We always aim to make content on our website accessible. However, we have assessed that ensuring every document published on our website meets the accessibility legislation would be a disproportionate burden.
We know some PDF, Excel and Word documents are not fully accessible and that it is likely that documents that are uploaded in the future and are in this format are likely not be fully accessible. This is something we’re working on.
We have assessed that ensuring every document published on our website meets the accessibility legislation would be a disproportionate burden.
Sharing accessible information is important to us. We are committed to making documents relating to patient care and the provision of our services accessible. There is already a process in place for this.
We will always make information and documents that are essential to providing patient care accessible.
Most of the information on our website is fully accessible already.
Our disproportionate burden assessment looks at PDF, Excel and Word documents that are not essential to the provision of our services and patient care. This includes, but may not be limited to, our annual report and accounts, public board papers, as well as some policies, procedures, strategies, plans and reports. These files do not consistently meet accessibility standards such as:
Non-text content
Info and relationships
Meaningful sequence
Contrast (Minimum)
Page titled
Focus order
Headings and labels
We continue to make incremental improvements to the accessibility of any new versions of these documents. This includes:
However, we cannot guarantee full accessibility at this time. This is in part due to the format of financial data and performance reports as well as the complexities of some of the information.
The accessibility requirements do not require us to fix PDFs or other documents published before 23 September 2018 if they are not essential to providing our services. We do not plan to fix any PDFs or other documents published before 23 September 2018, for example Board and Committee Papers, Health Board policies and procedure documentation or statutory documentation such as Annual Reports.
The benefits of making these documents into accessible HTML web pages are:
Information would be accessible to everyone.
Information would be easier to search and index.
Our assessment of the burden of making these documents into accessible HTML web pages is that:
There are hundreds of PDF, Word, Excel and PowerPoint files published on our website in both English and Welsh.
Each document would need to be reviewed for accessibility. Many are likely to require several hours’ work to become accessible. We estimate between two and thirty hours per document, depending on the length, complexity, and any sign off required.
Some documents, such as our board papers, are compiled by multiple people shortly before they are legally required to be available to the public.
Many of the documents are part of our legislative duty as an NHS health board, e.g. annual reports, and publishing a new version may require detailed checking, a formal sign-off process, and submitting a new official version.
Many of the documents contain complex elements which are difficult to retrospectively convert, such as detailed tables, graphs, and diagrams.
Also relevant to this decision are that:
Our focus is to ensure that any new documents, relating to patient care and essential to the delivery of our services, are accessible and meet the needs of patients and people living in our communities.
In the context of the wider website and based on Google Analytics, we can see that interest in the pages that contain the documents within the scope of this assessment is low.
We have and will always provide people with accessible versions of these documents on request.
We believe converting documents, where there is little evidence of demand, would represent a disproportionate burden on our health board because of the staff time it would take and the associated costs.
Under current financial constraints, payment to an external agency to make these documents accessible is not justifiable over other essential service requirements.
All our users will benefit from us making our website and online information accessible, so focusing our limited resource on maintaining the most-used accessible content on our website and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities is our priority.
This assessment was prepared in September 2023.