We've decided to use a combination of methods for our organisation, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the No. 2 Regulations.
We're doing a detailed accessibility check for the main Ipswich Borough Council website
The process for doing a detailed check will include:
We believe it is reasonable to carry out a detailed check for www.ipswich.gov.uk as this covers the most important content provided by Ipswich Borough Council.
Our accessibility statement for www.ipswich.gov.uk covers the problems we have found and our plans to fix them.
We'll carry out basic accessibility checks on Ipswich Borough Council websites that are independent of www.ipswich.gov.uk
These basic checks will be carried out by the service responsible for the website, based on:
Services will check samples of content, which will include
Accessibility statements for these websites will be published independently of www.ipswich.gov.uk
We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to pay an auditor to do a detailed check on our entire collection of websites.
Our most important content and transactions are provided on our main website, www.ipswich.gov.uk and we're doing detailed checks of these.
However, we do not believe the benefit of paying for detailed checks of our other websites would justify the impact on our organisation except where those sites are specifically aimed at people with a disability.
We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix the accessibility issues on some of our third-party systems and interactive forms.
Many of these are built and hosted through third party software and ‘skinned’ to look like our website. We do not have direct control over these third-party systems.
We’ve considered the cost of fixing the issues and do not believe that the extra improvements that could be gained from paying for these issues to be fixed would justify the cost.
Having carried out a detailed check of www.ipswich.gov.uk, we've also assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on www.ipswich.gov.uk since 23 September 2018.
The majority of these documents have never been viewed, therefore they are not negatively impacting users with disabilities or impairments. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified.
We will focus on fixing the most viewed documents on www.ipswich.gov.uk (top 10%), and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.
Ipswich Borough Council has 24 websites independent of www.ipswich.gov.uk.
These sites cover a variety of purpose, size and content.
Most of our independent sites are relatively small in scale, usage and complexity, and do not provide essential transactions.
As of 30 November 2021, there were 3,050 documents on www.ipswich.gov.uk published since 23 September 2018 (within scope of the No. 2 Regulations).
Focusing on fixing the top 10% most viewed documents is equivalent to about 305 documents.
We have estimated the costs for an external expert to do a detailed check (and later re-audit) on our full collection of websites.
On the basis of these assumptions, we estimate the cost to our organisation overall for detailed audits for all of our websites and services would be between £72,800 and £270,400.
These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. These include:
It's difficult to know how long it would take to make every document accessible without first reviewing each one.
However, if it took approximately one hour to review and fix each document within scope, fixing all 3,050 would take 412 working days (based on a 7.4 hour working day at Ipswich Borough Council).
Assessment of costs and benefits
We believe that:
In reaching this decision, we have considered the following:
Ipswich Borough Council is a local authority managing increasing front-line service demands but reducing annual budgets.
During 2020 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services.
The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities, taking into account the frequency and duration of use of the independent websites
We believe the potential of paying that amount just on audits (before we've actually fixed anything) is unreasonable.
Many of the services that maintain sites independent of www.ipswich.gov.uk provide front-line services to the public.
We believe that:
Our services will be assisted in their basic checks by:
Our Web Team is leading the detailed check of www.ipswich.gov.uk and our digital transactions. However, it is a small team, and the scale of co-ordinating the auditing and fixing of our main website and transactions leading up to 23 September 2020 - in addition to their other essential functions - means they lack the capacity to carry out a detailed audit of our other sites.
The estimated costs and benefits for our organisation: in relation to the estimated benefits for persons with disabilities taking into account the low level of usage for most documents
The cost of making all documents within scope of the No. 2 Regulations on www.ipswich.gov.uk accessible would be approximately 350 working days.
The vast majority of this work would have little to no benefit to users with disabilities due to the low usage of the majority of online documents.
Our users will benefit from us making our websites and online documents accessible.
However, we do not believe that for the majority of our websites the extra improvements that could be gained from paying for a detailed check would justify the cost over doing a basic check internally.
We also believe that users will benefit most from us focusing our available resources on fixing the most used documents on www.ipswich.gov.uk, and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.
Ipswich Borough Council,
Grafton House,
15-17 Russell Road,
Ipswich,
IP1 2DE
01473 432000
