The new guidelines for UK public sector bodies on ‘Delivering inclusive websites’ (see E-Access Bulletin, June 2008) are a bewildering blend of the vague with the Draconian.
The guidance, published by the Central Office of Information (COI) under the reference number ‘TG102′ (See www.coi.gov.uk/guidance.php?page=129),stipulates that all new UK public sector websites must conform to at least ‘AA’ accessibility standards as specified by the W3C Web Content Accessibility Guidelines.
Existing central government department websites must conform to ‘AA’ by December 2009. “This includes websites due to converge on Directgov or BusinessLink, unless convergence is scheduled before this date,” the guidelines state. Sites of all other government agencies and non-departmental bodies must conform by March 2011.
Where such content formats are decided to be essential, “every attempt should be made to ensure that the accessibility features of the relevant authoring tool are used,” the guidance states.
Other areas covered include a requirement for public bodies to submit website accessibility policies to the accessibility sub-group of the Digital People Network – a new forum set up by the COI for public sector managers working with digital media – by December 2008. The guidance also provides advice on planning, procurement, content design and maintenance and assessment of accessibility through the use of user testing and other methods.
So far, so comprehensive. But how strongly enforced will the guidelines be?
Though not mandated by law, the guidance warns that “Government websites owners are reminded to follow the conditions of use for a .gov.uk name (TG114). Websites which fail to meet the .gov.uk accessibility requirements may be at risk of having their domain name withdrawn.”
This softens the warning contained in a previous draft version of the guidelines, which had used the stronger formulation: “websites which fail to meet the mandated level of conformance shall be subject to the withdrawal process for .gov.uk domain names”.
Furthermore the ‘conditions of use for .gov.uk name’ referenced in the guidance, Cabinet Office document TG114, are vague on accessibility definitions.
They state: “Applications (web, email, etc) using a .gov.uk domain name must comply with current UK legislation and support channels that provide accessibility for disabled people, members of ethnic minorities and those at risk of social/digital exclusion. Legislation includes Copyright, Data Protection Act and Disability Discrimination Act. Abuse of [sic] will result in the name being withdrawn” see fastlink.headstar.com/caboff1).
How useful is this paragraph? It seems redundant for an official document to specify that any form of government activity ‘must comply with current UK legislation’. And the suggestion that websites must ‘support channels that provide accessibility’ also amounts to little, since ‘channels’ – presumably, meaning media or technologies – do not in themselves generally provide accessibility: this depends more on how channels are used.
Perhaps more usefully, the .gov.uk conditions go on to state: “When you are using a .gov.uk domain name to deliver a web presence you are reminded that websites should comply with the e-Government Interoperability Framework, the Guidelines for UK Government websites and Framework for Local Government particularly on such issues as use of metadata, PICS labelling, accessibility and security.”
Following this increasingly convoluted trail to the ‘e-Government Interoperability Framework’ (e-GIF) referenced here – and last updated as version 6.1 in March of 2005 – we find a strikingly familiar phrase in paragraph 2.23: “Government information systems will be designed to meet UK legislation and to support channels that provide accessibility for disabled people, members of ethnic minorities and those at risk of social/digital exclusion.”
With e-GIF, however, paragraph 6.25 contains some sterner warnings associated with a failure to comply, namely that: “If a system fails the test on any of the aspects listed above, then a migration strategy will need to be produced and agreed by the e-Government Unit.Failing to comply and the absence of an acceptable migration strategy will lead to the following courses of action:
“- compliance with the e-GIF is one of the criteria that will be used when assessing/evaluating departmental e-business strategies and deciding on the release of funding by the e-Government Unit and HM Treasury.
“- new systems failing to comply with the e-GIF will not get project approval or funding from the appropriate bodies within their organisations;
“- systems seeking to link to Directgov, the Government Gateway or the Knowledge Network and failing to comply with the e-GIF will be refused connection;
“- suppliers who are not prepared to meet the e-GIF specific requirements or equivalents.will not meet [procurement] specifications.”
Clearly here, at last, are some hefty sticks with which to beat those creating inaccessible websites. It is a shame, however, that they are buried in a trail of paperwork two documents removed from ‘inclusive websites’.
Some rationalisation of all this advice is likely to be needed if the laudably high accessibility levels stipulated in the new guidance are ever to come close to realisation.