Accessibility statements webinar: your questions answered

On last week's higher education and public sector focused webinar we discussed accessibility statements and what they need to contain, in time to meet the requirements of the Public Sector Bodies Accessibility Regulations (PSBAR) deadline of 23 September 2020.

Are your accessibility statements ready?

We asked attendees at the start of the webinar: How confident are you that your accessibility statement is compliant? The majority of respondents said they were not too confident about their statement's compliance.

• Very confident: 5%
• Quite confident: 36%
• Not too confident: 47%
• Concerned: 12%

To address the uncertainty from those in the public sector about whether their accessibility statements will comply, during the webinar AbilityNet's James Baverstock discussed the key things your higher education and further education (HE/FE) accessibility statement needs to contain.

Alistair McNaught of McNaught Consulting outlined what HE and FE sectors should consider beyond their main website's accessibility statement - including virtual learning environments (VLEs) and library resources.

George Rhodes of All Able, and Nick Jarvis Smith of the Department for Education shared his research into the prevalence and effectiveness of public sector accessibility statements in the UK and beyond. 

Your accessibility statement questions answered

AbilityNet's webinars offer an opportunity for attendees to pose questions to the expert panellists. This webinar generated lots of questions about compliance and accessibility statements which we weren't able to answer all of during the live session.

So, the panel members have offered their responses to the remaining queries from the webinar Q&A section below:

Do you have a sense of how many statements that orgs typically have?

Alistair: Depends on definition of a statement - typically 20 – 30 platforms - but if course level accessibility information is included it could be hundreds. Likewise, when referencing 3rd party journals and so on, it could be hundreds, but often these will be very “compact” referencing 3rd party statements and Voluntary Product Accessibility Templates (VPAT) and so on. 

Should the accessibility statement cover not only the public-facing part of your university website, but also the virtual learning environment (VLE) (which only logged-in users will see)? If so, should individual PDFs for examples be highlighted as a possible problem? 

Alistair: There’s a balance between being “actionable” and “feasible” so it is probably not feasible to highlight every PDF that might be a problem, but it may well be feasible to recognise that PDFs from a particular journal have no navigation or won't reflow effectively. That way you can give the user actionable advice without overwhelming them with individual minutiae.

As it has been mentioned content available from a VLE often covers a number of third party sites that are used (for example, Zoom). Would you recommend having separate statements for them or including them within the VLE statement?

Alistair: There is value in keeping all accessibility statements manageable in size. So where several courses make use of a particular tool like Zoom, it would be sensible to have a central "Zoom statement," which can be linked to from individual courses as a single line.

Do we need a statement for each third party resource (and if so, where do we put them) we have or can we have a blanket one?

Alistair: Unless all 3rd party resources have identical accessibility profiles, they will need a separate statement, but wherever the 3rd party resource has an existing good quality accessibility statement of its own you should be able to link to it to cover the basics of what works/what doesn't work. You can then supplement with a couple of links to your own local guidance on support/complaints/escalation and so on, which should be available as stand-alone information reference from multiple accessibility statements.

Who is responsible for accessibility of embedded web services, for example, YouTube videos or Google Maps? Is it us as an institution or the provider - can we say “we can’t fix” as we're using as a service?

Alistair: You are not responsible for 3rd party content that you do not have control over or fund, so these would be mentioned in the accessibility statement as content that is not accessible but is exempt for the reasons given.

Isn’t there a difference between courses and public-facing websites in that we usually know most of the needs that would be reflected by WCAG in the students? Particularly screen reader users will always be known, so would having a course-level statement be too much to ask of content authors?

Alistair: The whole point of the legislation is to shift the burden of responsibility away from the disabled person. If the disabled student has to discover the accessibility of course materials by trial and error and then request alternative formats where needed then they are needlessly burdened. It is the responsibility of those creating digital content to do so in an accessible and barrier-free way. Once organisational culture change takes place, and content is accessible by design and practice, you don't even need to know which of your students has a disability because they will be able to access the content independently.

I'm confused about third party suppliers. For example, take our library catalogue - do we need to add an accessibility statement to our catalogue? And would we include information about all the ebook/ejournal providers' accessibility from there?

Alistair: Yes, there would need to be an accessibility statement for the library catalogue. Ideally, your supplier will already have the information available for you that you can link to, but local information (like who to contact in case of difficulty, how to escalate an accessibility complaint and so on) also needs to be available so it's not quite as simple as linking to their accessibility statement. You will also need to link to internal processes and support.

Do you know when the WCAG 2.2 will be published?

James replied: The final version of WCAG 2.2 is planned for November 2020 according to W3.org. The First Public Working Draft was published in February.

Alistair said: "most" functions are keyboard accessible = compliant. Does this mean the accessibility statement itself is compliant? Is there an additional requirement, from the PSBAR or other regulation, that the website actually meet WCAG 2.1?

James: To answer “Is there an additional requirement, from the PSBAR or other regulation, that the website actually meet WCAG 2.1?” - yes, PSBAR requires websites to meet the WCAG 2.1 AA accessibility standard.

Alistair: The comment was not that “most functions being keyboard accessible equals compliance with WCG2.1,” but that we assume the sample statement the Government Digital Service (GDS) provides is "compliant" (otherwise why would they provide it?). If that is the case, the sample statement contains the line "most functions are keyboard accessible”. This implies that you have a compliant, “passable” accessibility statement using vague terms like “most functions”. My argument is that - on that basis - compliance is not a “mature” statement. Maturity needs to provide positive benefits for end users. Knowing that "most functions are keyboard accessible” provides no positive benefits for the end user because the lack of specific detail means the user still has to work by trial and error to find out which functions work and which ones don't. I would therefore regard the GDS sample statement as compliant (telling people the minimum about accessibility pros and cons) but not mature (giving action or formative information).

The person who's written our statement has said live video isn't complaint and wont be as is exempt. On GDS primer and WCAG2.1 AA it says live video needs captions, but Gov.uk says "your team does not need to fix the following types of content because they’re exempt from the accessibility regulations:
    ◦    pre-recorded audio and video published before 23 September 2020
    ◦    live audio and video."

Nick’s response: Stick to GDS guidance. WCAG is the standard we aim for, but GDS are monitoring services so I would go with its interpretation of the guidelines and regulations although live captioning would be great and improve user experience substantially.

Did you test websites using Dragon as this can have separate issues to screen readers?

Nick’s response: We only tested using a screen reader for our initial testing. We hope to complete more comprehensive testing in the future where we will try using other assistive technology software.

Watch the webinar recording

You can watch the webinar playback below, and you can download a transcript and slidedeck from the webinar recording information page.

Further resources:

• Blog: Countdown to public sector deadline: How prepared are you?
• Blog: George Rhodes - How well do supermarkets and transport providers deliver accessibility support?
• Unsure where to start with digital accessibility? Speak to our experts for help.

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