Introduction
SCH Environmental Surveys Limited aspires to make digital content and systems as inclusive and accessible as possible. It also has a legal duty to meet relevant regulations in this context, such as the Equality Act 2010 and the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 (the “Accessibility Regulations”)
The Equality Act 2010 includes a general duty to make reasonable adjustments for disabled people (including providing alternative, more accessible formats of digital content available to disabled individuals on request). The Accessibility Regulations clarify and enhance the Equality Act requirements for a digital context and require a more proactive and inclusive approach. A failure to comply with the Accessibility Regulations requirements will be treated as a failure to make a reasonable adjustment, contrary to the Equality Act 2010.
Purpose of the Policy
The purpose of this policy is to set out SCH Environmental Surveys Limited approach to meeting the relevant legal requirements, and the principles that it expects staff to follow to achieve this.
Scope of the Policy
This policy applies to:
All new, updated, and existing digital services and systems that are provided by SCH Environmental Limited.
Everyone that produces documents or content that will be published or made available to others on our digital services and systems; and
Everyone involved in the procurement, management and/or development of a company’s digital service or system.
For the purposes of this policy, a “digital system or service” is any Information Technology (IT) system that is accessed using a browser or on a mobile device and is created for an internal or external audience (for example company staff and members of the public). This applies to the administrative interface as well as the user interface.
This includes but is not limited to:
• websites
• web-based systems.
• documents and content hosted on a digital system.
• mobile applications.
A digital system or service is in scope of the Accessibility Regulations if it is funded, developed, or controlled by SCH Environmental Surveys Limited.
The policy does not apply to:
Any digital system that is not funded, controlled, or developed by the company name or is outside the scope of this policy.
Some types of digital content are not in scope. Even where a digital system or service is outside the scope of this policy, its accessibility will be considered, and where specifically requested, provisions made for reasonable adjustments or alternative formats.
Policy statement
SCH Environmental Surveys Limited will put systems and a framework in place to enable compliance with the Accessibility Regulations and all relevant legislation. It will ensure changes to legislation are considered in a timely manner and review policy and controls accordingly.
Digital systems will be developed and managed to comply with the Accessibility Regulations, addressing any technical limitations that become apparent. SCH Environmental Surveys Limited requires that:
Newly commissioned digital content and services, whether delivered by external providers or built in-house, must meet the required accessibility standard of WCAG 2.2 AA from the outset.
All existing digital content and services will meet at least conformance level 2 standard (AA) of Web Content Accessibility Guidelines (WCAG) 2.2
All mobile apps will meet at least conformance level 2 standard (AA) of Web Content Accessibility Guidelines (WCAG) 2.2
Any digital system or service that cannot be made accessible will be referred to MSPB who will act to manage the risk of non-compliance. This may be escalated to other accountable roles for accessibility compliance, or consideration of possible exceptions.
An owner for each digital content and service will be identified or appointed and that owner will be accountable for the accessibility of that content and service. They will also be accountable for the accessibility information provided via an Accessibility Statement to users of the content and service.
Staff who provide content must learn how to make content accessible and keep up to date with accessibility standards.
We will publish and keep up to date digital accessibility statements in a form that meets the requirements of the Accessibility Regulations.
If something is not in an accessible format, and an alternative format is requested by a user, the company shall provide an accessible format to the user.
Company directors are responsible for oversight of the Accessibility Statements and the overall consistency of information provided in them and for it meeting minimum legal requirements.
Company directors will be central point of contact for requests for an alternative format where what has been provided does not meet the Accessibility Regulations or is required as a result of an agreed reasonable adjustment.
Accessibility statement
All distinct websites authored by SCH Environmental Surveys Limited, all purchased third party software and web-based systems must have a published accessibility statement that is compliant with the Accessibility Regulations and guidelines laid out by the Government Digital Service (GDS).
Each accessibility statement will need to be updated annually. The company is responsible for authoring and publishing compliant accessibility statements for all purchased third party software and systems that do not provide their own.
Exemptions to this Policy and Disproportionate burden assessment
Exemptions from the position set out in this policy will be approved by the Cyber & Information Security Group.
The following circumstances may qualify as exemptions from the requirements of this policy:
Where compliance is not technically possible or may constitute a disproportionate burden (see below) due to the nature or purpose of the information resource or service.
Where compliance would result in a fundamental alteration of the information resource or service and not satisfy the original intent.
Where the content is not currently compliant, but efforts are underway to fix the issues by a defined date.
Exemptions to this policy may be made by submitting an exemption request to be reviewed by Cyber & Information Security Group. Non-compliant information technology must not be purchased or developed prior to receiving an exemption approval.
Compliance
Failure to adhere to this policy may be an infringement of the relevant legislation, which could result in reputational damage, action by our regulators, legal action and/or financial loss.