How to comply with new Digital Accessibility Regulations: Your questions answered

The 23rd of September 2019 marked the first milestone of the Public Sector Bodies Accessibility Regulations, which applies to websites published or substantially revised after the 23rd of September 2018. Our free webinar took place just three days after the first deadline and provided an update on 'Complying with the new Public Sector Accessibility Regulations' in month 1.

This webinar was part of our bi-monthly series of updates on how the regulations are being implemented by universities and other HE (higher education) institutions. As well as providing regular updates to give the latest news and advice relating to the regulations we discussed the ‘business case’ for compliance and what disabled students should be able to expect from their education provider.

On the live webinar there were lots of great questions asked and conversations happening between attendees and our presenters Abi James of AbilityNet and Alistair McNaught of McNaught Consultancy. This blog provides a summary of those conversations with further commentary. Our presenters also answer questions asked on the webinar and respond to attendee comments. The recording from the webinar is also included below for reference:

What is in scope?

There were several questions along the lines of “which digital platforms are in scope?”. Many assumed only student facing platforms were in scope but the legislation makes no such distinction. Disabled staff working in the public sector should have as much right to accessible content and systems as the people they serve. From a strategic perspective, prioritising improvements on a limited budget, there may be less risk in tackling password protected staff systems later in your road map but there is no indication that they are exempt.

Do we need course-level accessibility statements?

Alistair's part of the presentation focused on how we provide the right level of information to all users. He suggested accessibility information could be ‘nested’. An overarching VLE (Virtual Learning Environment) statement could be accompanied by more granular statements at subject level reflecting the different accessibility profiles of subject specific content. Some universities have already started planning this approach but some participants felt it was unrealistic. Three key questions/comments arose from the audience and are responded to below:

• Question: Are we expected to audit the entire site in order to be able to say which areas / things we're not accessible on?

Answer: Given the size of most HE and FE (further education) web and VLE estate, it is unrealistic to audit every piece of content or every interactivity. However, since courses are designed by people who have particular preferences and ways of working, it is relatively straight forward to identify likely benefits or barriers without sampling every piece of content they created. This does however imply that staff have enough accessibility awareness to be able to reflect on their personal practices (or resource/reading list choices) and communicate strengths/weaknesses to disabled users.

• Comment: The conversations we've previously had with GDS (Government Digital Service), AbilityNet and others have suggested that a single VLE statement was suitable, but Alistair is suggesting separate statements for every module are necessary. That's a very different situation and a lot more work expected on our academics if that's what has to be done.

Response: The issue here is fitness for purpose. Where it is possible to provide a single overarching VLE-level accessibility statement with useful and relevant information for all users then a “top level” statement would fit the bill. The evidence collected from VLE accessibility audits across the sector suggests that the variation in accessibility issues between courses is likely to require course level summaries – at least for some courses. Furthermore, sustainable accessibility is only possible if those creating and delivering courses know what issues exist and are actively engaged in attempting to improve them. The biggest challenge is not describing how accessible you are but having the training to create accessible content.

• Question: Does anyone know of an institution where academic staff have been given extra time (at the expense of other duties) to make content accessible - rather than having it as an additional responsibility?

Answer: We don’t (although that doesn’t mean it hasn’t happened). This is a serious issue though and organisations that don’t stem the inflow of inaccessible content are simply accumulating technical debt that will need to be resolved sooner or later.

Tools and approaches

A couple of questions and comments explored ways of helping content creators to be more accessible from the start. One of the respondents has been creating templates to help content creators and was asking about the best colour background for PowerPoint presentations. There is not a universal contrast level that suits all users – a dyslexic reader may prefer pastel backgrounds with low contrast but a visually impaired person might prefer high contrast. Corporate brand colours will also come into the mix. Good advice is to (i) choose an off-white/pastel background but (ii) test the background/foreground/text contrasts all meet or exceed the 4.5:1 contrast ratio required by the regulations. A tool like the Paciello group’s colour contrast analyser can be useful or use a ‘compliant contrast' colour swatch builder. Sometimes a slight tweak to your branding colours on the web can make a big difference to compliance.

There was a question about automated accessibility checkers and which tools content creators might use. This depends on the medium you’re working in but all current Office products have a built in accessibility checking features. Many different tools exist for websites and many can sit in the developer’s browser. The Lighthouse tool in Google Chrome is already built in but plugins also exist like the Wave tool and others which link to freemium services such as SiteImprove. 

Final thoughts

During the session there were a couple of reminders that this is not about “what can we do to minimise effort for our organisation” because inaccessible content simply transfers the burden of effort to the disabled user. The legislation is designed to shake up 24 years of digital complacency (the Disability Discrimination Act became law in 1995) and give disabled users what they have been entitled to for a generation.

Another respondent commented that “Adding an accessibility statement to the website is not enough for visually impaired student… when will the backlist content be remediated? Will visually impaired students have to wait for another year or so until all the books are accessible?”. The answer will vary from institution to institution but the onus is on the organisation to provide accessible content. If the mainstream content isn’t accessible an Alternative Format service needs to be in place. Ultimately, it is more cost effective and sustainable to create (or procure) accessible content for all.

The challenge is getting institutional buy-in driven from the top so that this just becomes a normal way of working – a way of working that improves independence, personalisation and productivity for everyone.

More information

The recording of our September webinar on the new HE Accessibility Regulations is available on our website. It is part of a series of free webinars this year where we've shared information and advice about the new regulations:

• Watch the recording of our May webinar on the new HE Accessibility Regulations
• Watch the recording of our July webinar on the new HE Accessibility Regulations

Do you want to be notified of upcoming webinars? Join our mailing list to be kept up-to-date and receive details of our November webinar when the topic is announced.

We are pleased to announce AbilityNet is partnering with McNaught Consultancy, featuring Alistair McNaught previously of Jisc, to provide Digital Accessibility Services in HE and FE.

TechShare Pro 2019 is the UK's leading accessibility and inclusive design event. A session on the new UK regulations for public sector and HE has been confirmed.

Abi James recently ran a series of HE Web Accessibility workshops on topics such as 'Developing and maintaining an accessibility statement for HE' and 'Understanding accessibility evaluations and testing results'. The recordings from our HE Web Accessibility Training Programme are now available.