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Adam Turner

Elements that need to be in place to ensure accountability for website accessibility compliance


Website accessibility is now a significant risk issue. If you don’t have a website that complies with WCAG 2.1 guidelines you may be breaking the law, and in an increasingly litigious climate,  you are at risk of legal action. Accessibility is also very important from both a moral and commercial standpoint, although it is the risks associated with non-compliance that tends to galvanise organisations into taking action.

In our last article we looked at the advantages of having a member of your senior management team  who is accountable for ensuring your digital channels are accessible and meet all your legal and regulatory obligations. However, to make someone properly accountable you need to have several elements in place. It’s not good enough to make someone accountable and then hope for the best. In this article we’re going to look at some of the essential “ingredients” that can help support real accountability.  

1. Understanding and awareness

It is important that accessibility standards and compliance are taken seriously. Making someone accountable is a step forward, but it can smack of tokenism. Generally, a prerequisite for meaningful action is for there to be a common understanding at the senior management level about the risks of not having an accessible website, as well as all the positive benefits that flow from it.

If you have a leadership team that is aware and truly understands website accessibility, then the necessary processes that support accountability such as reporting and measurement are more likely to happen. Getting senior management to take accessibility seriously is unfortunately not a given, and it can take time to change perceptions.

2. A job description or equivalent

If a person is accountable it needs to explicit and official. This means areas of accountability need to be written down and transparent, for example included in the accountable person’s  job description.  It can also be stated within strategy or planning documents – for example this accessibility plan for the Ontario Public Service defines the senior leaders who are accountable.

3. A performance review process

Accountability has little value unless there is some process to ensure the person accountable is making things happen. Therefore, progress around website accessibility needs to be covered in any formal performance review or appraisal for the accountable person.

4. Realistic resourcing

Website accessibility doesn’t just happen by magic. As the digital rockstars we work with know, it takes persistence and some work to achieve compliance. Realistically there needs to be dedicated and realistic levels of resourcing, both for tools (for example, to deliver automated testing) and for people to fix any issues.  However, even with a modest budget you can still improve digital accessibility, fitting it proportionately with your overall website spend.

5. Reporting

You need some kind of reporting to ensure senior management is aware of progress being made with website accessibility or if there is a risk of non-compliance. Ideally accessibility should be covered in management reporting both around general risk issues as well as the success and impact of digital channels. Reporting should flag when there is an issue and if (or when) the accountable person needs to intervene.

6. Measurement

Measurement is a key part of accurately reporting around website accessibility on an ongoing basis. This is not only to track improvement with a view to achieving compliance but also to show ongoing compliance and high levels of accessibility; without accurate measurement it is difficult to make someone fully accountable. A mistake that some stakeholders make is to think that once a website is accessible and compliant it will stay that way. However, with new content being added all the time, this is simply not the case.

7. Platform

It’s also important to have the right tool that will provide an accurate and independent measure of accessibility. This won’t be built into your CMS or covered by Google Analytics. Generally, the only way to carry out accurate measurement is to use a tool that offers automation to assess the accessibility of your website.  For example, many of our clients use Sitemorse’s PRIVATEINDEX score as their base measure for accessibility and to benchmark progress against other peer organisations.

8. Somebody responsible for operations

In our last article we looked at how a RACI matrix of roles relating to accessibility (Responsible, Accountable, Consulted, Informed) can help to define the roles and activities to make compliance happen. Usually the person accountable will be more senior than the person actually responsible for operations and improving accessibility; typically, the latter may be the web manager or the digital communications manager, and the accountable person his or her director. Generally, you must have a named person responsible for co-ordinating the day to day effort.

Accountability doesn’t exist in a vacuum

It’s great to have a senior person that’s accountable for website accessibility and the accessibility of your related channels but it needs various elements to be in place for a person to be truly accountable. This includes reporting, measurement and the related tool to get you accurate numbers. Does your organisation have all eight elements we’ve covered in this article?


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