The below discussion points came up in some of the interviews. They give insights into what may be affecting progress. They also consider local versus national approaches.
A national approach to leadership and policy
We heard there was little guidance at a national level. Health boards and councils had to come up with their own approach, according to interviewees. They had to develop plans, policies, training and roles and responsibilities. Local organisations paid for expert training. Technical support for websites was also bought in. Local organisations were duplicating efforts. A national approach would benefit the NHS and councils. Pooling resources could save them time and money. It would also be beneficial to share learnings on a larger scale.
Accessibility is bigger than individual organisations. We heard that local organisations want national guidance. They also welcome practical support. A national approach to leadership and policy could benefit the public sector.
Response to risk
How leaders respond to risk was a discussion point. Executive teams make decisions based on risk. This includes both operational and reputational risks. Public sector organisations have a responsibility to follow the law. So why isn’t accessibility a priority?
“I think in lots of organisations, the struggle to have accessibility taken seriously is because comms isn’t taken seriously.”
GDPR vs PSBAR
The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (PSBAR) and the Data Protection Act 2018 (the UK’s version of GDPR) became law in 2018. Several interviewees compared these two pieces of legislation. And the approach their organisations took to the legislation. It was quite different. Most organisations set up a dedicated team to prepare for GDPR. Staff received training and guidance. None of the organisations the interviewees spoke about, had done the same for accessibility. GDPR rules are clearer. Compliance is straightforward. As mentioned above, accessibility is complex. There are many facets to accessibility compliance. Accessibility is harder to put in place. This may be one reason a similar approach was not taken.
Technology is a consideration when discussing GDPR and PSBAR. GDPR applies to all sectors, including the private sector. The private sector had a business response to GDPR. Tech companies built GDPR into their tools. For example, newsletter tools ensure individuals have given consent to use the tool. When it comes to accessibility, technology cannot fix bad content. A website can have accessibility features, but that does not make it compliant. Content does not have a technology solution. People are responsible for content. This makes it harder for organisations to be compliant.
No perceived risk
We heard that the perceived risk of accessibility is low. The UK Government clearly states that the Central Digital and Data Office (CDDO) has a remit to audit public sector websites. They have the power to enforce compliance in a short period of time. But there are no known instances of financial penalties for non-compliance. Nor are there known risks to organisational reputation. In contrast, there are clear penalties for not complying with GDPR. It is easy to google and read about GDPR fines. Our desk research was unable to find an organisation that had been fined for accessibility. If there was a perceived risk, more organisations might try to comply. This theory is an interesting area for further research.
Inclusive communications 