Every U.S. organization communicating with people about their personal information—including account statements, bills, and medical information—is subject to accessibility legislation. This legislation, which could be at the federal or state level, generally mandates equal access to these communications.
The civil rights legislation with the most reach and enforcement is perhaps the Americans with Disabilities Act (ADA), operating at the federal level.
If your organization suddenly receives a request for accessible statements that meet ADA requirements—and perhaps tellingly, if you must deal with this yourself as a new request—you probably need some guidance.
In this article, we will summarize how you plan to meet ADA legal obligations to provide accessible statements that contain user (i.e., customer, client, taxpayer) protected information.
First, let’s look at the legal obligations very generally.
Your Organization’s Legal Obligations
The Americans with Disabilities Act contains several large sections called “Titles.” Title II deals with public entities, including public transportation; it prohibits disability discrimination by all public entities at the municipal and state levels.
Title III concerns private sector organizations and “public accommodations”: for those parts of private entities that the public can access, Title III mandates full and equal enjoyment of the goods, services, facilities, or accommodations.
Title II and III require that public and private (respectively) entities furnish or respect necessary “auxiliary aids and services.”
These can include allowing persons with disabilities to bring in service animals or persons to provide communication assistance and providing alternative format documents such as “audio recordings; Braille materials (and) large print materials.”
Accessible Statements
For organizations that provide statements to individuals, these statements must consider the requirements of the ADA Title II and Title III. In this context, “statements” include bank account statements, utility bills, credit card statements, and private medical information documents. All of these contain one or more pieces of personal and sensitive information.
This confidential information and its handling and communication are subject to one or more standards governing storage, access, use, and transmission (including by post). We touched above on the kinds of accessible alternative formats that the ADA covers.
Types of Alternate Formats That an Individual May Prefer and Request May Include:
- Braille: raised dots on thicker card stock in cells of up to six dots. This can be digital, but the classic printed braille requires special printing.
- Large Print: printed matter with a much larger font size (“typeface”) than normal.
- Accessible PDF: a PDF defined specifically to ensure people with disabilities can access the content. It can be printed or made available digitally.
- Audio: content that has been rendered into a spoken, audible recording. This can be accomplished with either a human or synthetic voice.
- E-text: While variable, this is generally text content without formatting, supplemental images, tables, or other such structures.
There is no legal obligation to provide all these formats; obviously, some are beyond the realistic expectations of some organizations and will require outsourcing if needed.
Things to Keep in Mind When Providing Accessible Statements Upon Request
It is easier to increase font size in a document and format for Large Print, whereas braille statements will require special card stock and dedicated, specialty printing facilities and expertise.
ADA Title III encourages private sector entities to consult with individuals with disabilities to determine the most appropriate aids or services for their needs.
Braille documents will not automatically meet the needs of people with visual disabilities, as reading Braille is a skill in itself. In addition, the law recognizes that all organizations have limitations in providing aids or services versus the cost and resources available.
An important side note is that when your customers request alternative formats, make their choice part of their regular, expected service.
Store this preference and deliver the same format until the customer requests a change. Do not force them to request their preferred format repeatedly; ensure this information is on file, securely, for any service representatives to see. This is an important aspect of good customer service.
Evaluate factors such as your business size, the types of statements you send to customers and the public, the resources you will have available (including physical production and software capabilities), and the frequency of requests for alternative formats.
Now, you can evaluate what statements you can produce in-house versus those you need to outsource.
When or if you decide to outsource statement production, you must carefully research what vendors can provide. This includes considering not only statement type but reliability, track record, and security of your customer information.
Thankfully, Allyant is an industry leader in all these categories.
How Allyant Can Help
Allyant has decades of experience in large-volume statement production, including braille, accessible PDF, and Large Print. Our approach is specific to each customer. Allyant has incorporated AI-driven automation to make production leaner and more efficient.
When working with a new customer, we collect a relevant sample of their regular statements to assess the types of data and how it’s organized.
We consider data presentation structure and contents, such as headings, logos and images, tables, lists, formulas, and any attached marketing material.Then, our software can define templates around our customer data and produce it in multiple alternative formats. We comprehensively test the output to ensure it is congruent with the original samples.
We prioritize privacy and security, including:
- HIPAA certification
- SSAE 18 SOC2 Type 2 certification
- Payment Card Industry Data Security Standard (PCI-DSS) certification
We regularly complete security audits in concert with our industry partners, ensuring we provide secure handling and production, including backup and disaster recovery planning.
Statement production includes a complex meshing of different elements, including customer service, design, production, delivery, security, and handling.
At Allyant, we have extensive experience securely creating and providing statements in all alternative formats. We maintain solid relationships with our customers and regularly assess and re-assess our statement templates and production to meet our service level agreements with them.
Our customers include banks, credit card companies, utilities, and other financial institutions, as well as municipal, state, provincial, and federal governments. If your organization needs to consider statement production, please contact Allyant for a consultation.
