Accessibility regulations: disproportionate burden assessment

Find out how we're checking our websites for accessibility issues, and what we consider to be a disproportionate burden.

Suffolk County Council is committed to meeting its legal obligations set out in the The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("No. 2 Regulations"). 

However, we have a complex collection of websites and limited resources to check them all for accessibility issues.  

You can read our approach to checking our websites, and how we've assessed what we consider a disproportionate burden. 

Our approach to carrying out accessibility checks

We've decided to use a combination of methods for our organisation, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the No. 2 Regulations. 

Detailed checks

We're doing a detailed accessibility check for:

  • the main Suffolk County Council website (suffolk.gov.uk)
  • digital transactions, many of which are branded consistently with our main site or hosted as a sub-domain, e.g. apply.suffolk.gov.uk

Our sample of transactions will include highly-used services across different corporate portals and platforms, including:

The process for doing a detailed check will include:

Please note: our manual testing will also include users with disabilities and impairments, who may be using assistive technology such as screen readers. 

We believe it is reasonable to carry out a detailed check for suffolk.gov.uk and our digital transactions, as this covers the most important content provided by Suffolk County Council. 

Our accessibility statement for suffolk.gov.uk will cover problems we found for both suffolk.gov.uk and our transactions, and our plans to fix them. 

Basic checks

We'll carry out basic accessibility checks on Suffolk County Council websites that are independent of suffolk.gov.uk. 

These basic checks will be carried out by the service responsible for the website, based on:

Services will check samples of content, which will include

  • their homepage
  • content pages that are mostly text based
  • images, video and audio content
  • interactive tools and transactions, like forms
  • pages including login functionality, if the website has them
  • PDFs and other document types they have
  • dynamic content like pop-up windows
  • navigation pages, including their sitemap and pages with search functionality

Accessibility statements for these websites will be published independently of suffolk.gov.uk. 

Disproportionate burden

Checking websites

We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to pay an auditor to do a detailed check on our entire collection of websites. 

Our most important content and transactions are provided on our main website, suffolk.gov.uk, and its associated portals and platforms. We're doing detailed checks of these. 

However, we do not believe the benefit of paying for detailed checks of our other websites would justify the impact on our organisation except where those sites are specifically aimed at people with a disability.  

Fixing documents 

Having carried out a detailed check of suffolk.gov.uk, we've also assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on suffolk.gov.uk since 23 September 2018. 

The majority of these documents have never been viewed, therefore they are not 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 suffolk.gov.uk (top 10%), and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities. 

Types of website and documents 

Websites 

Suffolk County Council has more than 70 websites independent of suffolk.gov.uk. 

These sites cover a variety of purpose, size and content. Some are hosted by our organisation; others are hosted and maintained by external suppliers, and managed and paid for by an individual council service or directorate. 

Most of our independent sites are relatively small in scale, usage and complexity, and do not provide essential transactions.

Examples of these sites include: 

  • Adopt East (10 pages) which is a partnership information site managed by adoption services in the East of England
  • Suffolk Recycling (40 pages) which is waste and recycling information site managed by our Waste team
  • Healthy Suffolk (250 pages) which is a health and wellbeing information site managed by Public Health 
  • The Source (700 pages) which is a young people's advice site managed by Children and Young People's Services

Documents

As of 9 April 2020 there were 2,586 documents on suffolk.gov.uk published since 23 September 2018 (within scope of the No. 2 Regulations). 

Of these:

  • 1,600 (62%) have never been viewed
  • 2,186 (85%) have been viewed fewer than 5 times
  • 2,353 (91%) have been viewed fewer than 10 times
  • only 45 have been viewed more than 50 times

Focusing on fixing the top 10% most viewed documents is equivalent to about 260 documents. This is also about the number of documents that have been viewed more than 10 times. 

Estimated costs 

Paying for detailed audits 

We have assessed that it could cost between £66,500 and £420,000 for an external expert to do a detailed check (and later re-audit) on our full collection of 70 websites. This is assuming:

  • suffolk.gov.uk and our most essential digital transactions are excluded (as they're getting a detailed check done internally)
  • the rest of our websites were considered "small" by an auditor

If 80% of our websites were considered small and 20% were large, the cost to our organisation overall for detailed audits for all of them would be between £189,700 and £882,000

These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. This includes:

  • a third-party day rate of £1,300
  • about 1 to 3 days to audit a small website
  • about 5 to 20 days to audit a large website

Cost of fixing documents 

It's difficult to know how long it would take to make every document accessible without first reviewing each one. 

However, if it took approximately one hour to review and fix each document within scope, fixing all 2,586 would take 349 working days (based on a 7.4-hour working day at Suffolk County Council). 

Assessment of costs and benefits

We believe that:

  • The costs of paying for detailed checks for all our websites and fixing all documents on suffolk.gov.uk would be a disproportionate burden on our organisation
  • The benefit to users of paying for detailed checks on the independent websites (taking into account the frequency and duration of use of these websites) and assigning staff to fix all documents on suffolk.gov.uk (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on Suffolk County Council

In reaching this decision, we have considered the following:

Our organisation’s size and resources

Suffolk County Council is a local authority managing increasing front-line service demands (e.g. for adult social care) but reducing annual budgets.

During 2020 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services. 

The nature of our organisation

We do provide services aimed at people with a disability, but these are generally included on our main website, suffolk.gov.uk, and associated transaction platforms (which we're doing detailed checks of). 

The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the independent websites

We believe the potential of paying up to a million pounds just on audits (before we've actually fixed anything) is unreasonable.

Many of the services that maintain sites independent of suffolk.gov.uk provide front-line services to the public, e.g. social work or waste recycling.

We believe that:

  • maintaining statutory and essential front-line services should be prioritised over paying for independent website audits
  • it would be reasonable within the meaning of the No. 2 Regulations for our services to carry out basic checks of their independent websites, and use any available budget to fix the main issues found on their sites

Our services will be assisted in their basic checks by:

  • automated accessibility monitoring software (Siteimprove), for which we already pay over £6,000 annually
  • internal guidance and support from the Digital Content Team (a specialist web content and user experience team)

Our Digital Content Team (DCT) is leading the detailed check of suffolk.gov.uk and our digital transactions. However, the DCT is a small team, and the scale of co-ordinating the auditing and fixing of our main website and transactions leading up to 23 September 2020 - in addition to their other essential functions - means they lack the capacity to carry out a detailed audit of our other sites.

The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities taking into account the low level of usage for most documents 

The cost of making all documents within scope of the No. 2 Regulations on suffolk.gov.uk accessible would be approximately 350 working days. 

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. 

How much users with a disability would benefit from making things accessible

Our users will benefit from us making our websites and online documents accessible.

However, we do not believe that for the majority of our websites the extra improvements that could be gained from paying for a detailed check would justify the cost over doing a basic check internally. 

We also believe that users will benefit most from us focusing our available resources on fixing the most used documents on suffolk.gov.uk, and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.

Please note: While this assessment explains our corporate position on disproportionate burden, some services may still choose to carry out a detailed check themselves, or pay for one if they are able to budget for it.

Last updated

This assessment was last updated on 14 May 2020, and has been approved by Suffolk Legal (Suffolk County Council).