Step 2: Assess and Test Your Systems and Resources for Accessibility

In partnership with All Able Ltd we have pulled together this useful guide for colleges to help with checking the accessibility of websites.

Step one: Identify what you have

Start by establishing which teams, services, digital platforms and resources students will interact with during their time at college. Then, identify the potential accessibility barriers which might impact students in each of those cases.

It is a great idea to map the student journey to identify key processes that need to be considered. Knowing where digital platforms sit within the student journey will benefit the removal of accessibility issues. A knowledge of what you have and how students will interact with them is a vital first step to prioritising what services need work first.

These resources will help you along the way:

• The Government’s Central Digital and Data Office (CDDO) has guidance on making online public services accessible. They describe the four steps you should take to make sure your online services are accessible:
• Decide how to check your website or app for accessibility problems.
• Make a plan to fix any accessibility problems you find.
• Publish an accessibility statement.
• Make sure new features are accessible.

Step two: Prioritising action

When considering where to begin, think about the following to guide you:

• Is the system/resource internally or externally facing?
• How heavily used is it?
• Is the information sensitive?
• Is the system/resource used by disabled users?
• Have there been previous complaints about it?
• Has it already been audited?
• What risk/compliance did the audit reveal?
• Is there an accessibility statement?

Step three: Test for accessibility

Once you have prioritised which systems and resources to tackle first, the next step is to test each of the identified websites / systems / platforms / learning resources to check their accessibility.

Basic testing

• Testing web-based systems

To get started with testing your web-based content and systems for accessibility, begin with these Quick accessibility checks from LexDis. The Microsoft Accessibility Insights automated testing tool is a useful free accessibility checker tool which runs on Microsoft Edge and Google Chrome browsers. It will help to find and fix accessibility issues in your web-based content.

• Testing electronic documents

Common applications such as Microsoft Office and Adobe have built-in accessibility checking features that  can be used now to check the accessibility of existing documents.

Microsoft – Improve accessibility with the Accessibility Checker.

Using the Acrobat Pro DC Accessibility Checker,

Best practice testing

Once you have completed the basic testing, it is highly recommended you progress to in-depth manual testing – testing with assistive technologies such as NVDA and user research with disabled students, to not only ensure compliance with legal requirements but also create highly user-friendly accessible content.

For more information on accessibility testing, read this informative resource from LexDis:

Guidance on accessibility testing resources

Step four: Review our accessibility statement

The requirement for colleges to publish accessibility statements has existed since 2018. If your college does not have an accessibility statement published for the main website by now, you are at serious legal risk.

These statements have very specific legal requirements alongside responsibilities for providing guidance and support to users. To produce an accessibility statement, you must first know what accessibility issues the platform has after completing accessibility testing.

Our research into accessibility in further education  found that 63% of colleges in the UK do not provide legally required accessibility information. Find out how your college scored in our tests.

Step five: Create/update your accessibility statement

To write a compliant accessibility statement, use the CDDO Sample accessibility statement template. Be sure to read the example carefully and consider what accessibility issues your platform has as well as any applicable exemptions.

For many systems delivered by 3rd parties, such as most virtual learning environment (VLE) platform foundations and the Microsoft Office 365 suite, there is often already ample accessibility support information available which colleges can tap into when writing their statements and guidance material.

Find out more about accessibility statements here:

LexDis guidance on accessibility statements.

Careful use of disproportionate burden

Disproportionate burden is a clause in the public sector accessibility regulations that allows organisations to avoid full compliance without penalty (not indefinitely) if you can prove that to achieve compliance would be a ‘disproportionate burden’.

To do this you must thoroughly evidence, that compliance would for example:

• Incur costs greater than the organisation has funds for.
• Not significantly impact disabled users.
• Be wasted effort if new products are to supersede current platforms.

The Government Digital Service (GDS) (regulation monitoring body), has provided guidance on the types of evidence expected to support a disproportionate burden claim and what NOT to claim for.

Levels of compliance on accessibility statements

When completing an accessibility statement, you will have to write the level of compliance you believe your website conforms to. The regulations give the options of “fully”, “partially”, or “not-compliant”.

You should be careful when considering which level of compliance you state in any accessibility statements you write.

• Fully compliant should only be used if the website has no outstanding issues against the WCAG success criteria and no exempted content that you must list in the “Content that’s not within scope of the regulations” section. Every college that lists themselves as fully compliant can be easily verified with the use of automated checking tools. You must be completely sure that there are no issues whatsoever before claiming full compliance.
• Partially compliant should be used when you know you have some issues and/or exempted content, which present moderate to low levels of impact to users. This will cover issues that while disruptive do not completely stop a user from being able to complete tasks.
• Not compliant should be used when there are serious issues which present critical and high levels of impact to users. This will cover issues that completely stop disabled user groups from being able to complete tasks on the website.

Avoiding overlay products

Colleges looking for “easy” routes to compliance should be wary of ‘overlay’ products.

Overlays are products marketed to improve or fix accessibility issues on a website, by adding a small snippet of code, or a button to your web pages which will “fix” the user experience. Some of these products market themselves as using artificial intelligence while others advertise user customisability. We are concerned that colleges are a vulnerable sector to these such offers.

We advise that colleges avoid paying for or utilising overlay products in all cases for the following reasons:

1. The UK regulation monitoring body states that overlays are not considered when monitoring for compliance. Therefore, any spend on an overlay product will not help to meet compliance requirements.
2. Overlays often do not fix accessibility issues, or provide the service advertised. There has been a concerted effort across the accessibility sector to call out the false advertising of these products.
3. In recent conferences, representatives from the US Department of justice have referred to the use of overlays for compliance as “legal suicide”, which is very strong language to represent multiple cases of these overlays now in legal disputes because of false compliance claims they made to customers.

There is no alternative to an accessible by design website that you have developed in the correct way.