The Public Sector Bodies (Websites and Mobile Applications (No. 2) Accessibility Regulation 2018 states that our websites and applications must be accessible. This means they must be compliant with the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. The University of Bath will meet at least level AA for our websites and mobile applications unless making the content accessible would place a disproportionate burden on the University, as allowed by The Public Sector Bodies (Websites and Mobile Applications (No. 2) Accessibility Regulation 2018. Our Public Accessibility Statement will explain why the website or app is exempted.
Roles and responsibilities for digital content
The roles and responsibilities for digital content will be described in a similar manner to the roles and responsibilities for the Disabled Students Policy, as non-compliance can be treated as a failure to make reasonable adjustments under the Equality Act 2010.
The Vice-Chancellor and University Executive Board
The Vice-Chancellor has overall responsibility for ensuring compliance under the Equality Act 2010 at the University. Senior Managers implement and promote the principles and behaviours embedded in University policies and procedures. The Vice-Chancellor delegates responsibility for undertaking aspects of these duties through line management and identified roles. The following people/teams have specific responsibilities under this Policy.
Digital, Data and Technology group (DDaT)
DDaT oversee the accessibility of our digital estate. This will include monitoring and reporting on websites with the bath.ac.uk domain and monitoring and reporting on mobile applications used by the University. This will be done against standards in legislation, or those agreed for the institution. Monitoring will be done in conjunction with other service owners where appropriate, with reporting by DDaT to University Executive Board at intervals required by legislation, or at more regular intervals if requested by University Executive Board. They will continue to update the University Public Accessibility Statement.
DDaT will notify the University Executive Board, service owners and users of any changes in legislation likely to significantly impact on our compliance in a timely manner.
DDaT are responsible for maintaining the University Digital Accessibility Policy.
Heads of Department or School
Heads of Department (including professional service departments) or the School, working in collaboration with the DDaT and other relevant professional services, have responsibility for ensuring that websites or mobile applications they procure, develop and/or maintain meet the requirements of the Digital Accessibility Policy. DDaT will notify Heads of Department / School if any services they own or maintain do not meet the required standards and will include recommendations on how to improve accessibility.
All staff are responsible for ensuring that they conduct their activities, and those activities over which they have control, in accordance with the University's Digital Accessibility Policy and relevant statutory provisions. They must co-operate with their line manager and Head of Department, School or Service so that their responsibilities can be discharged.
Staff should attempt to make all material compliant in the first instance through using institutional guidance and automatic accessibility checking tools. If content that staff have created is identified as not meeting accessibility requirements, either through an audit, an automatic accessibility checking tool or through a request for material to be provided in an accessible format, they must either take steps to make that material accessible, or send a notification to email@example.com as to why that particular material meets the requirements for an exemption under the legislation (see later).
Failure to provide digital materials in an accessible format may be viewed as a failure to make reasonable adjustments for a disability under the Equality Act 2010.
Students or contractors employed to carry out work within or on behalf of the University are considered by to be members of University staff for the purpose of this policy, whilst carrying out that activity.
Students are required to meet the same standards as staff if they procure, develop or maintain websites, content on websites or intranets (including the institutional Virtual Learning Environment) or mobile applications which could reasonably be considered to be associated with the University of Bath. This Policy does not apply to websites or mobile applications that they maintain in their personal or any other capacity which are not related to the University of Bath.
Roles and responsibilities for training
Digital, Data and Technology group (DDaT)
DDaT will be responsible for coordinating training on digital accessibility and maintaining institutional guidance for users. Guidance and training will be accessible from a single point for staff and students, regardless of the use. DDaT will work with the CLT, Library, Skills Centre, Student Services and Marketing & Communications to ensure the training and guidance covers user need and meets the requirements for different roles.
Interim guidance specifically for the development of learning materials and research outputs is available on the Learning and Teaching Hub. This will be replaced by institutional guidance when available.
All service owners
Where practical, service owners will take steps that make it easier for those developing digital content to meet accessibility requirements through automation (for example, having a default to automatically caption recorded lectures). Where compliance may be a concern, there should be links to training and guidance materials provided which will make it easy to engage with the training.
Heads of Department or School
Department / School should ensure that departmental / divisional staff and students receive any necessary training, information and instruction required in order to meet the requirements of this policy.
All staff are responsible for ensuring that they conduct their activities, and those activities over which they have control, in accordance with this policy, and that includes engaging with training that they need in order to meet the requirements of the policy.
Monitoring, reporting and maintaining compliance
The Government is required to report on the accessibility of websites and mobile applications by publicly-funded bodies. They have the right to ask for access to our intranets (including Moodle or other internal websites) to sample compliance.
All bath.ac.uk domain websites and all mobile apps used by the University will be monitored at least annually and an annual report provided to University Executive Board by DDaT on institutional compliance. In addition, the University will:
- Check that new features meet accessibility requirements
- Perform a new service audit if substantial changes are made to any services
- Check the compliance of new material where practical
In addition to institutional level monitoring, the University will:
- Continue to investigate accessibility of digital systems at the procurement stage
- Create accessible document templates - i.e. basic Word and PowerPoint templates which would be available as standard for all users to access. Updating any official, Departmental templates such as reports, minutes, forms etc.
- Promote accessibility tools available within the University
- Develop further guidance for academic staff on creating accessible resources
- Celebrate success to reinforce the importance of accessibility to the whole University community
There are situations where accessibility standards are not required to be fully met. This is the case if the impact of fully meeting the requirements represents a ‘disproportionate burden’ to the institution.
If the University wishes to declare that making particular websites or digital content accessible represents such a burden, it is legally required to carry out an assessment. The assessment should include:
- the burden that making particular websites or digital content accessible places on the University
- the benefits of making particular websites or digital content accessible
If the benefits would not justify the cost to the University, the University can claim that changes would represent a disproportionate burden and would be unreasonable. Any exemptions should be included in the Public Accessibility Statement.
If a service owner of member of staff developing or updating content for a website believes that an exemption can be justified, they need to send a notification to firstname.lastname@example.org as to why that particular material meets the requirements for an exemption under the legislation. An assessment will then be carried out and if the exemption is appropriate and be included in our Public Accessibility Statement. If an exemption is not considered appropriate, the member of staff will be responsible for converting the materials into an accessible format.
Government guidance clearly states that lack of time or knowledge should not be taken into account.
It is unlikely that staff not knowing how to use styles and create alternative text for images, or staff choosing to produce content on software that does not meet accessibility standards will be viewed as a disproportionate burden.
Public Accessibility Statement
As part of our legal duties, the University is required to publish an accessibility assessment for every University website and mobile application. The statement needs to include an explanation of those parts of the content that are not accessible and why. The University must outline how it is going to meet the requirements, or if it is unable to meet them, explain why resolving the issue would constitute a disproportionate burden.
DDaT will be responsible for reviewing and maintaining our public Web Accessibility Statement. Under legislation. This statement must be reviewed annually and include the steps which are currently being taken, an accessibility roadmap with information about the accessibility of all University Systems and any systems which are exempt.
- Policy was approved by Senate: 18 September 2020
- Policy latest updated: 18 September 2020