Digital inclusion and accessibility guidance

Introduction and purpose 

The digital inclusion and accessibility guidance describes The University of Manchester’s (referred to as “The University” in the following document) approach to being digitally inclusive and accessible. It represents our belief in our equality, diversity, and inclusive values. It supports the requirements set out by the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (referred to as “PSBAR2018” in the following document). PSBAR 2018 builds on The University's existing responsibilities around the Equality Act 2010. The regulation helps us realise our EDI goals by giving us a clear framework to adhere to. 

The PSBAR 2018 regulations require: 

1. full conformance to Web Content Accessibility Guidelines (WCAG) version 2.2 Level A and AA. It is The University’s responsibility to ensure it is compliant with the correct version. The next WCAG change is expected to be around 2030. 
2. individual digital systems (described in scope) must publish an Accessibility Statement that explains their level of compliance with WCAG, as well as all other required sections. 
3. the Accessibility Statement must be renewed every 12 months, or when the digital system is substantially updated 
4. The Accessibility Statement must be in the required format as laid out in: 
   1. Model accessibility statement
   2. Sample accessibility statement 

To give additional context to this guidance, it is similar to General Data Protection Regulation (GDPR), in that all relevant parties need to adhere to it, to make sure The University is meeting its legal obligations.

Scope and definitions

2.1 The guidance is for everyone who works with digital systems, communications or media, including documents, emails, content, systems, web applications or mobile applications that are procured, created, developed, managed, or paid for by The University (including funded partners on behalf of The University). Including those hosted on a system within The University network, or any digital experience produced in association with the brand of The University. 

2.2 A digital system includes but is not limited to: 

• websites 

• internally developed web-based systems 

• procured web-based systems 

• hosted documents 

• hosted content  

• email content 

• internally developed mobile applications 

• procured mobile applications 

2.3 For the purposes of this guidance, a 'digital system' is any information technology system that is accessed using a web browser, or mobile application that is for an internal or external audience (for example staff, students, researchers, partners, and members of the public). The guidance applies to all interfaces operated by a person, including administrative user interfaces. 

Out of scope 

2.4 Any digital system that is not procured, funded, developed, maintained or controlled by The University is outside the scope of this guidance. 

2.5 If a digital system does not clearly fit this scope statement, The Design, Usability and Inclusion Team will help determine whether it should be included as a system that must meet the standards set out in this guidance. 

2.6 PSBAR2018 has digital content that isn’t in scope, these include: 

• files published before 23 September 2018 (unless needed as part of an active process related to tasks performed by The University); 

• audio and video content published before 23 September 2020;  

• live video and audio streams;  

• online maps and mapping services, if the information on the map is provided in an accessible format alongside;  

• third-party content that is neither funded, developed or under the control of The University;  

• reproductions of items in heritage collections that cannot be made accessible without compromising the integrity of the item or without significant investment; and content qualifying as ‘archives’, meaning it is not needed for an active process and is not edited after 23 September 2019.  

2.7 Even where a digital system is outside the scope of this guidance, its accessibility should be considered, including provisions made for reasonable adjustments, and alternative formats where it cannot be made accessible to the WCAG 2.2 standard.

Roles and responsibilities

3. This is a summary of the roles who are required to comply with this guidance within The University:
   • Product owners
   • Service managers
   • Project managers
   • Business analysts
   • Front end developers
   • User interface developers
   • User experience designers
   • Content authors
   • Testers
   • Test managers
   • Procurement managers
   • Procurement officers
   • Contract managers
   • Partners of The University
   • Suppliers to The University 

If your role is not in the above list, and you are in any doubt, contact The Design, Usability, and Inclusion Team (duiteam@manchester.ac.uk) for advice to ensure that the guidance doesn't apply to you.

General principles 

4.1 The University will comply with The Regulations and all relevant legislation. It will ensure any changes to regulation are considered in a timely manner and review guidance and controls accordingly.   

4.2 Digital systems will be procured, developed, maintained and managed by The University to comply with The Regulations.    

4.3 Anyone creating content for a digital system owned or maintained by The University must follow the principles outlined by WCAG 2.2 and all relevant accessibility best practice, training and guidelines.   

4.4 The University must audit all relevant digital systems, communications and services for compliance with PSBAR2018.  

4.5 The University will provide all necessary accessibility compliance information required by PSBAR2018 regarding any of its digital systems in the form of an Accessibility Statement available via the digital system’s interface.   

4.6 Where The University cannot achieve a Compliance Status of 'Fully compliant' with WCAG 2.2 to A and AA, it must commit to mitigating, resolving or identifying alternative versions for the identified accessibility issues in a specified period of time. Where The University cannot commit to resolving accessibility issues it must make a 'Disproportionate Burden' claim as part of its Accessibility Statement. 

4.7 Any digital system or content within The University that cannot be made accessible should be referred to The Design, Usability and Inclusion Team, who can refer the system to the most relevant risk management process for the specific non-compliance. This may be escalated further within The University for action.  

4.8 The University will provide a mechanism for end users and the CDDO to report accessibility issues with its digital systems.  

4.9 The mechanism for reporting accessibility issues through the following email address: accessibility@manchester.ac.uk. Any accessibility issues reported through the email address will be acknowledged, logged, and forwarded to the owner of the digital system. 

4.10 Anyone who manages contracts or procures new digital systems and services must make sure that contractors and vendors comply with our obligations under The Regulations; they must also actively manage any identified accessibility issues until they are resolved. All contracts relating to digital systems and content must include appropriate regulatory compliance requirements.   

4.11 Anyone has the right to challenge the level of accessibility of our digital systems and the impact of any constraints outlined in this guidance. Such challenges will be dealt with appropriately through reporting mechanisms also outlined in this guidance.  

4.12 The University supports the principles set out by WCAG 2.2, Levels A, AA and AAA. Where A and AA are the minimum legal requirements. It will maintain process and procedures for monitoring the quality and compliance of its digital systems.  

4.13 Anyone who procures, manages or maintains digital systems must meet our obligations under the current legislation and actively manage any accessibility issues identified until they are mitigated, resolved or explicit alternative versions are identified. This includes a plan for auditing systems and updating accessibility statements annually, or when they are substantially updated.

Disproportionate burden 

4.14 The Regulation does not require The University to comply with the accessibility requirement if doing so would impose a disproportionate burden. A disproportionate burden claim is part of the Accessibility Statement and is where the cost of making the system accessible is disproportionate to the value that would be gained by persons with disabilities. 
 
4.15 To make a claim for the relevant digital system, The University must perform an assessment of the extent to which compliance with the accessibility requirement imposes a disproportionate burden. 

4.16 In undertaking such an assessment, The University must take account of relevant circumstances, including— 

(a) the size, resources, and nature of digital system in The University and 

(b) the estimated costs and benefits for The University in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the specific website or mobile application. 

(4) If, following the assessment, The University determines that compliance with the accessibility requirement would impose a disproportionate burden, it must— 

(a) explain in its Accessibility Statement the parts of the accessibility requirement that could not be complied with; and 

(b) where appropriate, provide accessible alternatives to documents held by that public sector body that are not available on their website or mobile application. 

4.17 If, following the assessment, a public sector body determines that compliance with the accessibility requirement would impose a disproportionate burden, it must— 

(a) explain in its accessibility statement the parts of the accessibility requirement that could not be complied with; and 

(b) where appropriate, provide accessible alternatives to documents held by that public sector body that are not available on their website or mobile application. 
 

Monitoring, compliance, and mandated time frames 

End-user reports 

5.1 If an end user reports an accessibility issue with a digital system, The University must manage the report within the mandated time frames of: 

• 28 days to acknowledge receipt of the report 

• 12 weeks to resolve or mitigate the issue to a satisfactory resolution 

5.2 If reported issues remain unacknowledged or unresolved following this period, the end user can escalate the issues to the Equality Advisory and Support Service (EASS), who can refer the issues as a complaint, to the Equality and Human Rights Commission (EHRC) for action. 

UK Government reports 

5.3 The Central Digital and Data Office (CDDO) actively monitors compliance with The Regulations and will perform periodic compliance audits on The University’s digital systems. When issues of non-compliance are reported, The University must manage the report within mandated time frames of: 

• 7 days to acknowledge receipt of the report 

• 12 weeks to resolve or mitigate the issue to a satisfactory resolution 

5.4 If reported issues remain unacknowledged or unresolved following this period, The CDDO will escalate the issues as a lack of compliance with PSBAR2018 to the EHRC may choose to start legal proceedings under The Equality Act.  

Non-compliance risks

5.5 Failure to adhere to this guidance is an infringement of PSBAR2018 regulation and may result in reputational damage, and unlimited financial loss to The University. 

5.6 The EHRC have the power to impose an unlimited financial penalty on The University for each complaint that is unresolved in the mandated timeframes set out above.