Firstly, immense thanks to members of the FEHE Digital Accessibility Working Group (DAWG) for identifying the need to clarify changes to the GDS sample statement and what it means for UK colleges and universities.
Particular thanks are due to Rohan Slaughter for capturing detailed information about the changes outlined here, and to John Kelly and members of Government Digital Service for helping us to check we had correctly understood the changes. A version of this information was shared with the Digital Accessibility JiscMail List and the Jisc Accessibility Teams membership following approval from GDS. As it’s not always easy to find older content in these platforms, key points are reproduced here for reference. If you spot any errors etc, please contact Kellie.
The updated GDS sample accessibility statement
The sample accessibility statement by GDS is incredibly useful to public sector bodies across the country. It provides a clearly defined structure and specific examples of wording.
If your college or university was ahead of the curve and created your statement a while ago, or you haven’t looked at the sample statement for a while, please be mindful that some changes were made in April 2020.
You will need to include these changes the next time you review or update your statement. If you are in the process of writing it for the first time, make sure to use the latest sample as a guide.
The heading structure has been reviewed. The headings now include:
- Accessibility statement for [website name]
- How accessible this website is
- Feedback and contact information
- Reporting accessibility problems with this website
- Enforcement procedure
- Contacting us by phone or visiting us in person
- Technical information about this website’s accessibility
- Compliance status
- Non-accessible content
- Non-compliance with the accessibility regulations
- Disproportionate burden
- Content that’s not within the scope of the accessibility regulations (PDFs and other documents, Live video)
- What we’re doing to improve accessibility
- Preparation of this accessibility statement
Where did these changes come from?
The sample statement changes flow from the European Commission annex with the mandatory content requirements. When GDS created the original sample accessibility statement, it was written to make it more accessible. However, the original statement was changed in April 2020 as the GDS team felt that the sample statement did not sufficiently reflect the EC guidance. The main changes include:
Site owners might have statements for a range of sites, services, courses etc. therefore the scope of the statement is important
Note that statements can ‘link up or down’, it is possible to write a statement that covers an entire system such as a VLE and not particular courses. This is the place to mention what this statement covers and what it does not, alongside links to any super-set or sub-set statements that apply to in the case of the VLE example individual courses or modules.
Some of the section titles changed
e.g. feedback and contact information (was ‘What to do if you cannot access parts of this website’) this is noted by GDS to be clearer and matches the EU statement
A ‘compliance status’ section has been added
The ‘Content that’s not within the scope of the accessibility regulations’ section has been matched to the EU model accessibility statement
This provides a place to note what elements are outside the scope, for example in these cases there is no need to add WCAG success criteria, if the site or element being discussed is outside of the scope of the PSBAR.
The ‘Preparation of this accessibility statement’ section has been added.
The use of nested Statements
GDS team members approved of the idea of using ‘nested statements’.
The accessibility statement found on a specific page should relevant to the page, site or service, users must be able to understand how such nested statements link together on a course / VLE / website.
More ‘user accessible / usable’ statements can be created but must at least link to a compliant statement that uses the ‘legal language’, this must include contact information, who to direct complaints or queries to etc.
Important things to note
The changes have not been put in place to enable easier monitoring or automated monitoring. The changes have been made to bring the sample statement closer to what is required by the regulations.
The GDS would expect site owners to review their accessibility statement annually and whilst it was noted by the GDS team that this is the ideal we were told that it is more important to have the information available than to have the specific section titles in the statement matched to the sample statement, however if this is wrong site owners can still be challenged.
Those who are who are developing a statement should include the WCAG failure points and what is being done to improve these accessibility failures.
It will be useful to record what you are doing to meet the regulations.
How will auditing be done?
Currently only new or substantively updated websites are being reviewed. From 23rd September 2020, all websites and services will be in scope of the public sector bodies accessibility regulations. The monitoring process is detailed on the GDS site.
GDS is already undertaking a small review sample of sites / systems and will be contacting organisations post audit and will send a report to the contacts given on a site or service.
GDS can request an organisational credential in order to access systems such as a VLE that are behind an institutional login. Requests for such access will be made using the contact information on the website.
Note that it is important to make sure you have current and useful contact information on your website, the GDS stated that they do follow up if they do not get responses.
Need more help?
Jisc provides training to help you with statement writing and all the other processes that need to be implemented around this. We also run drop-in clinics, and a lively community. Check out all the legal advice and resources on our accessibility landing page. You may also find this recent podcast by Rohan on the accessibility regulations helpful.
As part of the Digital Accessibility Working Group, Jisc subject specialists Kellie Mote, John Kelly and Rohan Slaughter can ask GDS questions on your behalf. So do get in touch if there’s something you feel isn’t covered or explicit enough in the existing guidance.