Documents are an often overlooked part of the regulation scope considering the title is websites and mobile applications. There are a few important points about documents that you should be aware of.
When you publish new documents on your website it is safe to assume that they should be made accessible as all new documents will be expected to under the regulations (unless otherwise listed as an exemption). We have a tools section that has many useful guides on creating accessible documents.
The important points of the regulations when it comes to documents are as follows:
These Regulations do not apply to the following content of a website or mobile application
of a public sector body—
- office file formats published before 23rd September 2018, unless such content is needed for active administrative processes relating to the tasks performed by the public sector body
- online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use;
- reproductions of items in heritage collections that cannot be made fully accessible for a number of reasons
- content of extranets and intranets published before 23rd September 2019, until such websites undergo a substantial revision
- content of websites and mobile applications qualifying as archives
So what does all this actually mean?
If your pre-September 2018 documents are date specific (for example they are a newsletter about events that happened on a certain date), are archived because they are old and there purely as reference material, or are not part of an active administrative process then these are not within scope of the regulations. However if someone requests one of these documents in an accessible format you still have a duty to provide them one under the Equality Act 2010.
Any documents that form part of an active administraitive process no matter their published date must be accessible come 2020. An active administrative process is normally a user attempting to complete some form of journey, for example the journey to apply for a blue badge, or to apply for a university course etc. These are often commonly some kind of form the user has to fill out or guidance material that they must read in order to be successful in the task.
Online maps and mapping services including maps within planning documents are covered within the exemptions page.
Intranet and extranet content including documents is subject to the definition of substantial revision and more on that subject can be found on the Intranets and VLEs page.
Finally documents considered historical do not have to be made accessible if in doing so impacts on the preservation or authenticity of the reproduction, or if it would be to costly and technically complex to extract text of manuscripts or other items of heritage collections and transform it into digital content that is accessible.
One of the other things you should consider is how your organisation provides FOI responses. These are often added to the website as part of an FOI log. publishing scanned PDF versions of hand redacted email contents or other information is not accessible and forms part of an administrative process. You should be thinking about adjusting FOI responses to always be delivered in an accessible format.