Located in Toronto with nearly 30 million customers, TD Bank Group is one of the largest financial services firms in North America. With more customers relying on online banking than ever before and with strict Canadian regulations, the Bank considers accessibility a high priority. 

As part of our Accessibility in the Enterprise series, we talked to two accessibility experts at TD: Bert Floyd, Senior IT Manager, Assistive Technologies; and Aidan Tierney, Senior Manager Digital Accessibility. In this interview, you’ll learn how TD has created a culture of accessibility across its business units and locations. 

Meet TD’s Accessibility Experts 

Diamond: Thank you for joining us! Let’s start with an introduction to TD and your roles. 

Bert Floyd: TD is a North American bank with over 90,000 employees across the continent. Inclusion and Diversity is a large part of the employee culture at TD and we have an area of focus dedicated to Persons With Disabilities.

I manage the Assistive Technologies team, and our role is to provide employees with disabilities with technology to help them succeed in their roles. We are also responsible for maintaining the TD IT accessibility standards, which we promote to help businesses create customer- and employee-facing systems that are accessible to everyone. In addition, we work with our vendors who provide technology to the Bank to help them understand our policies and standards to ensure we procure accessible systems.

Aidan Tierney: I manage TD's digital accessibility program, which supports TD's customer-facing websites and apps in the US and Canada. My team guides over 100 teams who build our websites and mobile applications to create accessible experiences.

Communication and Collaboration

Diamond: We often see accessibility under Diversity and Inclusion initiatives or under Compliance or Legal. It’s interesting to see how different organizations accessibility have organized. 

BF: There’s ownership across the organization to help create an inclusive and accessible ecosystem. TD's Inclusion and Diversity team sits within Human Resources (HR) because accessibility is about people. However, my team sits within IT. Our Canadian Accessibility Policy is owned by Compliance, and we work closely with Legal in the US. We work hard to embed best practices in project management, vendor management and governance teams. Each area has a very important role to play in order to deliver on our Inclusion goals.

AT: Inclusion and Diversity is central to the TD brand both in how we attract talent and serve customers. TD considers Persons With DisabilitiesPWDas an aspect of our diversity and inclusion initiatives. I was surprised to read how some other organizations still do not. To me, how could you not? Persons with Disability is an important aspect of diversity as it touches across all cultures, and it is an area that needs more communication and understanding if we are to truly move the dial.

It’s the responsibility of each area of the business to do the day-to-day work to make things accessible. There are various committees at TD that bring together PWD leadership and initiatives from across the organization. The committees are a forum to communicate how everything is going and to share practices. 

Diamond: How would you describe the communication between these different groups and committees? Is it collaborative or do you run into disconnects? 

BF: We have a senior representative from each line of business on the Persons With Disabilities Executive Steering Committee. It’s highly collaborative. They share a lot of ideas around best practices and strategies. There's also an Executive Working Committee, which is where they turn these ideas into action. When one business finds something that works well, it’s shared across the organization. 

AT: I’d say the communication works well. The challenge is effecting change in a large organization. 

Diamond: With the size of TD in mind, how do you combat those implementation challenges? Are there processes in place to try to ease some of those pain points?

BF: We try to put good mechanics in place where we can. For example, with project methodology, we've embedded the accessibility requirements into the template that everyone at the Bank uses. We've built out support documentation that designers, developers, and testers can use. 

Similarly, with vendors, we’ve baked it into the RFP and vendor onboarding processes. We evaluate vendor solutions to make sure that they meet the accessibility standards. Wherever possible, we've tried to embed accessibility into standardized processes that stretch across the organization. Still, it can be challenging to have everyone deliver a consistently accessible experience. We’ve done our best with an education program that includes webinars, a podcast series to help people understand WCAG 2.1 (Web Content Accessibility Guidelines), events and weekly articles that help drive home the importance of delivering accessible experiences. Our goal is to explain accessibility best practices in easy-to-understand language so anyone can implement them effectively. 

AT: I love thinking up processes or improving on ones that exist, but I'd say the best way to make progress is to ensure accessibility is part of the culture, where everyone feels they are responsible to play a part in improving accessibility.

A Culture of Accessibility Begins with Employees

Diamond: It sounds like there's a focus on educating and empowering your employees to make things accessible without needing someone from your team to approve every decision they make. 

BF: That's a great way to summarize it. Wherever possible, we try to raise awareness among our employees that accessibility is part of their job, and we have some great educational programs and resources to help them get it right. It's about empowering colleagues to make the right decisions. It's a journey, and colleagues have been very open to it. 

AT: Our small team of specialists supports thousands of practitioners – designers, developers, product owners, and quality engineers. For accessibility to succeed at scale, I think it's essential that those making digital products are responsible for their own work. This approach can be applied to the output of a given role, such as a visual design of a new screen, and to the output of the team, such as a release of an app. I see my team's work to enable our colleagues to succeed in this responsibility. 

Diamond: It’s a great approach to take because in theory, if every large company was educating employees on accessibility and giving them the tools and guidance to work accessibly, over time, that creates a workforce that is educated and knowledgeable and cares about accessibility and understands that it is a part of their job. 

AT: I'd like others to think of our accessibility team as coaches, not as the designated hitters, or as pinch hitters who get the product team out of a scrape.

Diamond: Do you find that people are willing to get on board with these accessibility initiatives or do you run into hesitancy?

AT: The products my team supports have accessibility as a requirement. It's not a feature we need them to prioritize – it’s a must-have. Our role is not to coax them to get on board, it is to help them meet their requirements. I feel fortunate to work in an environment where that is the dynamic. I believe it's very useful to spend time explaining why accessibility is important, and who benefits, and I find once people understand this, they are less hesitant to act. 

Today’s Accessibility Challenges

Diamond: Are there any other major challenges you are currently facing in addition to the ones we have discussed? 

AT: For me, the biggest current challenge is measuring accessibility progress. Earlier in the journey, it might be enough to report to committees that 'there is a process in place', but I'd like to see product teams report with more meaningful metrics, and ones that can be tracked over time or against other teams. I don’t think automated scanning results give a full picture of quality of experience. As an industry, I think we need better ways to measure the PWD customer experience or sentiment.

BF: One of the big ones we have right now is PDF accessibility. It is straightforward to create an accessible document in an Office product with the built-in Accessibility Checker, but creating an accessible PDF takes a little bit of expertise. It's not as simple as saving an accessible Word doc to PDF. Some of our teams use Adobe products or third-party applications to make PDF documents – turning that output into an accessible PDF has been a big challenge. We have some solutions in place but we're still exploring other options to help make it easier for the businesses to deliver accessible PDFs. 

Diamond: Would you say the accessibility challenges you face are universal or are some of them industry- or company-specific? 

BF: I think good accessibility is pretty universal for technology. We’re simply following widely accepted industry standard best practices that apply to a very wide range of technology. The accessibility standards are well established, and everyone active in accessibility is working toward a common outcome. I don’t think there is anything about accessibility that is unique to TD or the financial industry. Good accessibility is good accessibility, no matter where you are. 

AT: The challenges our team faces are not unique to financial industry. One thing that surprised me when I joined TD was the breadth of technology. For example, I didn't expect to be working on an augmented reality app for banking. 

Formal and Informal Accessibility Strategies

Diamond: In addition to the committees we discussed earlier in the interview, does TD have any sort of Accessibility Champion Program or other kind of internal network focused on accessibility? 

BF: We’ve got a couple of different approaches. First, we have a group of people we call our Accessibility Designates, who sit on one of the working committees. Those individuals help their businesses understand TD's accessibility policies and link people to the resources that are available to help them meet the requirements. We have a person from every line of business with that responsibility.

In addition to that, we use informal recognition to commend Accessibility Champions who do a great job with accessibility in their day-to-day work. These Champions are people who take accessibility seriously – they don't just make accessibility part of their job, they knock it out of the park. These are people who go above and beyond to highlight accessibility, educate their peers, call out barriers and go out of their way to make TD truly inclusive for colleagues with disabilities. 

We actively look for people who take accessibility seriously and drive it forward in their business to recognize as Champions. We also invite them to blog about their experience on our internal social media to give them some visibility while also showing their colleagues that this is something that the Bank takes seriously. 

Diamond: You have formalized rules and processes in place to ensure accessibility is a priority. You also have these informal champions and internal initiatives. How do these two approaches work together?

AT: Informal champions become the agents of change and reinforce the culture. To encourage those champions, we invite them an annual event where they meet those who benefit most from the work they do. 

BF: The policies and procedures identify what we need to do and how we need to achieve it, but by themselves, they just look like more work. The recognition programs, education sessions and events help people understand exactly how the policies and procedures benefit real people and create new business opportunities – they get people excited about disability inclusion. 

Looking Ahead

Diamond: Switching gears a little bit. Where are you in the digital accessibility and maturity model?

AT: TD has had an accessibility program for over 15 years and aspects of the program like policy and governance are mature. In the area I support, accessibility is very much a business-as-usual activity. I would like to grow the capabilities to measure and monitor progress, as I mentioned earlier. 

TD supports the digital accessibility community by sponsoring #a11yTO, which puts on an amazing annual conference. 

BF: We also have a mature accommodation program with an Assistive Technologies Lab where we research new equipment for use by our colleagues with disabilities and accessibility standards that apply to not just our customer-facing systems, but our internal systems as well. We also actively seek out talented Persons With Disabilities to work at TD with dedicated recruiters and relationships with groups like Lime Connect and Specialisterne. TD shares our best practices widely with groups such as Disability:IN, our peers in the industry, our vendor-partners and others. 

Diamond: Outside of the model, what are some other things in the next few years that you are hoping to improve or work on at TD? 

AT: In Canada, accessibility has become a regulatory requirement for financial organizations with the Accessible Canada Act. We’re waiting to know from a technical perspective what that meanswhether it’s going to be a particular standard we have to meet. But what we know already is that regulated organizations must identify barriers that Persons With Disabilities face, and address these, as well as preventing barriers in the future. 

I think the big next step will be to create a good framework for that to happen. It could be meeting with Persons With Disabilities, whether that’s organizations or customers, and getting their feedback. This approach will need to be collaborative. The key is talking to users to find out how their experiences are now and how they might be improved. 

BF: I agree with Aidan; accessibility is a journey and we can always make improvements by listening to our colleagues and customers with disabilities. They know firsthand which things are challenging and what works well in their day-to-day experiences. We need to continually gather that feedback and leverage it to evolve our approach to accessibility to improve our products, services and systems.

Diamond: Is there anything that we didn't get to talk about that you would like to highlight? What do you hope your peers can take away from this? 

BF: I think having a strong executive sponsor is critical to get things started. But at the end of the day, if you don't have a good network of champions and people who understand and drive accessibility forward, the hard work isn't going to get done. You need people at all levels across the organization to understand how they can contribute to accessibility in their own activities, because accessibility only works when everyone contributes. It's those champions who will help spread the message and encourage their peers to participate, so it's very important to find, recognize and support those accessibility champions across the organization.

AT: I appreciate the patience that customers have shown when they have encountered barriers and how much I learn from these interactions. As much as we don't like hearing that something isn’t working how we’d like, the customer feedback is invaluable to improve the experience. 

Diamond: Thank you both for your time today, and best of luck in your future initiatives!

Accessibility in the Enterprise is a content series from Diamond that highlights the work of Accessibility leaders at large organizations. To stay up to date with this content series, follow us on Twitter at @DWSLA.