Accessible Procurement: your questions answered

At AbilityNet we are committed to providing information and support to higher education (HE) institutions and public sector organisations that are impacted by UK digital accessibility regulations. On a recent webinar Procurement: Checking external products are accessible, Abi James of AbilityNet was joined by Claire Gibbons from Leeds Trinity University, who shared how her institution has been tackling accessible procurement.

Plenty of questions came through from attendees. We did our best to answer as many questions as possible, but the ones we were unable to cover in the time available on the live webinar are typed below.

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Did you miss the webinar?

Access the recording below, and download the webinar transcript and slidedeck from our website.

Image of Abi JamesQuestions posed to Abi James

Does the complexity of text, like the length of a sentence and words used, affect accessibility? Can you recommend a tool that addresses complicated or 'hard to comprehend' text content? 

Although Readability isn’t part of the accessibility standards required by the Public Sector regulations (as it is only tested at AAA level under the Web Content Accessibility Guidelines) it can have a big impact on the usability and accessibility of your site for many users. The UK Government has done a lot of research on how to write well for websites and the Readability Guidelines provides evidence-based guidance on good content design. Its Readability Questions are a useful primer for making sure content is readable. If you're looking for a tool to check reading age then many people use the Hemingway App or readability tools such as those built into Microsoft Word.

Do the Public Sector Bodies Accessibility Regulations apply to free third-party websites? When using online databases like Ebsco - would it be our responsibility to ensure that externally provided third-party content on our website is accessible at the procurement stage? 

The regulations apply to any content that is under your control. This generally means any tools that you have paid for, have specified or can customise. Jisc has published some legal guidance, which may help. Even with tools that are out of scope, it is very useful for students and other users to know if accessibility is supported. The more that tools support digital accessibility, the less likely you are to need to provide individual reasonable adjustments. A few quick accessibility checks will give you a good idea of how accessible a tool is. If many issues are found then you may want to consider looking for alternatives and also documenting why you feel it is appropriate to continue to use the platform to mitigate risks.

Many of the systems we use are accessed through a web front end system. Are those systems covered by the Public Sector Bodies Accessibility Regulations 2018 - and therefore need to be accessible?

Yes, any system delivered through a browser is covered by the Public Sector Bodies Accessibility Regulations. However, if they are on your intranet or can only be accessed by staff and students then the regulations only apply when there are substantial changes to the intranet. So, if you upgrade a system then it will likely to be required to meet the regulations.

How do you deal with software that provides a statutory process so it must be purchased - but doing so knowingly breaks the law? 

If you are required to use a particular system and you find that it is not accessible, then you should consider making a disproportionate burden assessment. You would also need to consider what accessible alternatives or support would be needed if someone with accessibility requirements had to access the system. This should all be documented in your organisation's accessibility statement.

Do you need advice about creating an accessibility statement? AbilityNet can help. Speak to our experts.

What do we do about eBook aggregators who host third party content? What advice would you give to University libraries purchasing subscriptions to resources when it comes to accessibility auditing? 

There are activities to improve information from ebook providers. The Aspire service is collating and evaluating the accessibility information from publishers and ebook aggregators.

Do we still need to do testing even though in a supplier's accessibility statement they claim they've met accessibility criteria? 

Whether you decide to evaluate an supplier’s claims on accessibility is a matter of considering the risk and how much information a supplier can provide you with to justify their accessibility statement. If the supplier can provide evidence of compliance, particularly if backed up by external testing then you may feel additional testing is not needed (their testing methodology should be included in the statement). When reviewing an accessibility statement, always consider the following questions:

  • How have you evaluated your accessibility compliance?
  • What is your roadmap to fix issues?
  • Will this system present major accessibility issues for our users and what will be the cost of mitigating these?

Overall, think about whether you would purchase a tool without confirming it provided the features and technical specifications they claim. If you would trial or test a system, then apply the same evaluation to its accessibility.

Do you have any recommendations for particular automated accessibility testing services?

There are many free tools that can test accessibility on a single page. Microsoft Accessibility Insights provides a combination of automated testing and manual tests. Many website monitoring tools will also scan sites for potential accessibility issues, but they can only cover about 30% of the requirements and some manual checks will still be required (for example, keyboard). AbilityNet will be offering online training in this area later in Spring 2020.

Looking for accessibility training options for your team? Visit our training page to see our current programme. Check back for regular updates.

Who do you go to for clarification on the Public Sector Bodies Accessibility Regulations? For example, what counts as a "disproportionate burden"?

Jisc has published some legal guidance and you can also access the Government Digital Service (GDS) guidance, which is regularly updated. On the topic of disproportionate burden I would also suggest looking at a recent blog by George Rhodes. This includes links to recourse within the LexDis digital accessibility toolkit such as the disproportionate burden cheat sheet and also to examples of disproportionate burden assessments such as the one by Equality and Human Rights Commission (EHRC).

WebAIM One Million report

During the webinar Abi referred to the WebAIM One Million report - a million home pages were scanned, and 98% tested had accessibility issues that could be detected automatically. The most common issues were low contrast text, missing alternative text for images and empty links.


Image of Claire GibbonsQuestions posed to Claire Gibbons

When working on the redesign for Leeds Trinity University, did you work to one specific checklist? Can you suggest such a checklist to explain tacking accessibility problems in a simple way to those who may not understand? 

The Government Digital Service published guidance on how to do a basic accessibility check (if you cannot do a detailed one) - this is a good start!

Did you have to put extra work into creating an Accessibility Statement for your university's website? 

Our previous site had a detailed Accessibility Statement based on the Government Digital Service sample accessibility statement (for a fictional public sector website). The recently updated website is still ‘settling in’ and we haven’t yet added all the tracking code that we need to (that is in development with the Student Recruitment Campaigns team). So for now we have put up a ‘friendly’ accessibility statement that sets out our intentions and our next steps for testing and development. Once we know more about which cookies etc we are using the statement will be updated.

What sort of user testing for accessibility did you do at the procurement stage and did you focus on usability beyond W3C requirements? 

We used WCAG2.1 in all of our system requirements, for example, for the content management system (CMS) procurement, but we also had ‘softer’ aims throughout the project. Such as lowering the reading age of the content and usability across different devices. In terms of usability more generally, we wanted to make sure that our content could be found, was trustworthy and on-brand, useful and actually interesting to read. So various workshops were run which covered the basics of content strategy and writing for the web, and these will continue across business-as-usual activities.

Could the web accessibility guidelines also be applied in other instances - for example, if you are buying an app or other software?

I would say yes! We quoted them in our CMS requirements document and also when tendering for a design agency. It's up to us as public sector bodies to procure systems that are accessible and usable to all, and that we only publish accessible content. There are many layers to the WCAG guidance including principles, general guidelines, testable success criteria and a rich collection of sufficient techniques, advisory techniques, and documented common failures which could be applied to a range of systems and applications. 

What advice would you give to University libraries purchasing subscriptions to resources when it comes to accessibility auditing?

Speak to potential suppliers about their accessibility statement and roadmap and any user testing they have done, and how they ensure that their services are accessible to all. You might also find this information of interest: Assessing the Accessibility of Library Tools & Services When You Aren’t an Accessibility Expert: Part 1 

The Open University has some useful information about its approach to accessibility

Many thanks to Abi and Claire for their answers above to some of the additional questions posed during our Procurement: Checking external products are accessible webinar.

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