Developing and Publicising a Workable Accessibility Strategy
This article looks at the increasing need for developers of institutional and educational Web sites to develop and follow a strategy for ensuring optimal accessibility of online content. In particular the need is stressed for careful thought about the aims of such a strategy, and to ensure that the strategy meets a balance between ambition, legal responsibility and equitable access to learning and teaching. As an example, the need for a well written public online accessibility statement is discussed, not only as a demonstration of awareness and proactivity, but also as an important factor in its own right in optimising access.
Background: Web Accessibility Drivers
In the UK there are several drivers that are helping to ensure that Web accessibility is at least a consideration for all education institutions. These have included the Quality Assurance Agency's (QAA) Code of Practice for the Assurance of Academic Quality and Standards in Higher Education, Section 3: Students with Disabilities , increasing awareness of good practice in Web development, (such as the use of standards), and disability discrimination legislation. It is this latter driver that has perhaps brought accessibility of Web-based material to the top of some Web managers' 'to do' list and is likely to continue to do so.
The Disability Discrimination Act 1995 (DDA) outlaws discrimination against disabled students, both as individuals, in that they cannot be treated 'less favourably' than non-disabled students and, potentially more significantly for the provision of Web materials, as a part of the general public by not making 'reasonable adjustments' to the services the institution provides.
Reasonable adjustments are a duty owed to the wider community and are anticipatory. The legislation is there to ensure that if a disabled student should wish to attend a course at a specific institution then practices that could have been amended have been, or that there is a policy in place that can amend a practice with the minimum of disruption to the disabled student.
Whilst it may be some time until the legislation is tested in a court of law, thereby providing case law to define the legislative requirements further, commentators have agreed that institutional Web sites would be covered by the requirement to make reasonable adjustments, that is, they need to be accessible to a wider disabled community .
However, while the legislation is a major driver and is forcing Web developers to look at how disabled students access their material, they should also be aware that a wider social inclusion agenda is also gaining momentum. Inevitably access to all electronic materials will become an equity of access issue that should be second nature to the developer, in the same way as the consideration of ramps and lifts is to an architect when designing a new building.
UK Higher Education Accessibility Studies
There is clear evidence that across the UK, steps are being taken to address accessibility of institutional Web sites, supported by two recent studies which simultaneously, but independently, analysed a range of Higher Education Web sites against established accessibility criteria. While current efforts are acknowledged, both studies indicate that there is scope for more to be done, particularly in terms of conformance with levels of accessibility claimed by the sites themselves.
Kelly analysed 162 Higher Education entry points (i.e. the home page of the Web site)  using the online Bobby testing tool. Kelly adds the caveats that the findings are only indicative of the current state of accessibility, that the testing tool is limited and that full assessment would necessitate a large degree of manual checking.
The limitations of automated checking tools have been further explored by Diaper and Worman . Their research found not only shortcomings in the tools but also that some results differed between the tools when tested on the same page.
Kelly's findings demonstrated that 70 entry points met the World Wide Web Consortium's Web Accessibility Initiative (W3C WAI) Conformance Level 'A', whereby at least all Priority 1 checkpoints of the Web Content Accessibility Guidelines 1.0 (WCAG 1.0) are satisfied and four met W3C WAI Conformance Level 'Double-A', whereby at least all Priority 2 checkpoints are also satisfied. However, only those checkpoints that could be tested with software tools were measured, meaning conformance with a significant number of checkpoints, and hence a true level of accessibility, could not be assessed.
Witt and McDermott  carried out two surveys using similar methodologies to Kelly; they also found that some institutional home pages met the Priority 1 and Priority 2 guidelines when tested with an automatic checking tool. However, they took the testing further and assessed home pages (both automatically and manually) against their declared level of compliance. They found that only 58 of the 80 they tested actually complied with the standard to which they aspired.
Why Make a Statement about a Web Site's Accessibility?
Web developers and managers should realise that more emphasis is being placed on their Web sites as a medium for information transmission. They are often an extension of the prospectus and sometimes the first time a student 'sees' an institution it is through a computer monitor. It is essential that institutions realise that this 'front door' will sometimes need a ramp.
Because of this an institution needs to understand the importance and implications of making a public statement about the accessibility of their Web site. Amongst other reasons, this will ensure that potential students with accessibility issues understand what is being done and what they can expect, in the same way that a prospectus carries information about aspects of student life other than the courses available. In addition, it is important that institutional staff know about the aspirations of the institution and understand their role in achieving them. This is essential if staff are required to publish material for students on the Web site. But, perhaps cynically, the statement is a first and obvious step to take in ensuring that the institution understands, and is meeting, its obligations under the DDA.
Text-Only and Web Site Logos
Throughout the Internet there are a growing number of Web sites offering specific 'disabled access'. These are almost always a text-only version of the existing Web site, in many cases preserving accessibility problems in the alternative site, and often appearing to consider blind people as the only group affected by accessibility problems. If Web sites are to become socially inclusive, all users must be able to enjoy shared experiences. Logos and signs pointing to a separate resource serve only to segregate the experiences of users and further exclude the disabled community. A metaphor that is being increasingly used to illustrate this point is that of a wheelchair user going to the theatre to be told that they must watch the play through a closed circuit television in the cloakroom because the main auditorium is inaccessible.
Web managers should also be wary of displaying a large variety of icons to indicate the level of accessibility they have reached - logos can easily become false indicators as soon as a change is made to a page which - usually inadvertently - introduces an accessibility barrier. Unfortunately there are people who seem to delight in publicly shaming sites which, though displaying a W3C WCAG icon, have slipped up somewhere .
TechDis also discourages the excessive and inappropriate use of logos denoting that Web sites are 'disabled friendly' . The use of a logo in many cases appears to be a contractual obligation or badge of honour for the developer, but can at best be seen as patronising and at worst as offering no true reflection of the usability of the site for a disabled person. Thatcher  describes how a site can be designed apparently following accessibility guidelines to the letter, yet spectacularly fails to provide an acceptable browsing experience for disabled visitors.
It is important to remember that social inclusion is more than an exercise in paying lip-service to what has been done for disaffected communities; it is about ensuring equity of service and standards. Web developers are now feeling the effects of the social inclusion agenda, but with a community of technologists that are used to innovation and change inclusive practice is only another milestone on the road to good and equitable practice.
Current Web Accessibility Information on UK Higher Education Institutions (HEIs)
So what is the current level of information about accessibility of UK HEI sites?
Of the 163 HEI Web sites accessed between September and October 2003, 88 (54%) were found to have some level of accessibility information on their public Web site. The information was of varying depth and quality, some were very structured policy documents linked to strategy and staff development, whilst some only made a broad statement about staff being mindful of disabled students' needs. Text-only 'alternate' Web sites were found in 44 HEIs - these are generally advertised as accessible versions of the main site.
Of the range of accessibility advice publicly available on institutional Web sites much of the material was aimed at the users of the Web site, informing the user of the lengths to which the institution had gone to ensure access and how to get more out of the features available. In addition institutions also provided material aimed at staff that published material on the Web. The approach here tended to be authoritarian informing staff of the policy and the need to ensure accessibility (usually as a result of the 'Special Educational Needs and Disability Act'). Stress was primarily placed on the need for staff to comply with the policy in order to protect the institution, but also in many cases it was explained why material should be created accessibly.
Some institutions devolved responsibility of accessibility, handing over the design and implementation of an accessible Web site to third parties, such as a Web design consultant. In many cases this involves the development of the corporate Web site and then the supplying of templates to Web managers for use by staff.
Across the 88 institutions that did have some form of information about accessibility there was no consistent reference to standards or guidelines:
- 36 referred to W3C.
- 16 referred to accessibility tools including Bobby and LIFT. This can be problematical as different tools can yield different accessibility results .
- Eight referred to SENDA compliance in meeting the requirements of disability discrimination legislation (where no direct reference to Web accessibility is made).
- 28 referred to a variety of other standards including US legislation (section 508) and 'in-house' standards.
- 19 of the 88 additionally suggested that users having difficulty accessing material should contact a relevant member of staff (such as the Webmaster).
Of the 75 HEIs that did not have a visible policy or statement, 20 were contacted via their Webmaster. Nine stated that they either had a policy that was not public or would soon be made public. Of the remaining 11, four stated that the institution had held workshops for staff or were creating resources to help staff acquire skills. This small sample of the 75 institutions with no visible policy, where almost half of those institutions contacted said that they did have some form of policy, could indicate that there is more awareness than is indicated by the original research.
Clearly, therefore, there is some scope for enhancing the information available about the accessibility of an institutional Web site, and the strategy taken to optimise accessibility of institutional Web content.
What Should a Statement Say?
The first step of any accessibility strategy should be to identify a workable yet equitable level of accessibility towards which to aim. This may be the W3C WAI guidelines 'Double-A' standard  (recommended) but other standards and guidelines are becoming available and the decision needs to be taken by the institution. Accordingly, a published accessibility statement should reflect this strategy. Be aware though, that for many disabled Web users, particularly those without expertise in Web usage and design, the statement of a W3C conformance level may be meaningless in terms of helping them to use the site. Therefore it is essential to provide, in non-technical language, information that advises on accessibility features provided.
In addition, there may be areas of the Web site that do not yet reach the aspired standards of accessibility - and due to factors such as use of complex multimedia, may never reach that level. In such a case, it is well worth mentioning them in the statement with a brief explanation of the access issues in question, and, crucially, with details of how a user can retrieve the required information or functionality in another way.
Other useful additions to the accessibility statement include:
- Details of any testing the site that has taken place with disabled users.
- Description of any assistive technologies used in testing, including any incompatibilities.
- Information about how people can change display settings, through the browser, or alternative style sheets if offered. It is extremely important that people know what they can do for themselves, by using their browser or operating system as assistive technology.
- Provide information about page layout - this can help screen reader users understand where on each page types of information are found - navigation bars, internal page navigation, form layout, etc.
It is essential to provide contact information for people to report any problems they are having or to request information in an alternative accessible format.
It is expected that an accessibility statement will be organic - changing to reflect the increasing accessibility as improvements are made.
A Cautionary Note
It is important to bear in mind that whatever is published about the accessibility of a Web site can affect users' expectations. There are indications that consumer rights and remedies are being increasingly used when contesting what is seen as inadequate provision of education services. One reason for this is that students are now making considerable payments towards their education. There is an expectation that statements made on for example an institution's Web site or in its prospectus should be accurate and should not be misleading. Advertising standards and practices also have a role to play in this. Making sweeping statements such as "we are compliant with W3C WAI 'Triple-A'" may be an admirable aspiration, but if any part of the institution's Web site does not meet this standard then there may be a legal case to answer. Using language such as " we aim to - " and "the Institution is working toward.." may be a better route, coupled with a pragmatic approach where students, potential students and other users are encouraged to contact an appropriate person at the institution if they have any difficulties accessing information. The legal issues about accuracy of this type of information are also highlighted by Cooper :
"Information given to students about IT facilities must be accurate as the provision of a particular facility could persuade a student to choose a particular course. A claim for damages could result from the failure to provide that facility."
By extension, stating that the institution's Web site is (or aims to be) accessible to a standard could arguably result in a similar scenario and the student could potentially have a legal claim for damages if his valid expectations are not in fact met. In addition use of 'notices and disclaimers' may not necessarily protect the institution from consumer protection legislation, where a disclaimer adding a caveat that some material is not accessible may be valueless if elsewhere on the site a statement claims to meet accessibility standards . Web managers should be aware that the institution may ultimately be held liable for any material published within its domain, including personal Web pages, Virtual Learning Environments and student discussion boards . If these facilities form part of the education provision and if students are encouraged to participate in or use them, then it is highly possible that the expectation of accessibility and usability is a valid one.
The Next Steps
Web managers need to be mindful of the issues raised in this article, particularly with regard to the expectations of students and potential students. Disability discrimination legislation has placed a clear responsibility on Web developers. Yet embedding the accessibility of the disparate elements of an institutional Web site into a strategy is not a simple task and involves, in the short term, ensuring that issues such as staff development, purchasing of resources and tools as well as development of materials are all included. Eventually, the ideal way of ensuring sustainable Web accessibility is to embed it in other strategies, e.g. staff development strategies, ICT and e-learning strategies, and information strategies.
However, in the short term, Web managers should take a series of steps:
1. Re-examine existing Web accessibility statements, ensuring they are user-focussed as discussed in this article.
1.1. This may mean examining all accessibility statements within the institution's domain (including those within VLEs).
1.2. Web managers should involve the institution's legal team and other appropriate committees.
2. Review institutional statements on equal opportunities and disability.
2.1. This is essential in ensuring consistency across the information that is provided. For example, a prospectus may state that the institution is sensitive to the needs of students with disabilities and they can expect adjustments to the way their courses are organised, taught and assessed. This would obviously have an implication if any part of it involved using the Web as a medium.
3. Decide on an appropriate level of accessibility that the institution should aim for.
3.1. Base the level on appropriate information. TechDis and other bodies recommend the W3C guidelines . However, there are other guidelines such as the UK Government's own standards  and it must be an institutional decision as to which are adopted.
3.2. Ensure that the chosen strategy is workable across sectors - do not introduce an inflexible level; that may result in some pedagogically valuable resources having to be removed, and in general may result in demotivation amongst staff.
3.3. Many institutions are using tools as a compliance measure, such as 'Bobby compliant'. While very useful in discovering, and in some cases repairing, certain accessibility features, these tools require a great deal of subjective assessment and claiming compliance could be challenged in the subjective areas.
4. Deploy the statement across all sectors of the institution.
4.1. This will ensure that all staff are aware of what prospective students are being told, and what they should be aiming for with any e-materials they are developing.
4.2. The statement should also be reflected in the institutional strategies on ICT, e-learning and any other appropriate areas upon which accessibility will have an impact.
5. Work with the staff development unit to ensure that appropriate workshops and training are available for staff involved in development.
Finally, Web managers should not attempt the task on their own. Only by working with other areas of the institution, such as disability support, staff and educational development, e-learning units and senior managers with responsibility for ICT, can institution-wide Web accessibility be achieved and maintained over time.
- Quality Assurance Agency [online] (1999) Code of practice for the assurance of academic quality and standards in Higher Education, section 3: students with disabilities http://www.qaa.ac.uk/public/COP/COPswd/COP_disab.pdf [accessed 30.09.03]
- Sloan, M. [online] (2002) Institutional Web sites and Legislation http://www.techdis.ac.uk/resources/msloan01.html [accessed 02.09.03]
- Willder, B. (2002) 'Disability legislation: implications for learning technologists in the UK'. In: Access All Areas: disability, technology and learning, Phipps, L., Sutherland, A. and Seale, J. (Ed.) ALT/JISC/TechDis. pp. 6 - 9
- Kelly, B. [online] (2002) WebWatch: An Accessibility Analysis Of UK University Entry Points Ariadne Issue 33. http://www.ariadne.ac.uk/issue33/web-watch/ [Accessed 30.09.03]
- Diaper, D. and Worman, L. (2003) Two Falls out of Three in the Automated Accessibility Assessment of World Wide Web Sites: A-Prompt v. Bobby. in Johnson, P. and Palanque, P. (ds.) People and Computers XVII. Springer-Verlag.
- Witt, N. and McDermott, A. (2003) What logo shall we use today, British Journal of Educational Technology (in press)
- Sloan, D. and Phipps, L. (2003) Helping to Avoid e-Discrimination in UK Tertiary Education. Proceeding of ACM Conference on Universal Usability 2003.
- Thatcher, J. [online] (2003) Web Accessibility - What not to do http://jimthatcher.com/whatnot.htm [accessed 19.11.03]
- W3C (1999a) Web Content Accessibility Guidelines 1.0
http://www.w3c.org/TR/1999/WAI-WEBCONTENT-19990505/#Conformance [accessed 16.10.03]
W3C (1999b) Fact Sheet for "Web Content Accessibility Guidelines 1.0",
http://www.w3.org/1999/05/WCAG-REC-fact.html [accessed 30.09.03]
- Cooper, C. [online] (2003) Legal Risks and Liabilities for IT Services in Higher and Further Education http://www.jisc.ac.uk/legal/index.cfm?name=lis_legal_risks [accessed 10.11.03]
- Sutter, G. [online] (2003) FE/HE Institutions and Liability for Third Party Provided Content http://www.jisc.ac.uk/legal/index.cfm?name=lis_gs_content_regulation [accessed 14.11.03]
- Office of the e-Envoy (2003) Guidelines for UK Government websites. Cabinet Office, London