One in five of the UK population has a disability. John Carter, Head of Experiences at KPMG in the UK, considers the opportunities and risks enterprises face and how they can respond.
In essence, digital accessibility ensures that technology and digital content is perceivable, operable, understandable and robust to those with a disability or long-term condition.
But what is a disability? The Equality Act (2010) states that ‘[A person has a disability for the purposes of the Act if he or she has] a physical or mental impairment and the impairment has a substantial and long-term adverse effect on his or her ability to carry out normal day-to-day activities.’
Why is (digital) accessibility important?
Inclusion and equality are general societal norms (although patronising view towards people with disabilities are still common), and for many of us there will be family, friends, and colleagues who have a disability. Even if you do not have a disability today, it is probable that you will have a disability in old age. An estimated 22% of working age adults in the UK are disabled, with 4.9 million disabled people in the workforce. However, 80% of people in work with a disability were not born with that disability, instead acquiring it later in life.
Your organisation is likely to have a set of values, which will typically reference inclusion and fairness, and hopefully you will agree that considering the needs of those with disabilities or long-term conditions is simply the right thing to do.
Legal
The Equality Act (2010) requires ‘reasonable adjustments’ for those with disabilities. The act does not list adjustments, but technology and digital content are commonly regarded to be within scope. The definition of ‘reasonable’ is less clear, and ultimately only an employment tribunal can rule on this.
The European Accessibility Act brings a much more direct pressure to produce accessible services. By 2025 all products and services available in the EU must be accessible — if you sell or operate there, then you are bound by it.
If you deliver solutions to public sector bodies in the UK today, it is likely their requirements will include accessibility due to The Public Sector Bodies Accessibility Regulations 2018. Other countries and regions have their own laws around accessibility, and you should be aware of those that impact you or your clients.
Maximising the potential of the workforce
Your organisation will have put significant effort into recruiting individuals into roles, and you want to get the best outcome from that investment. By considering accessibility, those colleagues who have a disability will be more productive, and those without disabilities will likely also feel secondary positive effects as a result of the focus on colleague experience.
Reputational
An organisation’s reputation can take years to build, yet can be destroyed in an instant. Society, our clients, customers and colleagues expect the highest standards of ethical behaviour.
Showing commitment to disability inclusion via signing up to a recognised global or country specific groups such as the Valuable 500 or the UK Government Disability Confident Scheme is valuable but must be backed by real action — if you fall short reputational damage may follow.
Recruitment and Retention
In the UK, one in five people of working age have a disability. The ‘war for talent’ has become more intense as people want flexibility, purpose, and interesting & challenging work in a hybrid, post-COVID world. Organisations that don’t provide this can miss out on the best talent. Do the maths — by making the recruitment process and the workplace accessible and more attractive to those with disabilities and long-term conditions we can increase our candidate pool by up to 25%.
Commercial – the ‘purple pound’
In the UK 14 million people have a disability, with a combined spending power of £274 billion: the ‘purple pound’. Globally this is $13 trillion. From a purely commercial perspective it does not make sense to have inaccessible technology solutions where there is an opportunity to make them accessible (and for new tech this is very easy to do).
The Accenture report Getting to Equal: The Digital Inclusion Advantage states that: ‘[Companies defined as one of the 45 Disability Inclusion Champions] are, compared with other companies in the sample, performing above average financially. Champions achieved — on average — 28% higher revenue, double the net income and 30% higher economic profit margins over the four-year period we analyzed.’
If you operate in a B2B environment, you will increasingly find your clients demand accessible solutions for the reasons noted in this section.
Better for everyone
If you improve your digital experience from an accessibility perspective you also make it better for everyone; directly, as we all appreciate simple processes, improved layout and readability of content, for example, but also indirectly as we create a culture of considering the needs of our users.
The relationship to ESG
Environmental, Social and Governance (ESG) is a well-known business framework for organisations to consider their impact on the world. You will likely see the primary business focus has been on the ‘E’, but increasingly organisations are looking at the ‘S’. In short, the ‘S’ includes the need to consider equal access for those with disabilities and long-term conditions. If your organisation has an ESG position, then accessibility should be considered in its plan and priorities.
A formal approach is required
Leadership support, aligned with value statements, is essential — likewise ‘bottom-up’ support from switched-on team members is important to build a groundswell of engagement. In smaller organisations, this may be enough to ensure at least some consistency of digital accessibility outcomes in the enterprise; however, we need to apply a formal approach to fill the gap between them. The following sections outline areas an enterprise must consider to ensure a consistent and effective approach to digital accessibility.
What needs to be in place?
We’ve already discussed the value of support and statements from senior leadership, but it is also important that all leaders in the organisation are aware and that those who support accessibility efforts are publicly praised for their position. Formal events to promote accessibility should be organised and a comms strategy must be developed.
You should build a digital accessibility team which, given the subject matter, is best placed within the technology function of your organisation. Your CIO/CTO must be supportive and willing to provide budget for staff. Only in the smallest organisations can this be done effectively from ‘side of desk’.
Define a vision, roadmap and strategy. Build a team and collaborate. Understand your landscape.
As with any team or function the best outcomes are achieved if you are explicit about the team’s vision, define a maturity model, and develop a scope, roadmap & strategy. If digital accessibility is new to your organisation, you may find that demand is significant; having a clear scope and roadmap will ensure that you focus on your priorities.
The digital accessibility team requires its own identity and leadership, but its influence and stakeholders are spread throughout an organisation and beyond. In addition to the technology relationship there is a link to an organisation’s Equality, Diversity and Inclusion (EDI) team function. This typically sits within a business support area, and we must be careful to ensure there is collaboration, alignment, and careful consideration of potential overlaps of roles. The same is true of the communications teams (both internal and external), as good work done on products and services can be overshadowed by inaccessible communications.
You should take steps to understand the accessibility of your entire estate and create prioritised action plans to remediate issues.
Challenge mindsets and language; build a culture
The way society treats those with disabilities has been modelled in several ways. Many refer to the medical and social models of disability; the former treats the disabled person as ‘the problem’, whereas social models recognise that it is the environment which is disabling. Furthermore, the medical model affords a charitable mindset that encourages sympathy rather than empathy. You should avoid actions that unintentionally reinforce those negative mindsets when promoting accessibility or demonstrating technology.
Many disabilities are non-visible, such as dyslexia, deafness, or diabetes, and care should be taken not to allow the assumption that all disabilities are visible by careful consideration of messaging and content (including images and iconography) and by gentle and appropriate correction of these assumptions.
You should also be careful in the use of language to describe people with disabilities. UK guidance is available, and you should respect individual choice in how they describe their disability or condition. You may find that colleagues and vendors from some cultures do not have an awareness of accessibility, on occasion to the point that they do not understand the term. In extremis they may hold views and use language that does not align with your organisational values.
Design and selection of technology services
Without a formal approach to considering accessibility in the design and selection of technology services, outcomes are mixed at best. We may be fortunate that some vendors, development teams, UX designers, testers, or sponsors are switched-on to accessibility, but this is not something we should rely on to obtain consistent outcomes.
Business and investment cases must refer to accessibility, and estimates and plans should reflect accessibility effort — often as a set of default functional or non-functional requirements.
Accessibility testing should be performed, and issues should be recorded and responded to in the same manner as other issues found. The bulk of accessibility testing can be automated, but there must also be human interaction in the accessibility testing path as automated testing will not capture everything. This human centred accessibility testing is best done by accessibility testing professionals, but there should also be some level of User Acceptance Testing (UAT) from representatives of the user population with disabilities (note that it is not generally appropriate to consistently target users with disabilities as a ‘pool’ of representative testers when that is not their day job).
Solution architects must ensure that the technology supports accessibility, and developers must be aware of how to implement accessibility requirements and the use of appropriate tooling. Modern web frameworks often include accessibility features by default, but some developer effort will still be required.
Human-centred designers and user experience professionals are generally well-aligned with the need for accessibility. They should ensure that the user research reflects the target demographic of the organisation and that user personas are both representational and intersectional.
It is important to get accessibility right first time and not to treat it as something that may be addressed in a future update. It is cheap to consider accessibility during the initial development or selection of technology, but it is far more troublesome to retrofit it to an existing product or service, or to require an existing vendor to update a product or service to be accessible.
Procurement and vendors
You will find that some vendors have no position on accessibility, and there are a minority who do not know what the term means (and if so, they will often guess it is related to the ‘responsiveness’ of web services). From the outset it is important to ensure that vendors are aware of your organisation’s expectations, but that does not go far enough. You should have standard content in RFIs, RFPs, contracts and/or schedules that explicitly state accessibility requirements, and your purchasing approval process must include digital accessibility sign-off.
Those vendors who are aware are increasingly producing Accessibility Conformance Reports (ACRs), typically in Voluntary Product Accessibility Template (VPAT) format. The existence of a VPAT is an indicator of awareness of accessibility but is not a substitute for other controls; after all the VPAT could essentially say ‘this product is not accessible’.
If you are a vendor of technology the message is clear: accessibility awareness needs to permeate the organisation (from engineering, sales, and support perspectives). If not, you will find that increasingly your competitors, who are aware, will get the sale.
Legacy technology
Perhaps the best working definition of legacy technology is that which is ‘painful’ to an organisation; often this is conflated with ‘old’ technology — for example, they may be difficult to integrate, rely on outdated backend services, or have service levels that simply cannot align with current requirements. But using the ‘painful’ definition also means that relatively recent technologies are legacy in that they may not be accessible; often with significant barriers to those with disabilities or long-term conditions.
Some of these technologies are deeply embedded into an organisation, and cannot be easily replaced, and often if there are accessibility issues, they may not be easily remediated.
So, having painted a potentially bleak picture, what can we do about it? There are five approaches:
- Engage with affected users: in addition to demonstrating issues are being taken seriously, they may be able to offer solutions or workarounds
- Create new experiences that integrate with legacy applications: this will also have the benefit of improving usability for all
- Engage with vendors to influence road maps and updates
- Review use of assistive technology: there may be a third-party tool that can at least partially address issues
- Put in place assistants who can access the technology on behalf of users with accessibility needs: these assistants do not have to be dedicated to individuals, and costs should be allocated centrally (enterprise-wide, or by department) to avoid the risk of treating individuals unfairly
Assistive technology
Technologies that assist those with disabilities, such as screen reading software, large monitors, colour filters and input devices are collectively known as Assistive Technologies (AT) and are likely to be considered a ‘reasonable adjustment’ within the context of the Equality Act 2010. As the appropriateness of technology is dependent on the individual, and often the identification of suitable technology is identified alongside non-technology adjustments during an Occupational Health Assessment, it is best left to HR to be accountable and responsible (although there is scope for accessibility SMEs to be involved in the selection of technology). It may be appropriate to place the budget for assistive technology centrally to ensure fairness and consistency.
Accessible content
Content is the presentations, documents, intranet pages, PDFs, images, and video that is produced manually or by tools such as reporting platforms. Just about everyone in an organisation will produce content at some point or other — certainly every colleague will consume it, and content will also be shared with vendors, clients, and customers.
The challenge is: how do we ensure this content is accessible without making everyone an expert?
We can make compliance the easy path — we ensure that branding, intranet layouts and document templates are accessible by design (e.g. through font choice, use of colour and images), that features such as PowerPoint’s Accessibility Checker are enabled by default, and that awareness of accessibility is given to all employees through training, ongoing comms, and leadership support for EDI initiatives.
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Significant and ongoing programmes that generate content through manual processes should have governance built-in; e.g. centrally delivered training materials must be assessed for accessibility alongside checks for accuracy and quality.
Even with all this support and the best intentions, things can sometimes go awry. There should be simple mechanisms to report content issues centrally, and digital accessibility teams should positively engage with the teams involved to ensure issues are addressed and not repeated. Comms to those affected is also recommended, and you will find they will be supportive and forgiving if commitments are made and followed-up on.
Risk, governance and assurance
Your technology organisation will have some form of assurance process. Traditionally this has considered issues such as strategic fit of technology or suitability of system architecture. There is scope to also consider digital accessibility within that assurance framework, for example by ensuring that third-parties demonstrate their solutions are accessible.
All enterprises will formally consider risks to their organisation, including legal, commercial, or regulatory, and they must consider digital accessibility with that lens — if systems are not accessible, then risk functions must be involved in assessing and managing that risk.
Note that information about an individual’s disabilities is special category data under GDPR. You should consult your data protection team for guidance on how such data should be handled.
End-user support
It’s often the case that users with disabilities are frustrated with support functions. It can seem that there is little awareness of assistive technologies and the disproportionate impact that failure can have on users with a disability. Often users find they need to repeat context and explain their disabilities during every interaction around a support ticket.
A dedicated support channel solves these issues — they understand the technologies and that the impact of technology failure can be severe, they also have strong links to the digital accessibility team and HR (to support assistive technologies).
In conclusion
Many enterprises commit to ensuring workplaces and colleague digital experiences are accessible, often as part of wider ESG and inclusion initiatives. Whilst these commitments are valuable and demonstrate intent, the enterprise must respond formally to this need with investment, policy and strategy — and a dedicated, passionate and empowered team to execute it.
If you deliver solutions to clients, you have little choice but to consider accessibility. Businesses are becoming increasingly sensitive to the experience of end-users with disabilities, and they are aware of legal and commercial pressures to provide accessible solutions to their customers and employees. If you cannot supply accessible services, your competitors will.
