If you pay for them then they come under the legislation so will be subject to the accessibility requirements and will need to have an accessibility statement covering them explaining the extent to which they meet those requirements. Only third party content over which you have no control (and you don’t fund/pay for) is exempt – eg use of free tools etc.
We think the best course of action is to be asking the suppliers of any product you pay for to provide a compliant accessibility statement that you can point towards.
The four minimal requirements in an accessibility statement are:
(a) an explanation of those parts of the content that are not accessible and the reasons why; – The vendor should provide details on this, ideally to include what testing they’ve done so you can be confident about their assertions. It is also a positive good practice to say what accessibility HAS been built in – it’s easy for users to not realise that they can benefit from the flexibility and personalisation provided by a well-designed tool.
(b) where appropriate, a description of any accessible alternatives provided; – This is context-dependent. Some tools might have alternative ways/views that provide more accessible experiences. If not you’d need to have some appropriate guidance in your own accessibility statement info – eg “We use tool X for parts of the course. It can create problems for screenreader users so please talk to your tutor about alternative ways we can help you access these activities”.
The other 2 parts (c & d below) are not really relevant at the scale of a single tool and wouldn’t be likely to be on the accessibility statement from the vendor (not least because they are NOT public bodies) but I think these could be easily covered by any course-level accessibility statement for the relevant modules
Contact – a description of, and a link to, a contact form which enables a person to—
(i) notify the public sector body of any failure of its website or mobile application to comply with the accessibility requirement; and
(ii) request details of the information excluded under regulation 4(2) and regulation 7(4); and
(d) a link to the enforcement procedure set out in Part 5 of these Regulations to which recourse may be had in the event of an unsatisfactory response to the notification or the request.
Crowdsourcing third party statements project
This project started in the Accessibility Community Microsoft Teams space (here is the link to join the community of practice) and has been supported by a number of members from the FEHE Digital Accessibility Working Group (DAWG). The group has been looking at the easiest and most sustainable way to take the project forward, at no cost to users.
The project seeks to crowdsource a list of all platforms that we are aware of as a sector in order to create a central repository of accessibility statements that we can all signpost to.
We are hopeful that this will encourage suppliers to create compliant statements in a consistent and standardised way and improve the overall accessibility of platforms so that they are as compliant as the Public Sector Bodies (PSBs) they are supplying to. As a sector, we will also have a very useful procurement list to help us compare accessibility apples with apples.
What do we mean by platform?
We are interested in all the platforms that we use in the public sector, so, if you are a public sector body and you pay for a service/platform please add it to the list.
The following is a list of category types we think offer a good guide to scope that such platforms cover:
- Accommodation and/or conferencing event systems
- Attendance Monitoring
- Business Intelligence
- Content Management System
- CRM – Alumni
- CRM – General
- CRM – Internal Communications
- CRM – Marketing
- CRM – Research and Enterprise
- CRM – Student Recruitment
- Current Research Information System (CRIS)
- Curriculum Management (Programme Planning)
- Data Warehouse
- Ebook Platform
- Electronic Document Management & Records Management System (EDRMS)
- Enterprise Service Bus (ESB)
- Enterprise Web & Staff/Student Portals
- IT Service Management Systems (Service Desk)
- Learning Analytics
- Research Proposals, Grants and Contracts
- Student Engagement
- Student Evaluation of Teaching Software
- Student Records
Where are we going to store the statements?
The incredibly committed Huw Alexander from searchBOX has kindly agreed to host the statements (which is great as Huw also hosts the eBook accessibility statements under the ASPIRE banner so all of this kind of content will be in one place).
What do we need people to do?
- Sign up for free to searchBOX.
- Check searchBOX Third Party Statements list to see if a platform has already been added.
- If the platform is not already on the Third Party Statements list please add the platform information using the searchBOX submission form:
Please add as much information as you can for each platform e.g. including a link to any existing accessibility statements where known.
- If the platform is already on the list:
Please check any information we already have for completeness and add any extra information available to complete the record e.g. adding a link to an accessibility statement. You can submit any updates via the searchBOX submission form or you can email firstname.lastname@example.org. We will then check any new information and update the central list.
If there is already a link to an existing statement please indicate how helpful you think the statement is using the like/dislike functions:
- Encourage suppliers with missing or non-compliant statements for their platforms to complete the Third party Supplier Accessibility Statement template.
- Submit the updated compliant statement link to searchBOX.
If you already have a list of suppliers we are very happy for you to submit them directly to email@example.com rather than adding each one individually via the submission form. We are keen to get as much information on the site as possible in order that we can all refine it together as we go forwards, so please use whatever method you prefer.
Draft third party supplier statement
We decided to use a revised version of the statement with all of the sections that are not legally required for suppliers toned down. All of the key sections to inform public sector body (PSB) compliance are retained but we felt that it was better to make it as easy as possible for suppliers to complete – particularly as they are not legally required to be compliant as part of the private sector. This is important as the information PSBs really need from suppliers is the technical information about the accessibility performance of the platform and we were keen to focus on this rather than add extras that may hold up the delivery of useful statements by supplier’s legal teams.
A comprehensive statement is a joint effort between a public sector body and a supplier. A public sector body has the responsibility to provide the legislative content of the statement, such as standardised wording regarding compliance, preparation and enforcement, while the supplier is best placed to provide practical accessibility and technical information for the statement such as known issues, reasonable adjustments and support materials.
The selection of information included into the searchBOX template is a reduction of the GDS sample statement in that it focuses on information that is best provided by suppliers. In previous conversations we have had with suppliers about the provision of statements, they are not keen to deliver documentation that points to the PSBAR enforcement processes etc. because not only are they not legally required to do so but suppliers linking to an enforcement process they are not responsible under would also be misleading. For example you could not report a supplier directly for non compliance as it must be associated with the provision of a service through a public sector body.
For those reasons, the searchBOX template is shorter, encouraging suppliers to complete it, while removing non-applicable sections that cause suppliers to be more concerned / less willing to complete a document.
We are hoping that adding to the searchBOX database links to suppliers and their current statements (whether fully complete or otherwise) will encourage a competitive edge where suppliers can be compared with their rivals and incentivised to recognise accessibility as critical for commercial advantage.