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Disproportionate Burden Assessment

Disproportionate Burden Assessment

Whilst we will prioritise patient information to ensure it is digitally accessible wherever possible, we know there are some sections of our website which are not currently accessible that have been produced since September 2018.  
 

1. PDF documents (WCAG 2.4.2 Page titled)


Benefit

Providing descriptions in PDF documents would ensure that everyone can follow and understand the information presented. This includes access for users with blindness, motor impairments, hearing impairments, visual impairments, cognitive disorders, age-related impairments and more.

Burden

We have reviewed the PDF documents on the website which include:

  • Board or committee papers. 
  • Performance reports which may contain complex reporting/statistical data. 
  • Policies and procedures produced since September 2018. 
  • Publications linked from our Freedom of Information pages – including disclosure logs. 
  • Publications which may have been professionally produced since September 2018 which would have to be fixed by a third party.

There are currently thousands of historical documents created by the organisation on the website. 

We have taken an evidence-based approach to evaluate the use of these resources. Compared to the context of the wider website and based on Google Analytics review from 01/09/2022 – 01/09/2023, this shows that only a small number of users access the pages that contain links to the PDF documents. 
 
Each document would require a large amount of time and resources to be recreated in a fully accessible version which would include numerous changes including adding descriptions, colour contrast, and converting these into HTML format.  

While the health service is an important service, it cannot be protected from the realities that we need to find ways of saving money and living within our allocated budget. Drivers include our cost base increasing during COVID-19 with a number of legacy costs remaining, significant inflationary pressures and unabating demand for services. The costs required for staff to resolve all existing issues in line with operational demands adds additional time restraints to resolving this issue.
 

Assessment

We consider that converting older documents where there is little evidence of demand would represent a disproportionate burden on the organisation in terms of time, resources and cost. 
 
We have taken into consideration that our existing website accessibility statement signposts to those who need information, including accessible PDF documents, to contact the communications team in the first instance who will pass the request onto the relevant team, where accessible resources are available on request. 
 
We have added guidance about creating and uploading accessible PDF documents to our existing website training guides that cover accessibility that are available to staff.

We have enabled an approval process so we can monitor these documents before they are published to monitor accessibility. 

We plan to fix existing issues by July 2024.

 

2. Alt Text on Images (WCAG 2.1 success criterion 1.1.1. Non-text Content)

Benefit

Alternative text (Alt Text) is a HTML Alt attribute that helps to describe an image to users who are unable to see them. It is used by accessibility tools such as screen readers to help anyone who may have difficulties when browsing the website.

Burden

Our website contains thousands of webpages which would require a large amount of time and resources to monitor, evaluate and change all images without alt text. We require Welsh translation for each description which adds an additional cost and demand on time. 

While the health service is an important service, it cannot be protected from the realities that we need to find ways of saving money and living within our allocated budget. Drivers include our cost base increasing during COVID-19 with a number of legacy costs remaining, significant inflationary pressures and unabating demand for services. The costs required for staff to resolve all existing issues in line with operational demands adds additional time restraints to resolving this issue.

Assessment

We have added alt tags with text to images to the majority of primary and secondary pages. 
 
We have prioritised adding alt text and descriptions on webpages with key information for public safety including our contact us page. 
 
We have included accessibility guidance about adding captions and alt text to our website training guides that are available to staff, and we have enabled an approval process so we can monitor these documents before they are published to monitor accessibility. 

We plan to fix existing issues by July 2024.

Preparation of this assessment 

This assessment was prepared on 13th September 2023.

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