Who is accountable for the accessibility of your website?

In your organisation who is actually accountable for the accessibility of your website? If the answer is “not sure” or “it falls between four different people” or “something we’ve still to decide” or “nobody” then it possibly means your organisation hasn’t thought about digital accessibility properly.

 A website which is not compliant with accessibility standards may well be illegal and failing a significant proportion of your users. In this post we’re going explore why having a named person as accountable for website accessibility is important for achieving compliance and improving accessibility on your digital channels.

Why must someone be accountable for website accessibility?

Most organisations make someone accountable for an issue or area where there is a significant risk attached. There is significant risk attached to website accessibility, both from the chance of legal action and the related negative outcomes such as brand or reputational risk.

Making your website and digital channels accessible is a necessity, not a ‘nice-to-have’. It is a legal and / or regulatory requirement for many sectors (including the UK public sector) and is a growing focus for legal action In the US. The number of federal website accessibility lawsuits have tripled from 2018 compared to 2017; we’re still waiting for the 2019 results but they are likely to indicate another rise.

Having a named person who is accountable for this website accessibility helps to:

• Highlight accessibility compliance as a significant risk issue
• Make sure it is not deprioritised or forgotten about
• Makes accessibility more “tangible”
• Helps to ensure appropriate actions are taken to reach and maintain digital accessibility compliance
• Helps to spread awareness and knowledge about accessibility which may be missing..

What happens when you don’t have someone accountable?

The obvious danger when you don’t have someone accountable for digital accessibility is that your website is not accessible to the required level and you risk legal or regulatory action.

Despite good intentions from individuals who want to do the right thing for accessibility, not having someone accountable can mean:

• There isn’t the co-ordination present to actually reach and maintain compliance
• There isn’t the required level of knowledge amongst the team to achieve compliance
• Everyone assumes it is someone else’s responsibility so things that need to happen don’t
• There aren’t the tools, reporting and processes in place to enable compliance around digital accessibility.

What does being accountable mean?

The GDS introduction to “Making your website accessible” states that accessibility is “the whole team’s job” and that

Accessibility isn’t the responsibility of just one person. Everyone on your team is responsible for making sure your service is accessible.

This is very true, in that the entire digital team – and the extended team of anybody who contributes to your website – can create content or carry out actions that can mean a website is no longer accessible. But the danger of making everyone “responsible” is not enough to guarantee compliance and make that happen. You need someone who is truly accountable and “where the buck stops” -  a different concept to being just responsible.  

Being accountable means a person taking ultimate responsibility for ensuring something happens and taking the blame if it doesn’t happen. Being accountable for digital accessibility might not necessarily mean that person carries out the required work on the website, but it does mean they need to have a mandate from senior leadership to direct others to prioritise that work.

When someone is accountable, there is likely to be the following in place:

• Digital or website accessibility is explicitly included in their job description
• There is transparency over their areas of responsibility
• There is an explicit recognition of the levels of required accessibility, likely to be compliance with the WCAG 2.1 guidelines
• There are reporting processes in place to evaluate the accountable person’s performance in this area, likely to be through their performance review
• There are tools in place that accurately assess the level of website accessibility
• The person has significant authority to ensure actions happen that will drive accessibility compliance
• They understand the concepts behind accessibility, what is required in terms of the law and the risks of not being compliant.

Who should the accountable person be?

There are no specific rules about who the accountable person should be but they should be of significant seniority, perhaps at the C-suite or Director level. For example, they may be the head of the department that manages the website, such as a Director of Marketing, or an individual who is generally responsible for areas of risk and has recognised authority within the organisation. For example, they may be part of, or responsible for, your legal and compliance function.

Again, its worth stating that the person who is ultimately accountable is probably not the person who is the “doing” person. It may be that there is a person who is mainly responsible for website accessibility because of their role – likely to be your website manager or product owner – and that this is written into their job description. However, the accountable person needs to be of a seniority level to recognise the risk involved and the importance of this issue.

Using a RACI Matrix

A “RACI Matrix” can be a useful framework to consider the roles and responsibilities of all  your stakeholders and team in website accessibility and its constituent tasks. A RACI matrix states who is:

• Responsible, for carrying out actions
• Accountable, for making this happen
• Consulted – who needs to be consulted if you are making changes to the way you deal with website accessibility, for example
• Informed – who needs to be kept in the loop about matters relating to website accessibility.

In this way you may be able to define more precisely the roles of the digital team, as well as those in legal and compliance roles, your IT or user experience team and even your Diversity & Inclusion Officer. It will also spell out who is ultimately accountable.

Next time: supporting accountability around digital accessibility

Of course, making someone accountable does not guarantee website accessibility and compliance, although it is an important step. In the next article we’ll look at all the ingredients that need to be in place to support someone being truly accountable including reporting, measurement and tools.