Disproportionate burden
For each of the following issues, we have assessed the costs and impact involved in resolving the issue alongside the benefits to affected people, and believe that doing so now would be a disproportionate burden within the meaning of the accessibility regulations. As a result, work is not currently underway to address them.
Work is underway to develop a new website for the Commissioner. It is expected that a new site will enable us to overcome most of the issues below. We will make another assessment when Phase 1 of the new website is developed, which is expected to be by April 2022.
We will also ensure information is available by other means wherever possible.
PDFs
Our PDFs and other documents do not meet accessibility standards - for example, the information in them is not structured in a way that would make them accessible to screen reader users.
This fails WCAG 2.1 success criteria including 1.1.1 (Non-text Content), 1.3.1 (Info and Relationships) and 1.3.2 (Meaningful Sequence).
There are over 5,000 PDFs on the website, covering a range of topics and types of information - many of which were created after 23 September 2018, and so are not exempt from the accessibility regulations. The issue has arisen as historically PDFs are the main tool which has been used to create and share our publications and information. Making the information in these documents more accessible would have benefits for some disabled people using the website.
It would take a significant amount of staff time and resource to make this change, and the website is not structured in a way that would easily support this. Changing business processes which result in the creation of new PDF documents on the website immediately would also involve a large amount of work and change to processes.
We believe addressing this issue for documents produced after 2018 now would be a disproportionate burden within the meaning of the accessibility regulations. However, we are working to establish how our processes can change in future and will make another assessment when this is complete, which is likely not to be before March 2022. We will also ensure information is available by other means wherever possible.
If you require assistance - for example if you would like particular information to be provided in an accessible format - please contact us.
Responsive Page Layout
When viewing pages with high zoom, some content becomes unavailable - i.e. it overlaps, is obscured, is no longer usable or disappears - and two-dimensional scrolling (i.e. left-to-right as well as up-and-down) is required. When viewing pages with increased line or character spacing, some content also becomes unavailable.
These issues fail the following WCAG 2.1 Success Criteria:
- 1.4.4 Resize Text [Level AA]
- 1.4.10 Reflow [Level AA]
- 1.4.12 Text Spacing [Level AA]
These issues arise because the website layout is not responsive or adaptive, including to mobile devices, as a result of the age and nature of the website design. The issues have a substantial impact on some users; however, resolving them would involve high costs as it would require significant website redevelopment.
If you require assistance - for example if you would like particular information to be provided in an accessible format - please contact us.
Decisions - Headings and Tables
The decisions database does not have the required header structure, and may contain nested tables (meaning a table within a table).
In addition, decision pages published before 23 September 2018 do not have the correct, logical heading structure, and contain tables that lack the required structure of column headers and/or are not identified as being for layout purposes only.
These issues fail the following WCAG 2.1 Success Criteria:
- 1.3.1 Info and Relationships [Level A]
- 1.3.2 Meaningful Sequence [Level A]
- 2.4.1 Bypass Blocks [Level A]
These issues arise because of the way the database was created, and the templates and processes used for publishing these decisions.
The decisions database is accessed by approximately 970 users each year. Addressing these issues would enable people using screen reader devices to fully understand the layout and content of the relevant pages such as the decisions database. The content is currently able to be read by a screen reader device, but is read out of context in some cases.
If you require assistance in accessing our decisions - for example if you would like a particular decision to be provided in an accessible format - please contact us.
Pop-up Messages
Pop-ups and other messages that are presented visually - such as the outcome when using the response calculator - are not announced by screen readers, making this information inaccessible to some users.
This issues fails the following WCAG 2.1 Success Criteria:
- 4.1.3 Status Messages [Level AA]
We are unable to calculate how often the response calculator is used within other pages, but the stand-alone information page about the calculator was accessed by approximately 800 users each year.
If you require assistance in using the response calculator, please contact us.
Tab Focus Indicator
There is no visible tab focus indicator built into the website. There should be a visible indicator - with a 3:1 contrast, over and above that provided by a web browser - to indicate to a user where they are on the page, and which button or link is ready to be selected, when navigating using the Tab key.
This issue fails the following WCAG 2.1 Success Criterion:
- 2.4.7 Focus Visible [Level A]
Addressing these issues would enable people navigating the website using a keyboard to clearly see where they are on a page, and which link or button is active. Resolving this issue would incur substantial costs. As mitigation, users can alternatively rely on their own browser indicator or add-on in place of a website-specific indicator.
If you require assistance - for example if you would like particular information to be provided in an accessible format - please contact us.
HTML Validation
The website accessibility audit, carried out in March 2020, identified some HTML validation errors, such as missing start or end tags, elements with duplicate attributes, elements not correctly nested, and non-unique IDs.
This issue fails the following WCAG 2.1 Success Criterion:
These issues affected a range of areas of the site. A number of errors were addressed while editing/updating pages to comply with other accessibility requirements, while others have been and continue to be corrected in the course of routine website content maintenance. However, a comprehensive review and action to address immediately would require significant resource.
If you require assistance - for example if you would like particular information on a page affected by these issues to be provided in an accessible format - please contact us.
