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The Heads of eLearning Forum (HeLF) is a network of senior staff engaged in promoting, supporting and developing technology enhanced learning (TEL). We have 140 nominated Heads from UK higher education institutions and a regular programme of well attended events.

12 Aug 2019

47th HeLF Meeting: "Accessibility"

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The 47thth meeting of the Heads of eLearning Forum was hosted at University of Birmingham, on 13th June 2019.


BY AMBER THOMAS, UNIVERSITY OF WARWICK, and SUE LEE, STAFFORDSHIRE UNIVERSITY.



"Coming Together" by Niki de Saint Phalle, 2001 - orphan work | CC0

T he day started with a warm welcome from Stephen McAuliffe, Academic Registrar of University of Birmingham. The theme of Accessibility had been chosen as topical with the regulatory changes due to come into force from September 2019. To start the day, Allen Crawford-Thomas from JISC outlined the new Accessibility regulation. Public sector websites will have to meet more stringent online Accessibility requirements and standards under the new regulation. Non-compliance will be treated as a failure to make reasonable adjustments under the Equality Act 2010. Further details are available on the UK Government's Digital Services website and linked below:
As part of the new requirement, Higher Education Providers (HEPs) must provide an Accessibility Statement in accordance with the example given in the new regulation and keep it under regular review to include:
  • An explanation of content that is NOT accessible and the reasons why;
  • A description of any accessible alternatives provided;
  • A Contact form – to notify – see disproportionate burden further below;
  • An Enforcement procedure.
Some useful accessibility statements were shared by Ben Watson (University of Kent) and George Rhodes (Kent County council) that can be found in the slides linked at the end of this article.

It is clear that HEPs will be breaking the law if their websites or apps do not meet the new Accessibility standards. This duty also applies to their Virtual Learning Environments (VLE) which are considered part of intranet websites under the new regulation. HeLF members who have worked closely with JISC on public-facing websites compliance at their institutions provided further clarification on this point – material added after the deadline must be compliant. Any material added before the September 24th deadline will have to be compliant by September 2020. Exemptions may exist but will require documenting a justification to support them. A few things to note, livestream is exempt but recordings are included. In certain cases like lecture captured recordings, the organisation may be able to claim that providing accessible versions of recordings creates a case of "disproportionate burden". Such claims would have to take account of specific organisational circumstances. They may include the size and nature of the institution, thus its resources, the estimated cost of compliance versus strategic accessibility investments that benefits the organisation, their staff and students with reasonable adjustments. The HeLF representatives present felt that it would be extremely helpful for JISC to broker some further sector-wide guidance on "disproportionate burden" and legal advice or exemplars.

The next presenter was Robert McClaren from the cross-party think tank Policy Connect
who joined the event via Skype. The ensuing discussions explored further the scope for full implementation by 2020 or 2019 and the frequency of the Accessibility Statement review as a result of "substantial revision" of the platform or its content as defined in the regulation. Under which circumstances the content held on older instances of an institutional VLE would be exempt? Would this be when the platform are upgraded or when a portion of the content has been updated? Because the VLE content is regularly and frequently updated at programme and course site level, the accumulation of these small incremental changes means that, as Maren Deepwell, ALT's CEO, stated “it is likely that VLE users would find that their platform would be substantially revised at least once every academic year.”
The application of the regulation to specific instances was discussed further in relation to the role of head of eLearning in ensuring compliance. Some of the points or issues raised were:
  • The term “substantial revision” doesn’t have a comprehensive legal definition and is difficult to apply to VLEs which are extensive collections of websites and webpages.
  • Some institutions treat archived VLE content independently from currently active content
  • The advice seemed generally to be that archived materials that may be critical to student study like past papers needs to be accessible. We can be more relaxed about other content like older handbooks which are seldom accessed.
  • Do student submissions and group work submissions need to be accessible to markers/examiners?
  • Is it the institution’s responsibility to ensure that student-created content is accessible?
  • Certain disciplines may need to make individual statements, for example, maths, cyber security and lecture recording


After lunch there were several presentations from HEPs on effective practices in implementing of the new regulations. At University College London (UCL), Fiona Strawbridge and colleagues have extended their preparation work to look into what the sector needs. Using Policy Connect to brief senior leaders was very important. UCL recommended that HeLF members join JISC's mailing list on Digital Accessibility Regulations as a very useful source of information and support for FE/HE communities. They also signposted the Further and Higher Education Digital Accessibility Working Group (FHEDAWG) which aims to collate and create exemplars of Accessibility Statements, guidance and frameworks on how to meet the new standards, good practice guidance in areas where the government’s official guidance is not clear. A key objective of the group is to liaise and lobby UK regulatory bodies to disseminate guidance adapted to the post-16 Education sector. UCL also shared some useful advice and clues drawn from their experience of effecting changes:
  • Commit to supporting exceptions outside full compliance;
  • Identify platforms in scope;
  • Develop policies;
  • More localised action;
  • Prioritise remedial measures;
  • Establish a central point of contact.


Claire Gardnener (@Cl4ireG) from the University of Derby described how they have implemented Blackboard Ally using a “big bang” approach across the entire institution. They prioritised their training on new resources creation rather than existing ones. They also used Ally to make changes to the Powerpoint template for lecture slides. Their project started 18 months ago with a Business case arguing that Ally would help to alleviate the disappearance of the Disabled Student Allowance (DSA). They ran a physical and digital accessibility audit over 25,000 modules, both current and historic. Using the quantitative reports from Ally and qualitative feedback from students on the impact of poor accessibility, tutors have made their resources more accessible. As a result, the Accessibility metric provided in Ally has gone up 15% over the past 18 months. They plan to publish their VLE Accessibility Statement by 23rd September – going to review it post upgrade in July/August. They are starting to focus more on students and how their understanding of accessibility issues is part of their digital capability. Blackboard have created a very active Ally user group publicly available at https://usergroup.ally.ac.uk

Richard Walker told us about University of York's Accessibility working group set up November 2018 which has been a great opportunity to implement sustainable changes to good practice, digital accessibility. The group has drawn on internal and sector expertise and, crucially, has included student representatives. Their key message is that Accessibility is not just about reacting to students that declare a disability but about driving inclusive practice which benefits everyone. York did a review of learning teaching and assessment content. Student interns carried out a comprehensive review using 19 review criteria including things that Ally would not pick up like “meaningful short names”. From the review, structured support was offered to depts; Ally training, champions and buddies and has led to a wider review of institutional web services and websites and consolidation of guidance to staff and students

Phil Vincent from York St John University (YSJ) joined us to share how they started their work implementing Blackboard Ally into Moodle five weeks ago. YSJ's Accessibility working group was led by the University Secretary. They led initiatives like:
  • Making lots of use of posters from the University of Hull “Do and Don’t“ forma;t
  • Setting up and signposting an email address for support and advice;
  • Providing Digital Accessibility training e.g. how to make accessible documents and content;
  • Step by step feedback for academics, etc.


During breaks, afternoon group activities and Q&A, there was much discussion about how the regulation would be applied. some of the discussions topics are below:
  • Transcripts, Formats for mobile use and tags for images – are they useful to everyone?
  • Anticipatory duty – hypothetical – reacting to student needs/a tailored approach
  • How do you win hearts and minds to develop content differently
  • Do you lock down authorship to only people who pass the test
  • The awareness challenge isn’t ours alone
  • Embed accessibility awareness into PG Cert and academic development training for lecturers
  • Multi-pronged approach
  • The number of systems in scope at each institution which can reach 200+
  • The significant difference from GDPR - Sanctions not clear.
  • The risks – individual, or class action, no-win-no-fee lawyers pursuing a case
  • Making more use of Microsoft Office365 tools to support Accessibility;
  • Power of student and people stories;
  • JISC could broker some baseline guidance and legal advice leading the sector efforts to meet the new regulatory requirements;
  • We can’t fix it all, but how can we at least make things better? We should aim at progress



Thank you to everyone who attended this popular event and to the University of Birmingham, for hosting and to the HeLF Steering Group for organising.

The next HeLF event will take place in Glasgow in November.