you are ordering terminal replacements, you may want to consider purchasing terminals that not only meet ADA requirements but are also EMV capable/capable if/when that functionality is implemented in the U.S.?

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ATM ADA Guidance Client Communication

Columbus Data Services

ATM Model Specific Guidance

In order to support voice guidance, your terminals software (and possibly hardware) may need to be updated. The following are the requirements for each terminal type: Terminal Type Diebold 912 Diebold 911 NCR Aptra Advance Software/Feature Required Agilis 2.2 patch 10 or higher Unsupported AANDC 3.02 or higher NOTE: RealSpeak required for Multi Lingual Load sets AE 3.0 or higher Unsupported --Support Provided By Text-To-Speech data from host Unsupported Text-To-Speech data from host Project Requirements CDS / Customer Effort N/A CDS / Customer Effort

NCR Aptra Edge NCR Native Triton Tranax (Hantle, GenMega) Lipman Glory Hyosung Hyosung NDC TidelAnycard Wincor

Std 1 or Std 3 MoniPlus2 version 1.04.00 -ProCash or ProFlex

Triton Prism 912 Customer Effort CDS/Customer Effort

--

Voice supported locally Unsupported Voice supported locally Voice supported locally Voice supported locally Voice supported locally Voice supported locally Text-To-Speech data from host Voice supported locally Voice supported locally, via web enhancements; labor/software from Wincor is required Text-To-Speech data from host

CDS/Customer Effort Customer Effort Customer Effort Customer Effort Customer Effort Customer Effort CDS / Customer Effort Customer Effort CDS/Customer Effort

CDS / Customer Effort

Clients with the appropriate resources may configure voice guidance at the terminal independent of CDS CDS and/or the client will need to review the overall scope of the ATM configuration to determine the appropriate path to supporting voice guidance

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Next Steps
Please contact your CDS Account Manager for further information or to request specific customization services.

Sample Letter for ATM Owners

The following page contains a sample letter that has been provided by Meta Payment systems. You may elect to use or modify this to assist in communications with your clients.

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ADA Rules for ATMs June XX, 2011 Dear ATM Owner: The Americans with Disabilities Act Accessible Design (ADAAD) final rule was published on September 15, 2010 with the standards going into effect March 15, 2012. What does this mean to you and your merchants? The simple answer is that by March 15, 2012, every deployed terminal in the United States (whether owned by ISOs, merchants, ATM operators, financial institutions, whomever) must be fully compliant with the requirements or standards for accessible design that were published in 2010. The ATM terminal standards that must be met by March 15, 2012 are published in this link: http://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm Structural elements have been grandfathered by the Department of Justice (DOJ). The DOJ term for grandfather is safe harbor. Auxiliary aids are not under the safe harbor clause of the Federal Register Rules published by the DOJ. Since voice guidance and Braille instructions are considered auxiliary aids, both must be available on every deployed terminal as of March 15, 2012. With regard to location, the law requires a terminal inside a location and one outside the same location be considered two separate locations and both must be compliant. However, if there are two terminals within a location (i.e. merchant store), then only one of the terminals needs to be upgraded. This is a high level listing of required updated standards with regard to ATMs. Voice Guidance All ATMs must be speech enabled to service visually impaired consumers. Braille Instructions Braille instructions to initiate the voice guidance feature must be provided. Height and Reach ATMs reach must equal 48 inches. Clear Floor Space The area around the machine needs to equal 48 inches by 48 inches. Input Device Input device controls must be tactually discernible, meaning key surfaces must be raised above the surrounding surfaces. Numeric Keypads Keypads must be arranged in a 12-key ascending layout or descending layout. Function Keys Function keys must be designed to contrast visually from their background surfaces. o Enter or Proceed Key: raised circle o Clear or Correct Kay: raised left arrow o Cancel Key: raised letter o Add Value Key: raised plus sign o Decrease Value Key: raised minus sign Display Screen - For visibility from a point located 40 inches above the center of the floor in front of the ATM, characters on the screen must be in sans serif font, a minimum of 3/16 inches high, and contrast with their background. To meet the ADAAD requirements, the ATM owner may be required to purchase an upgrade kit for the deployed terminal. In other situations, upgrade kits may not be available for the terminal or it may not make economic sense to upgrade a terminal no longer supported by the manufacturer. In those situations, replacement of existing terminals with new terminals may be the best solution. If you are ordering terminal replacements, you may want to consider purchasing terminals that not only meet ADA requirements but are also EMV capable if/when that functionality is implemented in the U.S.