Clackmannanshire Council is committed to meeting the requirement to make websites accessible, set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("the accessibility regulations").
However, our work covers a huge array of local services which encompass a large and broad range of information and online activity. We have a vast, complex collection of websites and tools, many of which we procure from other organisations and third parties, and have limited resources to check them all for accessibility issues.
We've decided to use a combination of methods, as set out in the GOV.UK guidance on deciding how to check our websites and in compliance with the accessibility regulations.
We're doing a detailed accessibility check for:
This is our ‘main website’.
The process for doing a detailed check will include:
We believe it is reasonable to carry out a detailed check of our main website, as this covers the most important web-based services provided by Clackmannanshire Council.
Our accessibility statement for www.clacks.gov.uk covers problems we found with our main website, our plans to fix them and any issues it would be a disproportionate burden to fix at this time.
We will also carry out basic accessibility checks on Clackmannanshire Council’s websites that are independent of our main website.
These basic checks will be carried out by the team responsible for the website, based on:
We will check samples of content, which may include:
We believe that our approach to carrying out accessibility checks is reasonable but means that we will not do detailed accessibility checks on all of our websites. This might mean accessibility issues on some of our websites are not fixed.
However, the accessibility regulations say that we do not need to make a website accessible if doing so would impose a disproportionate burden on us. We believe that carrying out more detailed checks and fixing documents, beyond what is set out above, would be a disproportionate burden.
You can read why we consider this to be a disproportionate burden.
Our most important content and transactions are provided on our main website. We're doing detailed a check of this.
However, we do not believe the benefit of paying an auditor for detailed checks of our other websites would justify the impact on us except where those sites are specifically aimed at people with a disability.
We've also assessed that it would be a disproportionate burden to fix all documents published on these websites since 23 September 2018.
The majority of these documents are rarely viewed; therefore they are unlikely to be negatively impacting users with disabilities or impairments. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified.
We will focus on fixing the most viewed documents on these sites (top 5%), and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities.
Websites
Clackmannanshire Council has a number of websites and services independent of its main website.
These websites vary in purpose, size and content. Some are hosted by us, others are hosted and maintained by external suppliers and managed by an individual council service, programme or directorate.
Most of our independent sites are relatively small in scale, usage and complexity, and do not provide essential services or specifically address the needs of, or are meant for, persons with disabilities.
Examples of these sites include:
Documents
As of 2 September 2020, there were 416 documents on our main website published since 23 September 2018 (within scope of the accessibility regulations), however if you consider our entire web estate, there would be around 2300 historic documents created by the organisation.
Focusing on fixing the top 5% most viewed documents on our main website is equivalent to about 20 documents.
Paying for detailed audits
We have estimated the costs for an external expert to do a detailed check (and later re-audit) on our full collection of websites.
On the basis of these assumptions, we estimate the cost to our organisation overall for detailed audits for all of our websites and services would be between £30,000 and £70,000.
These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. These include:
Cost of fixing documents
It's difficult to know how long it would take to make every document accessible without first reviewing each one.
Potentially each document would require several hours of work to be recreated in a fully accessible version. (Estimated based on extensive experience of converting documents at between 2 and 30 hours per document, depending on length and complexity, plus any required sign-off, or subject matter expert involvement).
However, if we use a conservative estimate of three hours to review and fix each document within scope, fixing all 416 would take 178 working days (based on a 7 hour working day at Clackmannanshire Council).
Assessment of costs and benefits
We believe that:
Therefore, doing detailed checks on all of our websites and fixing all documents on our main website would impose a disproportionate burden on us.
In reaching this decision, we have considered the following:
Our organisation’s size, resources, and nature
Clackmannanshire Council has a very small amount of dedicated web development and content resource.
At the time of writing we have the following personnel, both equivalent to 1 FTE:
During 2020/2021 we have also been forced to re-prioritise resources owing to the Coronavirus (Covid-19) pandemic, ensuring business continuity of essential services and focusing mainly on our Covid-19 response.
Additionally we have a wide variety if BAU tasks as well delivering projects and maintaining the existing website and functionality. The Content Coordinator also manages certain aspects of communications and social media.
The estimated costs and benefits for our organisation: accessibility checks
We believe the potential of paying the substantial costs set out above on audits (before we've actually fixed anything) is unreasonable and not a good use of valuable public resources. It could also have an impact on the delivery of the services themselves that the websites relate to.
Many of the teams that maintain sites independent of our main websites provide valuable support to public services such as education, housing, social care and community support.
We believe that:
Our team will be assisted in their basic checks by:
The estimated costs and benefits for our organisation: fixing documents
The vast majority of this work would have little to no benefit to users with disabilities due to the low usage of the majority of online documents.
The estimated benefits to users
Our users with disabilities will benefit from us making our websites and online documents accessible.
For our main website, we are already undertaking a detailed accessibility check, fixing the most accessed documents and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities. This focuses our accessibility improvements where they will provide the most benefits to people with disabilities.
However, for the majority of our websites, we do not believe that the limited additional improvements that could be gained from detailed checks or more document fixes would justify the substantial costs of doing so.
If you need information in a different format contact us and tell us:
We’ll consider your request and get back to you as soon as possible.
Strategy & Customer Services
Kilncraigs, Greenside Street, Alloa, FK10 1EB
Tel: 01259 450000
Email: clacksweb@clacks.gov.uk