1. Introduction

1.1 The University is guided by the Public Sector Bodies Accessibility Regulations1 (PSBAR, 2018), to ensure that digital content and services that it provides are usable by everyone including those with disabilities. These Regulations build upon the Equality Act 2010 and provide more specific requirements for digital accessibility.

1.2 Under the regulations, the University must publish an accessibility statement explaining how accessible its digital content and services are.

1.3 There is also a responsibility on the individual to adhere to PSBAR and the University is committed to supporting all members of its community to meet the requirements of the regulations.

1.4 Accessibility is an institution-wide issue that affects marketing, communications, learning materials, and research outputs. As a result, the University has adopted an institution-wide response to its legal obligations.

1.5 The regulations provide the University with an opportunity to adopt a more inclusive approach to the design, development, procurement and use of digital products and services; helping to enhance the support we offer the diverse community at Bath.

1.6 The policy applies to all staff and students

1.7 The policy is supported by associated procedures.

2. Purpose of Policy

2.1 The purpose of this policy is to:

a. promote equal access to digital content and services;
b. improve the user experience of our digital platforms for everyone, including persons with disabilities;
c. highlight the responsibility of everyone involved in the design, development, procurement and production of digital content and services at the university to adhere to the PSBAR

3. Scope

3.1 The policy covers:

a. Online materials that the University of Bath publishes via websites, intranets, wiki, blogs, social media channels etc.   b. Documentation including documents, presentations, meetings/events papers, instructions that are produced day-to-day
c. Multimedia – audio, video, and imagery
d. Teaching and assessment content – including online content, documentation and multimedia used in teaching 
e. Digital products / services / platforms delivered by the University of Bath which have a user interface, whether developed in-house or externally

4. Policy

4.1 The University of Bath recognises its legal and regulatory responsibility in respect of digital accessibility. To ensure that it is compliant with these requirements, the University will:

a. provide the necessary tools to ensure that staff who are involved in creating digital content, are able to do so in an accessible format;
b. maintain a Digital Accessibility Special Interest Group (DASIG) to provide institutional guidance on regulations and requirements for digital accessibility and to oversee an institutional approach for training and support of staff;
c. develop and provide appropriate training, including refresher opportunities, for all staff to ensure that they can create digitally accessible content and can use tools and resources in a digitally accessible manner;
d. build a community of practitioners from across the institution who can provide timely support and help for those staff members with ‘How do I?’ questions;
e. actively promote accessibility tools which staff can use as they develop digital content and services;
f. establish and deliver an internal audit process for accessibility of digital content and services to identify where additional support and guidance is required to meet regulatory requirements;
g. monitor the Summary of Reasonable Adjustments (SORA) of disabled students related to digital content and services and the extent to which the SORA are met or are exempted due to disproportionate burden on the University;
h. ensure, during contract and procurement stages, that new digital systems and services meet at least conformance level 2 standard (AA) of Web Content Accessibility Guidelines (WCAG) 2.2;
i. seek to ensure that developers of digital products and services, comply with current legislation;
j. review annually our Public Accessibility Statement which provides an assessment of every website and mobile application that is hosted by the University of Bath

5. Roles and Responsibilities

5.1 The Vice-Chancellor has overall responsibility for ensuring institutional compliance under the Equality Act 2010 and PSBAR (2018).

5.2 The Chief Information Officer (CIO) is accountable, and product owners or project managers are responsible for the procurement of digital products, services and platforms;

5.3 Individual members of staff are responsible for ensuring that digital content that they create and share is accessible in accordance with the policy statement. They must also provide an explanation in the case where they are seeking exemption from the regulation;

5.4 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.

5.5 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. 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.

5.6 Heads of Department are responsible for ensuring that their staff engage with training and support to create digitally accessible content and/or services;

5.7 The Digital Content team will oversee the accessibility of the 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. The Digital Content team are also responsible for updating the University Public Accessibility Statement in relation to this domain. They provide a reporting service for problems associated with accessibility and are responsible for ensuring a resolution (although the resolution may be undertaken by others).

5.8 DASIG will notify the Digital Content team, service owners and users of any changes in legislation likely to significantly impact on institutional compliance with regulations in a timely manner. They will also ensure that training on digital accessibility and maintaining institutional guidance for users is kept up to date.