Accessibility regulations for public sector bodies came into force on September 23rd 2018. These new regulations, known officially as The Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018 build on existing obligations to people who have a disability under the Equality Act 2010 (or the Disability Discrimination Act 1995 in Northern Ireland). These regulations state that all UK service providers must consider ‘reasonable adjustments’ for disabled people.
At first glance, these new regulations seem quite daunting. We’ve put together this simple guide that you can follow step by step.
When Do Parish Councils Need To Comply With The Accessibility Regulations?
First things first, let’s establish how long you have to comply. Was your website published before or after 23rd September 2018?
If it was published before 23rd September 2018 then you have until 23rd September 2020 to become compliant. If your website was published after 23rd September 2018 then you have until 23rd September 2019 to be compliant and publish an accessibility statement. You will need to review and update your accessibility statement regularly.
Does A Parish Council Website Need An Accessibility Audit?
Before we get into the nitty gritty of compliance it’s worth pointing something out here. As approved Jisc registrars of gov.uk domain names we’ve noticed of late that things have changed whenever we apply for a new .gov domain. One notable change is that we are sent an email that we must forward to the clerk, this includes a link to the Gov.UK service manual and more importantly a link to this page about making your service accessible.
Whilst the content of this page is self explanatory and in line with the regulations that this article discusses, one point in particular caused some alarm and that was this paragraph –
If you’re working on a GOV.UK service (that’s a service published on a .service.gov.uk subdomain), you must get an audit before your service moves into public beta.
The guide then goes on to suggest that an audit should typically cost between £3000 and £7000. As suppliers of websites to many Parish Councils we realise that this figure is untenable for many smaller authorities. After much research we found that many clerks had sought clarity on this point on the Government Digital Service Website. In performing this research we found some clarity from Joshue O’Connor, Interim head of accessibility at the Government Digital Service who, in response to a complaint from a Clerk said:
These are excellent points. We are aware that these cases do represent a vast part of the cohort. While we are talking about legal requirements for accessibility, it needs to be said that people in smaller organisations can only reasonably be expected to do their best.
IMO, if this is the case and they still fall short they shouldn’t be unnecessarily penalised, as the purpose of this whole accessibility ‘thing’ is to reduce barriers and increase inclusion – not develop a punitive culture of compliance.
This suggests that some further clarification will be coming in the future but for now, it would be safe to assume that smaller authorities shouldn’t have the burden of an external audit and that an internal audit by the clerk or the person responsible for the website should suffice when done in conjunction with the other points regarding accessibility compliance.
Top Tip! – Whilst a .Gov domain looks official, it isn’t a requirement for a Parish Council. It may be worth considering a .org.uk domain. Your website will still need to comply to the same regulations but clearly won’t require an audit.
How Can A Parish Council Website Comply With The Accessibility Regulations?
If you’ve already done some reading on the Accessibility Regulations then you perhaps feel a little overwhelmed. Thankfully however, chances are, technology is on your side. If your website was created and updated regularly over the past few years then it’s entirely possible that you’re half way to compliance already. Our websites (from 2018) are compliant out of the box, the only way in which one of our websites can be non compliant is if the person responsible for adding content uploads something or changes something such as the text colours etc that creates a non compliance issue. We’ll cover this further down the page.
Why Does My Council Have To Comply?
The new regulations need the website to comply to WCAG 2.1 AA. These standards range from A to AAA. In order to comply however, the website needs to achieve at least AA standard. Let’s take a look at these in summary form.
The regulations exist so that everybody can access the content of a website regardless of any impairments the user may have such as:
- vision – severely sight impaired (blind), sight impaired (partially sighted) or colour blind people
- hearing – people who are deaf or hard of hearing
- mobility – those who find it difficult to use a mouse or keyboard
- thinking and understanding – people with dyslexia, autism or learning difficulties
When we think of these impairments, we then start to think how they may affect how people interact with a website. This may include the ability to:
- use a keyboard instead of a mouse
- change browser settings to make content easier to read
- use a screen reader to ‘read’ (speak) content out loud
- use a screen magnifier to enlarge part or all of a screen
- use voice commands to navigate a website
A modern website such as ours is already compliant out of the box in so far as it allows interaction with assistive technologies such as screen readers. Now we know the basics of what the regulations require, let’s break down the steps needed to achieve compliance.
A Simple Guide To Compliance
Provide Alt text
This means providing text for none text items such as an image. You can imagine that text readers struggle when it comes to an image unless an alternative text description is provided. When uploading an image to our website you’ll be presented with an alt image box. You can insert a short description in here. For example, when uploading an image of a councillor you can simply insert the alt text “photo of councillor John Doe”. When a text reader comes across the image it will state “Image – Photo of Councillor John Doe”. This enables the person with a visual impairment to know what images are on the webpage.
Transcripts For Audio / Video
Any future videos or audio files need to include a text transcript to replace the audio.
Provide Captions For Video
Captions for video help those with audio impairments.
Content To Be Structured Logically and Accessed By A Screen Reader
Most modern websites have this capability out of the box. It’s only by ensuring that those who update the website maintain this compliance by not uploading images of text. For example, taking a scan of a poster advertising a garden fete and posting it as a notice on the website without a full text transcript would render the site non compliant as text readers can’t read the text on an image. This also means that any embedded third party content, such as a feed from your Facebook page also needs to comply or be mentioned in your accessibility statement. We’ve written a separate article about partial compliance here.
Colour Not To Be Used As A Description or Indentifier
For example, an instruction to click on the blue button would exclude those who cannot distinguish between colours.
Use Text Colours That Show Up Against The Background
Thankfully, gone are the days when we used to see yellow text on dark green backgrounds. Using a black text on a white background is one of the best contrasts.
Ensure Text Can Be Resized
Whilst you don’t need to provide this feature (as most browsers provide the function) you need to make sure every feature can be used when text size is increased by 200% and that content reflows to a single column when it’s increased by 400%
Make Sure That Your Website Is Responsive
Again, any modern website should be able to resize it’s content automatically depending on screen size or based on page orientation and font size that a user prefers.
Compatible With Assistive Technologies
A website must work well with assistive technologies – for example, important messages are marked up in a way that the screen readers knows they’re important. Yet again, a modern website such as the ones that we supply will already be compliant in this respect.
Putting It All Together
So as we’ve seen, a large part of becoming compliant lies with the technology that the website is built on. Our Parish Council Websites are already compliant out of the box. The only concern that you must have once the website is up and running is that you must be mindful of providing text alternatives for things like images and videos. It’s therefore crucial that whoever is responsible for uploading and creating content on your website is trained and educated in what is and isn’t acceptable in order to maintain compliance.
It’s worth noting that some technologies such as maps are still not compliant with certain parts of the regulations. It’s difficult for text readers to understand an embedded map so wherever possible you can include a title and an alternative method of conveying the information that the map provides. If you have such elements on your website then it’s important to include these in your accessibility statement which we’ll cover in a moment.
Compliant websites must be able to work with certain assistive technologies. The Government Digital Service suggests that testing is done using the following technology.
- JAWS -Screen Reader – Internet Explorer 11
- ZoomText – Screen Magnifier – Internet Explorer 11
- Dragon Naturally Speaking – Speech Recognition – Internet Explorer 11
- NVDA – Screen Reader – Firefox (Latest Versions)
- VoiceOver – Screen Reader – Safari iOS10 and OSX onwards
Of course this list isn’t exclusive but covers the most common technology. Additionally, you may want to provide your own online tools that enable the user to increase font size and contrast easily. This isn’t a requirement but it can be a good idea if you want to go to these lengths. We’re happy to advise on this on a case by case basis.
Writing An Accessibility Statement
Once you’ve tested and self audited your website you can then move on to publishing an accessibility statement. This again isn’t as daunting as you may think, It’s a simply format that gives the user a brief summary on the parts of the regulations that you comply with and if there are any parts that you don’t, for instance a map, then you can provide a method of contact to further help the user. Rather than reinvent the wheel, we’ve provided a link to the government guidelines and example accessibility statement published by the GDS. You’re also free to use our accessibility statement from our demo website. Remember to change the email address and telephone number to yours.
Common Reasons For Non Compliance
We stress to all our clients that although we create fully compliant websites, it’s important for the person who adds content to be aware of the requirements and how simple it is for a compliant website to become non compliant. We’ve listed the most common simple things to remember or avoid.
The GDS recommend that wherever possible, content should be created as HTML instead of using a PDF. See this link to read the article. This sounds more complex than it actually is. HTML (Hypertext Markup Language) simply means publishing a webpage. Let’s take minutes as an example. Typically, these are typed up by the Clerk and published as a PDF and then uploaded to the website. This is familiar to most clerks. It’s really simple however to either copy the text from the document and paste it into a webpage, instantly you now have HTML. Our most recent website theme, NetWise V2 allows for both a PDF document upload and HTML.
One thing to definitely avoid when uploading documents is to upload an image such as a jpg or png file. We see this often when Councils upload something like an external audit. This is an instant failure in regards to accessibility as text readers cannot read text on an image. A simple test is to try to highlight some of the text with your mouse as if you were copying it. If you can’t highlight it then a text reader can’t read it.
We test all our websites via Wave and Google Lighthouse as soon as we hand them over to the Council. One of the main checks are for contrast errors. The most simple way of avoiding a contrast error is to keep your colour scheme simple and high contrast. Black text on a white background being the most ideal. If you are changing your menu colour then again, keep high contrast in mind. A dark blue menu with green text for instance will be non compliant. Dark blue with white text on the other hand should pass a contrast check. The same goes for buttons etc.
All images need an alt text. As explained above, the alt text can be read by a text reader and gives some context to the content of the image that can be relayed to the website visitor. Forgetting to provide alt text is a common error but will result in your website being non compliant. So remember, as you add an image to a page or a gallery then on the image edit screen, always add your alt text.
In particular pay attention when posting images of flyers or notice board images. If they aren’t in a PDF format then text readers can’t access them and they are therefore non compliant. We see quite often Councils posting images of events that are happening locally and although these have traditionally looked good, they instantly make your website non compliant with WCAG2.1aa. See the image below, try and select the text on it with your mouse, if you can’t select the text then neither can a text reader. If you want to use an image such as this then it’s important that you also provide a text transcript and add alt text (alternative text) to the image as you upload it explaining what it is and that a text transcript has been provided. If you provide the transcript and the alt text then you will remain compliant. We cover this in more depth in this article, we’d advise anyone who is responsible for uploading content to your website to give it a read.
Typography, or text should again follow the same guidelines as colours in so far as less is more. Easy to read fonts should be used with minimum decoration such as colour, italics etc. Headings should be logical and not used for aesthetics. Keyboard navigation uses heading tags as a way to logically navigate a page. If you use heading 2 tags followed by heading 4 tags and then back to heading 2 tags then a visitor who relies on keyboard navigation will have an unpleasant experience on your website.
Sometimes it’s necessary to add third party plugins so that you can add extra functionality to your website. In time we expect that most plugins will ensure that they display their content in a way that is WCAG2.1aa compliant but in the meantime it’s important to understand that some may cause an issue. The regulations allow for such content as long as it’s mentioned in your accessibility statement and you only claim partial compliance as a result. Typical third party content might include social media feeds, maps etc.
It’s perhaps best to weigh up the pros and cons, is your third party content absolutely crucial to your website and does it’s inclusion outweigh the advantage of claiming 100% compliance? Very often we see requests from Councils for visitor counters and all manner of gadgets. Such features were popular in the late 1990s and don’t really have a place on a modern accessible website. Careful consideration should be given before adding such features.
Up until quite recently, most of our Parish, Town and Community Council websites had a feed from their Facebook page or group that displayed somewhere on the website. On the introduction of the regulations, clerks became bombarded with literature that although published with the best intentions, served to almost scare councils into taking drastic action. Prior to us launching our NetWise V2 theme, which incidentally was conceived in part due to the introduction of these regulations, we’d often get requests asking for proof of compliance.
In order to achieve that elusive 100% compliance we’d run the website in question through online tests on platforms such as Wave and Google Lighthouse. We’d need to ensure that there was sufficient contrast on text, that each image had meaningful alt text and a host of other technical adjustments. One thing we’d almost always have to do however is to remove Facebook feeds. This was often due to images that were pulled through from the feed that didn’t contain alt text. Each image would flag as an error, very often resulting in less than 70% compliance.
Social media allow you to now add alt text to your images but very often these social media pages are administered by local groups with multiple page admins that possess varying degrees of IT ability. We published an article about this topic recently, you can read more about third party content here.
Complying with the Public Sector Bodies Accessibility Regulations 2018 isn’t as daunting as it may first seem. The take away points from this article are
- Our websites are compliant out of the box
- Non compliance can be caused by creating content that doesn’t have text alternatives for images, videos and audio files. In addition, third party content, such as maps, social media feeds etc may also mean that you have to decide between partial or full compliance.
- Keep the regulations in mind when considering new features or content. Very often, less is more when it comes to aesthetic features such as sliders and animations as they often aren’t easily read or interpreted by assistive technologies.
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