Accessibility in procurement
‘Accessible design is good design’ (United Kingdom 2015) therefore if a product or service is designed to be inclusive from the ground up it will be pure in its function and easy to use for everyone.
The Accessibility in Procurement guidance below will enable us to ensure that Kent’s commitment to Equality, Diversity and Inclusivity (EDI) is made clear to suppliers of University systems in the first phases of procurement and help to raise awareness of key inclusivity criteria to factor into the development of both functional and non-functional requirements for any new system or digital service.
The national eBook accessibility audit is a joint project across UK Higher Education Institution (HEI) disability and library services that has developed an eBook accessibility audit to help publishers and aggregators improve the accessibility of their platforms and educational institutions evaluate accessibility features to inform procurement. The audit focuses on eBooks supplied to the education sector in the United Kingdom (rather than books for mainstream commercial consumption e.g. popular fiction).
- Questions about the supplier
- Questions about the product/service
- Guidance on answers to questions about/for the supplier
- Guidance on answers to questions about the product/service
- Procurement checklist – guidance notes
- Four Principles of Accessibility
- Understanding accessibility and inclusive design
- Quick accessibility assessment for online learning platforms
- Advice for procurement of specific platforms and systems
- Is Equality Diversity and Inclusivity relevant to this procurement?
- Equality impact assessment
- Using personas
- Testing accessibility
Questions about the supplier
- Looking at our institutional strategic plan outline the key principles which demonstrate your own organisational approach to equality, diversity and inclusivity (EDI), providing evidence to support your comments.
- Tell us about the EDI training your staff are required to complete and any additional activities you undertake to raise awareness.
Questions about the product/service
- What are the key accessibility features of the product or service? In addition please tell us how the following accessibility features are supported (where appropriate):
- Page magnification so you can zoom in on images and/or text.
- Text magnification to 25 point text equivalent or more.
- Text reflow so that as text is magnified the lines rewrap to fit the size of the screen, reducing the need for left-right scrolling.
Text to speech
- Text can be selected and used with text to speech tools.
- Text can be copied to the clipboard for use with a clipboard reader or third party text to speech tool.
- If a version is available for mobile devices it integrates with any inbuilt text to speech functionality in the operating system.
- There is an inbuilt text to speech feature.
- Users can navigate by meaningful signposts including interactive links to:
- Section headings and subheadings.
- There are keyboard shortcuts and alternatives for non-mouse users:
- The tab order is logical.
- Skip links enable keyboard only users to quickly get to the body text.
- Users can change text appearance including:
- Default font size.
- Font type.
- Font colour.
- Background colour.
- Non text media has alternative descriptions:
- The key teaching points of images are available in captions, Alt tags or the body text.
- The key teaching points of video or audio are available as summaries, transcripts or subtitles as appropriate.
- Formulae and equations are rendered in MathML.
User testing and guidance
- The resources have been tested with users that have a range of accessibility needs using a range of assistive technologies (AT)?
- What assistive technology was tested and who did the testing?
- What were the key outcomes?
- Describe how accessible your product would be to [example persona e.g. visual, auditory, cognitive or motor] see University of Kent example personas.
- When you release upgrades how can you assure us they will not have a negative impact on accessibility?
- There is an easily discovered help page where guidance on the above can be found.
- Please tell us about any standards that the product has been designed to meet e.g. WCAG 2.0 AA, BS8878, EN 301 549)
- A useful introduction to WCAG can be found on the Web Accessibility Initiative (WAI) Home. The BS8878 code of practice applies to all products delivered via a web browser, including websites, web services and web-based applications such as email. BS 8878:2010 is designed as an introduction to digital accessibility for non-technical professionals. EN 301 549 European Standard on accessibility requirements for Information and Communication Technologies (ICT) products and services.
Guidance on answers to questions about/for the supplier
- A good answer would show that they have clearly engaged with our strategic principles and have a good understanding of our ethical and operational standards. This should be followed by a clear statement that demonstrates their own commitment to EDI evidenced by links to policy documentation to support it.
- An organisation that embeds EDI training for staff shows a clear commitment to paying more than lip service to EDI. Evidence of training programmes schedules and PowerPoint files would be good indicators of this kind of commitment.
Guidance on answers to questions about the product or service
- The supplier should include a list of the accessibility features of the product and supply clear guidance on how to use them alongside details of how the product or service has been adjusted to account for accessibility. For online platforms you may wish to seek specific reassurances in relation to Jisc's accessibility assessment criteria (inlcuded below) to ensure that basic accessibility functionality such as magnification/reflow, reformatting e.g. convert text to speech, change appearance e.g. recolour are all accounted for and that systems have been tested by users of assistive technology. It may also be useful to consider the following inclusive design principles when seeking and evaluating supplier feedback.
- Many of the major standards for accessibility are extremely rigorous. Any supplier that is able to describe how they are developing their product in accordance with them will be on their way to excellent accessibility. Be careful that suppliers do not just say that they are 'aspiring' to a particular standard however. Wherever possible ask for evidence to show current accessibility maturity.
- Ultimately, the best way to understand if products are truly inclusive and accessible is to involve protected characteristics groups in all stages of design, testing and ongoing development of systems. A clear commitment to this kind of engagement and a process for acting on feedback received is representative of a supplier actively engaged in a positive EDI agenda. It would be helpful for the supplier to provide clear information about the specific assistive technology that was tested e.g. Jaws, NVDA, Apple Accessibility tools and who was involved e.g. visually impaired users, specific learning difficulty groups.
- This kind of question is an opportunity to prompt a flexible response and enable them to demonstrate how the particular features of their product are accessible to particular kinds of requirement. You may wish to specify that they provide a response for each category e.g. visual, auditory, cognitive or motor to show how they product is accessible across a range of disabilities.
- A good answer here would indicate a robust quality assurance workflow that will anticipate all potential impacts in their own equality impact assessment for the upgrade.
Procurement checklist – guidance notes
Understanding accessibility and inclusive design
- An accessible/inclusive product or service is one which can be used by all its intended users, taking into account their differing capabilities.
- Products that have been designed inclusively will be readily adaptable to the different requirements of a wide range of users and the technologies they will be using.
- Ultimately, the best way to understand if products are truly inclusive and accessible is to involve people from protected characteristics groups in all stages of design, testing and ongoing development.
Four principles of accessibility
The Web Content Accessibility Guidelines (WCAG) provide a useful framework for reviewing basic accessibility targets for a range of online platforms. The following principles offer a useful starting point for thinking about how accessibility issues may affect electronic systems being procured:
Information and user interface components must be presentable to users in ways they can perceive. This means that users must be able to perceive the information being presented (it can't be invisible to all of their senses).
- Text Alternatives: Provide text alternatives for any non-text content so that it can be changed into other forms people need, such as large print, braille, speech, symbols or simpler language.
- Time-based Media: Provide alternatives for time-based media.
- Adaptable: Create content that can be presented in different ways (for example simpler layout) without losing information or structure.
- Distinguishable: Make it easier for users to see and hear content including separating foreground from background.
User interface components and navigation must be operable. This means that users must be able to operate the interface (the interface cannot require interaction that a user cannot perform):
- Keyboard Accessible: Make all functionality available from a keyboard.
- Enough Time: Provide users enough time to read and use content.
- Seizures: Do not design content in a way that is known to cause seizures.
- Navigable: Provide ways to help users navigate, find content, and determine where they are.
Information and the operation of user interface must be understandable. This means that users must be able to understand the information as well as the operation of the user interface (the content or operation cannot be beyond their understanding):
- Readable: Make text content readable and understandable.
- Predictable: Make Web pages appear and operate in predictable ways.
- Input Assistance: Help users avoid and correct mistakes.
Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies. This means that users must be able to access the content as technologies advance (as technologies and user agents evolve, the content should remain accessible):
- Compatible: Maximize compatibility with current and future user agents, including assistive technologies.
Quick accessibility check for online learning platforms
JISC (2015) advise that the following basic checks would help to identify 'common barriers' in relation to online platforms:
- Can font size be easily changed?
- What is the maximum point size equivalence?
- Does text reflow when enlarged?
- Can the user change background/foreground colours or contrasts?
- Are there keyboard shortcuts for all mouse actions?
- Is the tab order sensible (if you press Tab to navigate from one part of the page to the next)?
- How many tabs does it take to get to the accessibility information?
- Are pages marked up so they can be navigated in a meaningful way – either by heading level or by hyperlinks.
Alternative text descriptions
- Are text descriptions available for graphics and images?
- Is it easy to link a transcript or summary to a video podcast?
- Where do you provide user friendly guidance on the accessibility features you have incorporated into your system?
Where platforms are delivered as web pages reassurances about core standards e.g. WCAG 2.0 AA compliance should be sufficient to address many of the items above. A very thorough set of example criteria for database platforms and full text platform assessment are included in the Open University's accessibility requirements database document. The current accessibility features of learning platforms have been published on the Open University's databases with accessibility issues pages.
Advice for procurement of specific platforms and systems
The following are links to helpful guidance to inform procurement of different types of platforms and systems giving helpful questions thinking:
E-book platforms should allow users to modify the content to best suit their accessibility requirements. Typically this will mean that e-book platforms should facilitate:
- Are text descriptions available for graphics and images?
- Is it easy to link a transcript or summary to a video podcast?
- Magnification/reflow: text should be able to be enlarged significantly without losing context on the page. The content should be responsive to magnification in order that each line can be viewed in full without the requirement for horizontal scrolling.
- Colour and contrast changes should be supported.
- Navigation: users should be able to navigate without the use of a mouse.
- Text to speech: Text should be able to be read by screen readers. Often digital rights management (DRM) restrictions mean that this functionality can be 'tuned out' and electronic scans are represented as 'image only' with no selectable text.
- Alternative text descriptions: should be provided for all images, charts and diagrams.
- Testing: platforms should have been developed with users and tested with key assistive technologies.
- Clear guidance should be provided on how to use accessibility features.
An excellent guide to assessing the accessibility of e-book platforms is available from Jisc.
Below are links to useful guidance for reviewing the following platforms:
- Virtual Learning Environments (VLE) Moodle accessibility guidance
- Web Technologies
- Public Access Terminals
- Application Software
- Smart Cards
Is Equality Diversity and Inclusivity relevant to this procurement?
Equality, diversity and inclusivity are core to both University and IS strategy and therefore all projects and procurement should necessarily consider what the equality, diversity and inclusivity impacts may be.
Some example scenarios for IS projects and with potential EDI impacts are already addressed in the IS Project Management Wiki under Equality Diversity and Inclusivity (EDI) in projects.
The steps below will help refine thinking to understand how to determine particular barriers to anticipate for different types of procurement:
Equality Impact Assessment
A useful way to begin thinking about the EDI of proposed procurement would be to undertake a small scale equality impact assessment to assess if there might be any adverse impacts on people with protected characteristics:
Equality Act 2010: protected characteristics
- marriage and civil partnership.
- sexual orientation.
- religion or belief.
- gender reassignment.
- pregnancy and maternity.
Questions you may wish to ask in a basic equality impact assessment might include:
- Are there any concerns or is there evidence that this procurement could have an impact on people due to their protected characteristics?
- The procurement of a server that hosts content but requires no direct interaction with end users has fewer equality, diversity and inclusivity (accessibility) concerns than an e-learning platform/ 'web products' (BS8878:2010, p.9) that may be directly engaged with by people from all protected characteristic groups.
- Could this impact amount to an adverse impact?
- What are the needs of the users? From a disability perspective, this means understanding the accessibility requirements of users to determine what you will require from the supplier. You may also wish to consider for example if a licence will include access at remote campuses.
- Can the procurement be altered (in terms of objectives or specification) to eliminate the adverse impact and still meet the overall aims?
- Invite protected characteristics groups to give feedback on what you intend to do and what you intend to provide and then ask what impact this will have on them. The feedback you get from protected characteristics groups will help inform the specifications that you require from your supplier. Some suppliers will also allow you to try a product first (in which case, you can ensure protected characteristics groups are involved in trials).
To undertake a more in-depth analysis the ECU (2012, p.49) have developed a Relevance Assessment Tool to help decide how to review EDI procurement considerations for protected characteristics groups. Further information about equality impact assessments can be found here: ECU (2007) Conducting equality impact assessments in higher education. The University of Kent also provides access to Equality, Diversity and Inclusivity e-Learning modules one of which covers the topic of equality impact analysis.
The BS8878 Code of Practice recommends that using personas can be a helpful way to visualise disabled users requirements:
Personas are precise descriptions of a model user from each target audience and what they wish to accomplish with the web product. Personas can serve as an aid to summarizing and communicating an audience's defining characteristics and needs (BS8878:2010, p.11).
The web user experience team have created some excellent in-house personas for guidance (see University of Kent example personas).
Question 4 in the checklist is an opportunity to prompt a flexible response and enable suppliers to demonstrate how the particular features of their product are accessible to particular kinds of requirement.
- A range of useful online resources can support basic 'do it yourself' testing of online platforms. These may be particularly useful for testing in-house developed systems. For third party procured systems it is clear that the ultimate responsibility for inclusivity rests with the supplier.
- Web 2 Access offers a holistic approach to understanding how easy to use online platforms may be.
- WAVE is tool to help web developers make their web content more accessible. A range of really helpful resources are available on the WebAIM site such as the WAVE colour contrast checker.
- Some practical advice on testing platforms with screen readers can also be found in the Government Service Design Manual.
- If you are a Kent member of staff and would like help resourcing module reading in alternative formats for students with print disabilities follow the guidance in the Kent Alternative Formats Process (docx).
- Creating accessible documents, presentations and spreadsheets.
- Kent Inclusive Practices (KIPs).
- To find out more about accessible information and technology at Kent contact us.