ADD2424 Accessibility auditing and specialist advice

1.1. The 2018 Regulations – The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 – are there to ensure public sector websites are useable by all, including those with temporary or permanent disabilities. Websites published on or after 23 September 2018 have been required to comply with the Regulations since 23 September 2019. Any other public sector websites (such as the GLA’s) have a further year, until 23 September 2020, to comply, and public sector mobile apps must be accessible by 23 June 2021.

1.2. Public sector bodies are required to publish an accessibility statement on compliance with the accessibility requirement and keep that statement under regular review. These requirements are already being built into the GLA’s new proposals at commissioning stage and via testing during the development cycle.

1.3. London.gov.uk is a large and complex site and while it was originally built in 2014/15 to meet the accessibility guidelines at that time, the accessibility of all sites tends to diminish over time as content changes and new functionality and products are introduced – especially with involvement of multiple editors and suppliers.

1.4. Accessibility testing is a very specialised field - expert knowledge is required to understand the guidelines and recommend design solutions that will work, as well as for testing across different platforms and assistive technologies, such as screen readers and voice recognition software.

1.5. Commissioning an agency to carry out auditing and expert testing will help ensure that the GLA identifies any areas that need to change to achieve compliance with the Regulations and to meet the specified deadlines. In doing so we will improve user experience across our digital products, services and information for all Londoners; accessibility is good for all users.

1.1. The audit and expert review will provide a clear and detailed report with insights and data that can be actioned and built into our website development work programme to ensure the GLA is complying with the 2018 Regulations.

1.2. It will also support future capacity development. Partnering with an expert who can provide technical advice and training across content, design and development will help to develop the capacity, skills and knowledge within the GLA. This will ensure we maintain and continue to develop our digital products, so they are as inclusive as possible for all Londoners.

3.1. This work supports the aims of the Mayor’s Equality, Diversity and Inclusion Strategy, in actively reducing barriers to accessing digital services for people with accessibility needs and will ensure content from the GLA is as accessible as possible.

3.2. Under section 149 of the Equality Act 2010, as a public authority, the GLA (including the Mayor of London) is subject to a public-sector equality duty and must have ‘due regard’ to the need to (i) eliminate unlawful discrimination, harassment and victimisation; (ii) advance equality of opportunity between people who share a relevant protected characteristic and those who do not; and (iii) foster good relations between people who share a relevant protected characteristic and those who do not. Protected characteristics are age, disability, gender re-assignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status (all except the last being “relevant” protected characteristics).

3.3. This work will enhance the GLA’s reputation as a provider of accessible services. The accessibility audit is a fundamental step to ensuring the GLA’s websites cater for all users, including those that may have disabilities.

Key risks and issues

4.1. There are numerous risks associated with not following the suggestions outlined in this decision; Without the accessibility audit we will not know any areas where the GLA is non-compliant with the 2018 Regulations.

4.2. Without a review of the digital estate there is a risk that future websites will not properly serve the GLA or Londoners. Currently around half a million people visit our digital estate every month, viewing more than two million pages. The websites are a key engagement tool for the GLA, as well as being a growing provider of services and information. Our websites must be built on research to ensure they can fully support the GLA’s priorities, the policies of the Mayor and the requirements of the London Assembly. Links to Mayoral strategies and priorities

4.3. This decision supports Inclusive London, the Mayor’s Equality, Diversity and Inclusion Strategy, by ensuring our digital information and services are as accessible as possible.

5.1 Approval is sought for expenditure of up to £50,000 to appoint an Accessibility Agency to provide

advice and accessibility testing for the London.gov.uk digital estate.

5.2 The expenditure will be funded by the 2019-20 financial year Corporate Contingency.

6.1. As a public sector body, the GLA must comply with the 2018 Regulations .

6.2. The 2018 Regulations create an “accessibility requirement" for public sector bodies to make their websites and mobile applications “perceivable, operable, understandable and robust” for people with disabilities in particular. They build on existing obligations that public bodies have under the Equality Act 2010 which provides that all UK service providers must consider ‘reasonable adjustments’ for disabled people.

6.3 The Government Digital Service will monitor compliance with the 2018 Regulations and the Equality and Human Rights Commission will enforce the 2018 Regulations.

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