There are tight deadlines to meet the Public Sector Bodies (Website and Mobile Applications) Accessibility Regulations 2018, but making your services accessible is not a project to be started and finished. Building and maintaining accessible services is an ever evolving journey. You should look at how you approach accessibility and try to ensure that the changes you are making support a long term change that will mainstream accessibility as part of your standard processes.
Setting up your own groups
If you are leading on digital accessibility for your organisation you will have many groups that you need to engage with both internally and externally to help you deliver accessible services by the legislative deadlines under the new regulations. Public sector organisations may therefore need to develop or modify policies and create new workflows on:
- Procurement of online systems/interfaces
- Captioning/transcription of media content
- Teaching content
- Complaints, escalation and take-down/take-action policies
Firstly you should consider Internal organisation working groups. For example The Kent Digital Accessibility Working Group (KDAWG) is a group made up of multiple departments within the University of Kent, who are working to agree an approach to accessibility that is consistent across the University. This group has members from; student support and wellbeing, copyright / legal, IT/digital/web development, learning resources, the student union, procurement and more.
This has been a very effective way of engaging those who have actions to take to support the digital accessibility agenda and getting expert feed in from a range of different viewpoints to help temper the approach into something that meets the requirements of all interested stakeholders.
You should also consider opening discussions with external organisations, such as other local organisations within your sector and beyond. In Kent they have brought together representatives from Local Authorities, Blue Lights Services, Health and Higher / Further Education to discuss a county wide approach to digital accessibility. This has resulted in knowledge sharing that would not have been possible if they weren’t willing to discuss their challenges and possible solutions with others.
You can go beyond this local discussion and begin to engage with wider national groups, mailing lists and channels that open up a greater pool of learning for you to make use of.
Engaging Higher Management
Often staff at middle levels of an organisation are given responsibility for the digital accessibility agenda without having the power, authority or budgets to make the necessary changes. There is a Jisc article about taking responsibility without the authority which highlights how this can be a fast route to failure and why senior engagement is essential.
When discussing digital accessibility with management, it is often required to highlight the organisational risks, legal pressures etc., alongside the human aspects of accessibility to ensure that you get buy in and support.
To encourage management to take accessibility seriously they recommend you cover the following points:
- What are the regulations – supportive of the existing Equality Act, went live 2018, what the regulations cover ie. public sector websites, but should be considering all digital systems.
- Timeline – when the major dates are and what is going to happen. Stress that the 2020 deadline compared to your existing web estate leaves little time to rectify all issues before then.
- Organisational Risks – detail exactly why as the risk holders for the organisation, your management should be supporting improvements to accessibility and what the consequences of not doing can be.
- GDS / EHRC Compliance – The first main risk is if your organisation comes under scrutiny by GDS and the EHRC. If you fail to demonstrate adequate documentation or progress of your accessibility journey they may impose further specific remedial actions on you, or could begin the process of an unlimited damages fine in the same manner as the Equality Act. (NOTE: Remember that with WCAG compliance now defined as the standard of reasonable adjustment in the 2018 regulations, it can be an open and shut case of demonstrating your organisations failure to make reasonable adjustments, which is the punishable offence.)
- Secondary Challenge – In addition to the risk of assessment by the monitoring and enforcement bodies, there is a risk termed “Secondary Challenge”, meaning challenges by members of the public through FOI or other means. This is of equal if not greater concern to GDS assessment, because from September 2019, it will be extremely easy for any member of the public to request your accessibility statement, info on your auditing process, the results of audits undertaken so far, and your remedial action plans. If you cannot demonstrate WCAG compliance or the supporting documentation mentioned to demonstrate that you are actively resolving the problems, you again sit at risk of a user submitting an Equality Act challenge with unlimited damages, with clear documentation detailing your failure to meet reasonable adjustments.
- Internal Challenge – There is a further risk of increased internal equality act challenges from staff. As accessibility becomes a more mainstream topic and staff become skilled in delivery accessible services, there may be more equality act challenges about internal systems that are not accessible.
- What actions need to be taken – Detail what broad steps need to be taken to reduce the risk to the organisation and meet compliance requirements.
- Accessibility Statement – Must be published by September 2019 and cover information detailed in the Accessibility Statement article.
- Changes to procurement – Immediately make changes to procurement guidance to ensure that all future digital systems are procured with accessibility written into the contract and tested. More information in the Accessibility and procurement article.
- Identify existing web estate – Undertake a review of your existing web estate to identify the scale of the work required before the September 2020 deadline for all existing websites. With this information prioritise your highest risk sites.
- Auditing and remedial action – Start auditing your websites and begin remedial actions to improve accessibility. Document thoroughly to defend challenges.
- What you need from management to mitigate these risks?
- Additional funding – Do you and your service owners have the funds available to cover staff time and resources for auditing, and costs for remedial action?
- Increased resource – Do you need to hire additional expertise?
- Endorsement to make significant changes – Do you need your management to invest you with the power to make these changes?
You can find the information above in presentation format ready for discussing with Management in the Engaging Management in Digital Accessibility Presentation.