NB This is the fourth page of the online version of the SDT Guidance Note Disability Equality Duty: Implications and Opportunities for ICT provision in Higher Education Institutions and Colleges of Further Education, published in April 2006.

 

4: Specific Duties

Disability Equality Scheme

As explained previously, HEIs/Colleges are required to publish their first Disability Equality Scheme by 4th December 2006. The use of ICT can have a significant positive role to play throughout the life cycle of the Scheme. There are also areas in which institutional decisions and actions relating to ICT will need to be considered with respect to their impact on disabled people.

This section considers the relevance of ICT in each of the areas which are to be covered by the Scheme.

Involving disabled people and gathering information

One of the key requirements of the new legislation is the responsibility placed on institutions/colleges to ensure that disabled people play an active role in the formation of the Disability Equality Scheme. This requires early, regular, meaningful and appropriate involvement, through accessible mechanisms.

More in-depth discussion on involving disabled people and strategies relating to the type of information that needs to be gathered, the relevance and completeness of existing information held by institutions and analysis of the information, can be found in the Equality Challenge Unit's Briefing Paper 3: Disability Equality Schemes: Collecting and improving baseline data and the importance of involving disabled people. Available at http://www.ecu.ac.uk/publications/pamphlets/.

ICT can play a major role in supporting the involvement of disabled people. In particular, it can significantly improve the communication process, mainly for people whose impairment(s) may limit their ability or willingness to communicate in more traditional ways and situations, such as verbally in a large meeting. It may be necessary or convenient for some people to be able to present input in written form through email or electronic documents, or converse with others in the consultation process through email, instant messaging software or web-based discussion fora. This may be particularly relevant for some disabled participants from external organisations - people whose involvement may be potentially valuable, but who may be physically located away from the institution/college and thus find it difficult to travel to the campus.

Research into computer-aided interviewing has suggested that it can be a particularly effective way of eliciting information of a sensitive nature from respondents. This is potentially vital in helping to ensure that the information gathered relating to current institutional practice with respect to disability support is truly reflective of respondents' views.

While there are many benefits of electronic communication for disabled people, there are also accessibility problems with some instant messaging, bulletin board and chat room software applications and interfaces, which can make them difficult or impossible to use for some people. Care should be taken to ensure that communication software used, and materials provided as part of the consultation process are themselves as accessible as possible. (Policy relating to accessibility and ICT provision is discussed separately).

For more information, see: Smith J. (2004) Accessibility of online chat programmes. Web Accessibility in Mind project (WebAIM): http://www.webaim.org/techniques/articles/chats).

There is an obvious role of ICT in the process of gathering information relevant to promoting disability equality and informing and monitoring the Disability Equality Scheme. As the Code of Practice and other resources point out, institutions/colleges should already have conducted similar processes as part of obligations under the Race Relations (Amendment) Act 2000.

The Equality Challenge Unit reminds institutions/colleges that they must include in their Disability Equality Schemes information on how data is gathered about the effects of policies and practices on disabled people, including:

the effect of its policies on the recruitment development and retention of disabled people, and

the effect of its policies on the educational opportunities of disabled students.

(from Equality Challenge Unit, 2005: Briefing Paper 3: Disability Equality Schemes: Collecting and improving baseline data and the importance of involving disabled people, p6)

Thus, data gathering may include analysis of existing data that is already gathered as part of institutional/collegial procedure, as well as gathering additional data necessary to measure impact on disabled people.

Impact assessment

A key part of an institutional Disability Equality Scheme is impact assessment of policies and practices which, according to the Code of Practice (Section 3.29), includes all current and proposed activities which the authority carries out. It also relates to the impact upon disabled staff, disabled students and disabled visitors and/or service users, both existing and in the future.

The Scottish Disability Team publication Disability Impact Assessments - A Brief Guide provides valuable information on carrying out impact assessments, in terms of what should be subject to an impact assessment, and how to go about carrying out assessments. The guide is available at http://www.sdt.ac.uk/resources/ImpactAssessmentGuidanceDec05.doc(Word version)

The critical areas of relevance to this report are:

ICT provision and support
referring to technology as tools to allow staff, students and others to do their jobs, receive education or other services as defined in the legislation.
Digital information creation and publication
the nature of the information produced by ICTs, for use by staff, students and others.
ICT in learning and teaching
the specific role of ICT in supporting students and staff in an educational context.

These areas cut across all general areas of institutional activity, although policy, practice, procedure and criteria may variously be set at institutional, faculty, departmental or school level.

ICT Provision

Disabled staff, students and service users may require, or be required, to use computing equipment as part of their work, study or access to services. They may also require additional assistive technology to enable them to use their computer. This may be hardware (such as alternative input devices replacing the mouse or keyboard) and/or software (such as screen reading or screen magnification software), or adjustments to the standard desktop computing system provided by HEIs/Colleges.

For example, if an assistive technology or access solution is available at only specific locations, this may have an adverse impact on a disabled student if the student is involved in collaborative coursework that requires group discussion at a computer terminal, and it is not possible for the discussion to take place at a terminal where the assistive technology is available.

There is also a need to monitor the impact of changes made to out-of-the-box systems that may have been procured from a third party supplier, but enable a degree of customisation to be made by the institution. If the impact of change on the level of accessibility of the system is not considered, disabled people may be placed at a significant disadvantage.

The storage of a disabled person's specific access requirements, and the ability of an e-learning resource to respond to those requirements, is the focus of ongoing work led by the IMS Global Learning Consortium. This is of potentially significant impact - and is discussed further in the Standards, Guidelines and Best Practice section of this document.

ICT Provision - Areas for impact assessment:

  • Any policy or practice relating to a baseline provision of computing equipment (hardware and software) will need to be assessed for its impact on disabled staff, students and service users, particularly in terms of availability of assistive technologies required by particular groups.
  • Any policy or practice relating to customisation or changes made to out-of-the-box systems that may lead to a reduction in accessibility of the systems.
  • Particular areas of focus will include those that cover:
    • Assessment of users' access requirements and matching of appropriate assistive technology or access solutions to those requirements;
    • Education and training of users in effective use of their particular access solution;
    • Monitoring of users' needs and re-assessment of their access solution as required;
    • The physical availability (around campus) of assistive technologies and access solutions.

ICT Support

Given that many disabled people will require additional support in finding and using the most appropriate assistive technology or access solution, this should also be subject to an impact assessment. The level of support provided by the institution's ICT department to disabled staff, students and service users will, therefore, be highly relevant.

Of particular importance will be the availability of knowledge amongst ICT support staff of the assistive technology provided or likely to be provided by the institution, both in terms of number of support staff with the knowledge and the time they are available. The support required will include provision of advice both on use of accessibility features of operating systems or specific software applications; and on configuring and operating dedicated assistive technologies.

For example, disabled people may be placed at a disadvantage if ICT support includes only one staff member with detailed knowledge of the assistive technology provided by the institution, and that staff member is not available to provide full-time cover.

There is also a need to assess general training materials and programmes provided by HEIs/Colleges, whether in-house or third-party, for their consideration of accessibility issues. Material that makes assumptions about a person's abilities or fails to cover accessibility issues is likely to place disabled people at a disadvantage.

ICT Support - Areas for impact assessment:

Any policy, practice or procedure relating to provision of support to disabled staff and students, in terms of:

  • Influence of knowledge and experience of assistive technology in defining recruitment strategies for ICT support staff.
  • Training of ICT support staff in assistive technology and access solutions (hardware and software) and any known or potential issues with other ICT provided by the institution.
  • Availability of ICT support staff with the appropriate training.
  • Suitability for people with specific disabilities of generic ICT-related training materials and programmes provided by or used by the HEI/institution.

Digital Information

The use of digital information in a variety of forms is the other crucial area requiring attention. There are many formats in which electronic information may be provided, including popular documents formats like Microsoft Word and Adobe PDF, as well as HTML web pages and multimedia such as video, audio and animated content (see Standards, Guidelines and Best Practice for further links to accessibility for each format). Decisions relating to the format and production of digital information, and availability of alternatives, are likely to have an impact upon a disabled person who is trying to access that information.

For staff, digital information likely to be of importance will be diverse in nature, but may include:

For current and potential students, digital information likely to be of importance may include information on topics as diverse as:

Digital material used in teaching and learning is also critical - this is discussed separately.

Much of the information specifically aimed at staff and students will be provided on the institution's web site; some information may be available through an intranet, extranet and/or virtual learning environment; and access may consequently be restricted. Other electronic information may be circulated by email. On the institution's public web site, there is also likely to be information of interest to other individuals on topics such as:

In considering impact assessment of digital information on disabled people, it is important to focus on both the creation and publication of the information.

Digital Information Creation

Accessible information creation requires the appropriate software and training on the part of the author.

Software may be a dedicated application or part of a more complex suite of tools, and includes, for example, word-processing software, databases, spreadsheets, presentation software, web site creation software, content management systems, management information systems, and student records systems. The facilities for generating accessible output may therefore vary from application to application.

To ensure optimal accessibility, software should:

In particular, any software that enables the publication of HTML-based web content (including content management systems and publishing tools of other systems) will require to be assessed for capability of outputting accessible material - including automated generation of documents and prompts for authors to include features to improve accessibility. See Standards, Guidelines and Best Practice for more information.

Digital information creation - Areas for impact assessment:

Policy, practice, procedure and criteria relating to:

  • Procurement and provision of tools for creating and publishing optimally accessible electronic information, including web content;
  • Circulation of digital material that may be for restricted audiences and therefore not published online, and provision of the information in alternative accessible formats if required;
  • Staff training relating to publishing accessible electronic materials.

Digital Information Publication

There is a need to monitor the accessibility of digital information that a disabled staff member, student or member of the public is likely to encounter. In this area, institutions may already be active, given their responsibilities under Parts II, III and IV of the Disability Discrimination Act by, for example, specifying baseline levels of conformance of Web pages with accessibility guidelines.

Given that documents may have originally been authored with accessibility in mind, but then amended to a point where accessibility barriers have been introduced, it is important that these barriers in published electronic information are identified and addressed as soon as possible. At the same time, there are opportunities for extending the accessibility of information or experiences for specific groups of disabled people through the use of additional alternative formats, such as podcasts or multimedia presentations.

Obviously, given the enormous amounts of digital information likely to be present within an institution's 'digital environment', regular checking of every resource is likely to be impractical. However, an effective strategy needs to ensure that there are clearly identified roles and responsibilities for monitoring and compliance, including strategies for addressing problems found, and action taken by the institution against the resource and author if accessibility barriers are not adequately addressed.

For example, if an institution's policy is to circulate important or time-critical announcements by emailing scanned copies of a paper document, there are adverse implications for blind and visually impaired people if the text of the scanned document has not been made available in screen reader accessible format.

If security measures are implemented in order to limit the likelihood of malicious capturing and use of institutional resources, such as email addresses, disabled people may be at a disadvantage if the security measure also prevents people with specific access requirements from accessing or using the resource. For example, an online registration facility that requires users to enter the characters shown in a distorted image (sometimes referred to as a "captcha") may be unusable by anyone who cannot read the image (e.g. due to a visual impairment).

More information on accessibility and security measures is provided in the W3C document Inaccessibility of CAPTCHA - Alternatives to Visual Turing Tests on the Web, available at: http://www.w3.org/TR/turingtest/.

Digital information publication - Areas for impact assessment:

Policy, practice, procedure and criteria relating to:

  • Current baseline levels of accessibility to be met by digital information provided to staff, students and service users;
  • Methods for providing information in alternative, accessible formats when required;
  • Accessibility-focused evaluation and repair strategies for published digital information, including:
    • programmes of accessibility evaluation of existing material - scope, nature and frequency;
    • delegation of responsibility for carrying out evaluations and for making necessary repairs to documents found not to meet accessibility standards;
    • policy for dealing with failure to repair an inaccessible resource or provide an accessible alternative, with regard to the responsible staff member and to the resource itself;
  • Nature and impact on accessibility of any security measures aimed at limiting or preventing access to information or resources by malicious software.

ICT in Learning and Teaching

The impact of the use of ICT to support teaching and learning can have a significant impact on disabled staff and students - whether learning on-campus or at a distance. In particular, the use of e-learning resources can have a positive or negative impact on disabled people.

Although HEIs/Colleges may already be addressing some of the issues under the DDA 1995, impact assessment is still required to ensure that appropriate steps are being taken to ensure that e-learning resources actively enhance the accessibility of the learning environment rather than introduce new barriers.

Current approaches to developing, procuring and providing e-learning resources and other ICTs in teaching and learning activities will need to be assessed in terms of their impact on disabled users.

ICT in learning and teaching - areas for impact assessment:

Policy, practice, provision and criteria relating to:

  • Baseline provision of ICTs for teaching and learning - both at institutional and at faculty/school levels. This may include institutional policy and practice in selecting a VLE or MLE.
  • Assessment of the accessibility of a teaching and learning resource. This will require to be assessed from a user perspective (is the learning objective accessible to a student with a specific impairment? Can a disabled member of teaching staff configure the resource as appropriate? Has the resource been designed and evaluated for accessibility following appropriate methods (see Standards, Guidelines and Best Practice section)?)
  • The provision of alternative accessible routes to achieving the equivalent learning experience. If it can be demonstrated that the resource cannot be made accessible to people with a particular impairment, what alternative provision, if any, exists for that group?

The resources provided by the Teachability project (http://www.teachability.strath.ac.uk) will be helpful in establishing appropriate strategies for ensuring that e-learning resources are used to enhance, rather than reduce, accessibility of the curriculum.

Procurement

While some ICT may be developed in-house, institutions are likely to procure ICTs from external agencies, which may have varying levels of expertise in and commitment to accessibility in the work they produce. Policy, procedure and practice relating to procurement of ICT will therefore require to be assessed for impact on disabled people.

The Code of Practice gives specific examples of such a scenario:

A Scottish Executive Department that is planning to procure a new IT system should ensure that its action plan includes the work it will do to ensure that the new system is suitable for use by disabled employees. The action plan should also indicate the way it will develop the specification so that the system delivers the right products for disabled customers. This might include having a means of identifying those customers and their requirements, which could lead to being able to, for example, print notifications and letters in accessible formats for visually impaired people.

(from pp68-69)

The Head of Information Technology of a Scottish Executive department is overseeing the redesign of the department's website, which is being contracted out to a web designer. The head of IT ensures that the tender documents include reference to the Disability Equality Duty and in particular the need to ensure that the web site is fully accessible to disabled people. The standard terms of contract are revised to reflect the fact that any updating and/or maintenance work on the website must ensure access for disabled people, in order to ensure that the department is meeting its disability equality duty.

(from pp117-118)

There is a clear need to ensure that accessibility is influential at all stages of the procurement process. In particular, institutions need to establish the level of accessibility which the system in question will meet, how that will be assessed once the system is delivered, and the action to be taken should the specified level of accessibility not be met.

There is also a need to ensure that the supplier is suitably qualified to deliver the desired level of accessibility, and has a demonstrable commitment to developing accessible systems - including due mention of accessibility in supporting documentation and training materials. This may be established at an early stage during assessment of candidate systems and suppliers, or by seeking references or third party comment on their commitment and track record with respect to accessibility.

HEIs/Colleges should also be aware of their potential obligations under the Public Procurement Regulations, the Public Contracts (Scotland) Regulations 2006. Where a procurement by a public authority is subject to these regulations, the authority is obliged to "whenever possible, take into account accessibility criteria for disabled persons or the suitability of design for all users" when laying down technical specifications for the procurement. Similar obligations exist for public authorities in England and Wales.

The Public Contracts (Scotland) Regulations 2006 are available online at: http://www.opsi.gov.uk/legislation/scotland/ssi2006/20060001.htm

Procurement - Areas for impact assessment

Policy, practice, procedure and criteria relating to:

  • The extent to which disabled people are involved in the drawing up of requirements to be specified in any invitation to tender or system description;
  • The extent to which minimum standards of accessibility are included within other baseline requirement specifications or invitations to tender for ICT systems or products, and in contracts between the institution and supplier;
  • Assessment of candidate suppliers with respect to their commitment to, capability and track record of supplying accessible solutions and supporting documentation and training material;
  • Strategies for considering alternatives should no product or tender meet the baseline for accessibility;
  • The extent to which accessibility of ICT delivered by third parties is evaluated against the specified baseline standard, and the actions to be taken should the delivered solution be deficient.

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