Indicative Roles, Responsibilities, and Policy Compliance

A proposed management structure for digital accessibility is outlined below to support the statements set out in this policy.

Digital Core Group

The Digital Core Group is accountable for ensuring that Ashford Borough Council adheres to The Regulations.

Strategic Lead for digital accessibility & compliance

The Digital Transformation Manager will develop a suitable strategy and framework to support Ashford in meeting its accessibility goals and monitor its implementation. They will ensure that good practice is applied and support services in their digital plans. This includes acting on relevant legislation and actions needed, as set out in this policy, to ensure compliance.

Operational Lead for digital accessibility & compliance

The Digital Improvement & Web Development Officer oversees matters of compliance with the technical web standards set out in the regulations, including compliance of accessibility statements. Working with the technical lead to resolve any issues This includes raising awareness of relevant legislation and of actions needed, as set out in this policy, to ensure compliance, including:

• Staying informed about the regulations and respond to any changes made to national guidance around accessibility.
• Liaising with the CDDO/GDS on any audits ensuring any issues flagged are resolved within the timeframe given.
• Supporting Procurement/Contract Managers to ensure that all systems (both existing and newly procured) have the Ashford Borough Council accessibility requirements built into contracts with the supplier.
• Conducting accessibility audits and testing using both manual and automated approaches.
• Creating and maintaining an accessibility audit framework that includes a list of systems in scope of this policy and their current accessibility status.

Technical Lead

The Senior Systems Developers will advise and support the Operational Lead to resolve issues where technical issues have caused incidences of non-compliance with standards that are identified across Ashford Borough Council digital estate.

Health and Wellbeing Group

The Health and Wellbeing Group support the maintenance of the framework and the monitoring of the Ashford overall adherence to the legislation through Equality Impact Analysis (EIA). There should be regular EIAs (Equality Impact Analysis) on how changes are affecting staff in different equality groups and positions within the Ashford Borough Council.

Digital Champions

Assistant Directors/Service Managers must appoint a digital champion who is responsible for accessibility to take responsibility for service systems/forms/web pages ensuring that they meet digital accessibility compliance for their services.

To do this, Champions will be fully supported by the Operational Lead and the Digital Core Group. Service Accessibility Champions will:

• Raise awareness of accessibility within their service, so that staff understand their roles in making systems and content digitally accessible. This includes sharing all guidance, communications, and training opportunities within the service.
• Flag any changes to the list of systems in scope of this policy within their service, including each system's compliance status to the Operational Lead.
• Support System Owners within their service in their pursuit of compliance by liaising with the Operational Lead to schedule audits and plan remedial actions.

System owners

Ashford Borough Council system owners will ensure that the digital systems under their control remain within the standards of WCAG 2.1 AA and relevant legislation. To achieve this, they must:

• Ensure their digital system or mobile application is fully compliant with WCAG 2.1 AA;
• Ensure their digital system or mobile application matches the requirements set out in the Councils Accessibility Statement Template.
• Put procedures in place to only publish accessible content on their system. If other services are providing content to the system owner, the system owner should make the service aware that they must only provide accessible content and can refuse to publish non-accessible content depending on their risk appetite.
• Work with the Operational Lead to identify and monitor known accessibility issues in the form of a remedial action plan. Issues should be prioritised and resolved as part of this plan. If deadlines are provided as part of a monitoring process, the system owner must resolve the issues by the stated deadlines.
• Work with contract managers and the Ashford Borough Council Accessibility Champions to incorporate accessibility requirements into new and existing contracts. This includes taking active steps to move websites into the Ashford Borough Council domain where appropriate.

Provide information about their system’s accessibility and allow access to the system for internal and external monitoring processes if asked to do so by the Operational Lead for digital accessibility and ensure that reasonable adjustments are in place for systems, for example providing accessible formats on request.

System owners are also responsible for the handling of any digital accessibility related complaints associated with their system(s) via the corporate complaints procedure. They should also report all such complaints to the Operational Lead for corporate monitoring purposes.

Procurement of Digital Systems

Contract managers (or managers with contract management responsibilities) must make sure that contractors and commissioned service providers understand their responsibilities in providing digital systems that support Ashford Borough Council in meeting its obligations regarding digital accessibility. They must also ensure that any tools used to deliver such services comply with the current standards at the time. Advice can be given by the Operational Lead.

As part of the procurement process, contract managers should complete an Equality Impact Analysis (EIA) and check the supplier’s conformity to accessibility requirements. Where a supplier does not meet accessibility requirements, tender should only be awarded if there are no suitable accessible competitors.

To achieve this, contract managers must ensure that appropriate clauses are included in the contract. They must then actively monitor and report on the compliance with those contractual obligations by the supplier as part of contract management.

Where issues are found that need funding to resolve, the contract manager and the service are responsible for managing these requirements.

Where products do not meet accessibility requirements, the supplier must provide evidence of their progress towards compliance. This must be actively monitored as part of contract management

Contract managers should seek support from the Operation Lead where they are unsure about digital accessibility compliance matters.

Service managers

Managers, team leaders and supervisors must ensure that staff are appropriately trained to produce accessible content and that the content published (or submitted to be published) is accessible. Training materials are available on Ashford Achieve and there is a digital accessibility section on the SmartHub which provides guidance, tools and training for creating and procuring accessible content.

Staff creating digital content

All staff are responsible for the compliance of any content they produce for a digital system, for example websites, intranets, digital document sharing platforms:

• Any multimedia & video content that is available to the public or to staff on a Ashford Borough Council digital system should have human-corrected captions

Staff should use the tools available on the SmartHub to make their content accessible before it is published and should seek advice from Digital Champions and then the Operational Lead if full accessibility cannot be achieved.

Ashford Borough Council advises that staff need to be given appropriate training on the tools and platforms they must use. Since digital accessibility is a developing area, regular training on updated technology and practice must also be provided. This training is mandatory for all staff creating digital content and must be repeated every two years.

In addition, any training, additional CPD opportunities or additional workload needed to use new tools and platforms should fall within staff members’ current workload allocation and should not be carried out in addition to the workload already agreed by contract.