The new regulations and what we need from Jisc, GDS, Ucisa etc… What the sector needs The new regulations and what we need from Jisc, GDS, Ucisa etc…

What the sector is doing Awareness appears patchy… The digitalaccessibilityregulations@jiscmail.ac.uk Jiscmail list provides evidence of panic and confusion Briefings and conferences springing up - well-attended and much- needed

Clarity needed On scope On timescales On semantics On exemptions ‘Substantial revision’ ‘Disproportionate burden’ On exemptions On monitoring and enforcement Even on the correct link to the legislation! www.legislation.gov.uk/uksi/2018/952/made

Meet the key stakeholders PolicyConnect Trying to provide guidance, but have contributed to confusion Government Digital Services (GDS) Are providing guidance, but seem not to appreciate the scale of the task for HEIs – and have lost one key person Jisc Have been working behind-the-scenes with GDS - but have lost their ‘accessibility lead’ Run monthly clinics And a Working Group – FHEDAWG…

Further Higher Education Digital Accessibility Working Group (FHEDAWG) Includes reps from the sector and beyond (Kent, UCL), GDS, PolicyConnect, Jisc, AbilityNet Objectives: Create model accessibility statements. Collate guidance & frameworks on how to meet standards. Provide good practice guidance in areas where the government’s official guidance is not good enough. Liaise with government and regulators to promote outputs and press government for better guidance.

Notes from a conversation with GDS Our questions GDS answer 1. Definition of substantial revision The regs don’t define this – it’s up to the HEI to determine… Recommended FHEDAWG provide guidance 2. Documents and priorities – we suggested greatest good for the greater number… We need to be clear about any ‘partial compliance’ in our Acc Statements 3. Third party content If we have purchased it or funded it in some way then it’s in scope 4. Lecture capture – an additional format? 5. What platforms are in scope and how do we prioritise them? Pretty much any platform (research, student information, HR, timetabling, finance, etc) once it has undergone a major revision 6. Disproportionate burden – one-off or incremental? Disproportionate Burden can’t be treated as a ‘forever’ derogation. Need to keep Acc Statements up-to-date.

GDS did clarify timescales: Public-facing websites New or updated online content published on or after 23 Sept 2018 has to comply by 22 Sept 2019.  Existing sites (published before 23 Sept 2018) must comply by Sept 2020. Intranets (behind a password – e.g. VLEs) New or substantially revised content published on or after 23 Sept 2019 to comply with the requirements of the regulations on publication. Intranet content published before 23 September 2019, doesn’t have to be brought into compliance at a fixed point; they must instead be brought into compliance only when first substantially revised on or after 23 September 2019

What all institutions need to do Could share ideas and examples Understand the legislation Identify in-scope platforms Write accessibility statements for each platform Develop policies More localised actions needed Assess and prioritise remediation work Communications plan Enhance guidance and training Fix stuff (platforms, content) Establish a central point of contact

Some possibly useful accessibility statements… Joint production from the awesome Ben Watson (University of Kent) and George Rhodes (Kent County Council) Technical Statement​ Includes all of the wording from the regulations. Plain English Statement the one we would hope most of our end users will access. A good way to help people get the best from our digital content regardless of disability… Known Issues An overview of current issues that have been identified through auditing or user feedback

A good read… On the challenges of responsibility without authority

What Ucisa is planning to do Raise awareness amongst IT Directors Produce a Digital Accessibility Toolkit (in partnership with FHEDAWG) Facilitate provision of legal advice on the ‘grey areas’ (maybe with Jisc) Lobby GDS and PolicyConnect to provide more consistent, focused and practical guidance Put pressure on vendors to improve the accessibility of their platforms Procure/develop sector-focused guidance and training

Hot off the press Guidance from FHEDAWG - https://www.lexdis.org.uk/digital- accessibility/ on timelines and ‘what is a website’