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Australian National Audit Office Better Practice Guide: Internet Delivery Decisions

Note: The official version of this guide is on the ANAO site www.anao.gov.au . It is posted here for convenience.

Component No 9: How to Make Government Internet Sites More Accessible

This component of the ANAO Better Practice Guide provides advice on how government managers can make government internet sites more accessible. It explains the reasons for making sites more accessible and describes the meaning of accessibility.

It also sets out how program managers can confirm that their program's sites are accessible. Some better practice sites are also identified.

Why do Commonwealth internet pages need to be accessible?

because that's what often best suits the clients (or 'service users')

For anyone who uses the online services, accessibility means better service at times and places which suit them. This is most important for clients with a disability, but more accessible services make access easier for everyone.

Remember, disability is not always a physical limitation. A client with agoraphobia (a fear of crowds or open spaces) may find a trip to a shopfront office an impossible challenge.

because it is efficient and effective to make internet based services accessible

Internet based information products and services, when properly set up, can significantly reduce the expense and time spent using products such as Braille and audiotape to reach Australians with disabilities. It can reduce the need for inefficient paper products.

Accessible design makes it easier for everyone in the community to get better and faster access whether they have a disability, including:

because the Government has decided that Commonwealth internet services must be accessible

On 21 March 2000, the Government adopted accessibility requirements for Commonwealth sites. This is part of the Government online strategy, requiring:

because the Disability Discrimination Act requires accessibility

The Disability Discrimination Act 1992 requires government bodies to provide equitable access to people with disabilities.
Commonwealth websites (and others, including commercial sites) risk exposure under the Act to complaints from anyone claiming disadvantage by lack of access. The Act requires equal access for disabled people, where it can reasonably be provided.

While other service providers may argue that providing access would 'involve unjustifiable hardship', this defence is not acceptable when administering Commonwealth laws and programs.

For anyone who uses the online services, accessibility means better service at times and places which suit them. This is most important for clients with a disability, but more accessible services make access easier for everyone.

What does accessible mean anyway?

In terms of government programs and services, accessible means available to clients in formats which are easily available, easy to use and appropriately targeted at the potential audience. For example, it might include providing:

Users who cannot see, or cannot easily read print (e.g. those suffering retinal pigmentosa, or RP), or cannot distinguish colours, or hear, can receive and exchange information through the internet as readily as other users if sites and services are designed to be accessible.

In particular, blind or vision impaired people can use screen reader software and a range of programs and devices to receive web page content in speech or Braille. People who cannot read written English -due to learning or literacy difficulties or language differences-can also benefit from this ability of the internet to deliver material in different formats.

But what does accessible really mean?

The W3C standards have been government's benchmark for accessibility for Commonwealth Government sites: (see also the Human Rights and Equal Opportunity Commission's [HREOC] advisory note on Disability Discrimination Act compliance at www.hreoc.gov.au/disability_rights/standards/www_3.html). Government has set the W3C's Priority 1 'checkpoints' as a first stage and required Commonwealth bodies to comply.

The selected priority one checkpoints within the W3C guidelines are:

In General (Priority 1)

And if you use images and image maps (Priority 1)

And if you use tables (Priority 1)

And if you use frames (Priority 1)

And if you use applets and scripts (Priority 1)

And if you use multimedia (Priority 1)

And if all else fails (Priority 1)

Where do I get more information?

Refer to the W3C Web Content Accessibility Guidelines and accompanying Techniques for Web Content Accessibility Guidelines 1.0. The full checkpoint list including Priority 2 and 3 Guidelines is also available.

In addition to its World Wide Web Access, see the Disability Discrimination Act Advisory Notes HREOC published in December 1999.

DOFA's Guidelines for Commonwealth Information in Electronic Formats also include discussion of accessibility issues.

That's too much information—can you put it more simply?

A useful easy reference guide to some major issues is provided in the W3C Web Access Initiative's Quick Tips for Accessible Websites:

How do I check if my pages are accessible?

The Bobby program (available free at www.cast.org) can give an automatic check. This should highlight major access problems. However, automated checking is not a full substitute for human judgment and human user experience in any thorough assessment of effective accessibility, and broader issues of 'useability'.

Users who cannot see, or cannot easily read print (e.g. those suffering retinal pigmentosa, or RP), or cannot distinguish colours, or hear, can receive and exchange information through the internet as readily as other users if sites and services are designed to be accessible.

Frequently asked questions (FAQ)

Does accessibility mean I can't use innovative or attractive design?

No. There is obviously a role for attractive visual design in ensuring that sites reach and serve their intended audience. Many people (including some people with disabilities) receive some information more effectively through graphic forms than through words. Accessibility does mean that, as far as possible, users can choose how they get the information from your page.

Does accessibility mean I need to maintain several versions of my site?

Some Commonwealth sites appear to have effectively managed several accessibility issues (as well as long download times for graphic-heavy pages) by implementing text only equivalent sites. A smaller number have implemented the W3C preferred approach, with one accessible version (but different versions of particular elements or pages where necessary). There are several reasons to adopt the single accessible site approach. A single accessible version will benefit all users. Work on 'accessibility' issues can provide a simpler, clearer, better site. Also, parallel ('text') versions may not cover all your site's accessibility issues because:

Is PDF accessible?

PDF does not, in itself, accord with accessibility guidelines. It is, however, widely used by the Commonwealth and other Australian governments. This is only acceptable if sites either:

PDF is, at least in its origins, essentially a graphical format, which presents access problems for people who cannot see and who are relying on screen reader software to convert text into speech or Braille.

The W3C Web Content Accessibility Guidelines recommend:

When inaccessible technologies (proprietary or not) must be used, equivalent accessible pages must be provided...Converting documents (from PDF, PostScript, RTF, etc.) to W3C markup languages (HTML, XML) does not always create an accessible document. Therefore, validate each page for accessibility and useability after the conversion process... If a page does not readily convert, either revise the page until its original representation converts appropriately or provide an HTML or plain text version.

The proprietors of PDF have recently published a White Paper on PDF accessibility which includes guidelines for PDF accessibility. These emphasise the need for providers of documents to check that their work converts effectively.

If document providers check their documents convert effectively, by converting them to accessible formats, then such text or HTML alternatives are little extra effort to put online alongside the 'authentic' PDF version. Consequently, users aren't required (from their viewpoint, 'penalised') to do the conversion and undergo additional effort, expense or delay, together with the uncertainty of whether conversion will in fact be effective (rather than jumbled text and junk symbols, as seen on converted PDF files from a number of Commonwealth sites).

Can I use frames?

Several Commonwealth Government sites use frames as a convenient way to navigate. An example is using side bar menus in a constant screen position while the user scrolls through document content in another frame.

However, not everyone uses or can use browsers which support frames. Frames can present particular barriers for screen readers - who, for example, may not be able to find their way out of the first frame encountered to view the rest of the site.
The Web Content Accessibility Guidelines does not disbar frames. They require that frames should not prevent navigation by users who cannot see the whole page or use frames, and that a 'no frames' option should be provided. Frames are, after all, intended to improve navigability and presentation, rather than to make it difficult or impossible.

The Guidelines provide detailed advice on techniques to ensure that frames do not disable accessibility. Many of the Commonwealth sites which use frames do not comply with these requirements.

Can I use video, pictures, music and sound bytes?

Yes, but ensure that you provide a text description of the picture, video or sound track, and provide transcript and/or captioning of dialogue wherever possible.

Can I use animation and moving elements?

Yes, but you must provide an accessible alternative. Shockwave, flash animation and moving text
are not accessible to all users. Also consider why you need to use these formats on a Commonwealth site.

Fixing the whole site will take time - where do I start?

Sites must comply with the priority one guidelines as soon as possible, thereby complying with government policy. This should not prove as hard as it looks once a start is made.

The following suggested order of priority for achieving compliance with at least the Priority 1 guidelines is based on advice from a leading commentator on web page useability:

Can you give some examples of better practice sites?

Several Commonwealth agencies have achieved significant progress in accessibility (although
further accessibility or useability improvements may be possible). These include:

Can you give examples of current problem areas?

Here are some problems identified in HREOC's December 1999 audit of Commonwealth sites, in addition to the problems with frames and PDF already discussed: