Will the new Accessibility Regulations make any real difference?

closed padlock on a shut dor

On 23 September, 2018, the EU Web Accessibility Directive became law. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 calls for websites and mobile applications of public sector bodies to meet an accessibility requirement. While not explicitly referring to ‘Virtual Learning Environments (VLEs), course documents, and video recordings of lectures’ as listed by Wonkhe the need for online content to be perceivable, operable, understandable and robust (WCAG 2.0) strongly suggests this is the case.

However, it isn’t obvious.

The majority of media coverage I’ve seen so far prioritises the technical structures of websites and mobile apps. Neither Jisc’s Accessible Organisations or Gov.uk’s Make your public sector website or app accessible make explicit reference to resources for teaching and learning.

white plasticine person carrying a gold key

So already I’m confused. Exactly what does the law say with regard to the day-to-day digital documents uploaded to institutional VLEs?

It seemed I had to do what my first supervisor always advised – read the original text. I started with the European Directive.

Ignoring the paradox of centre alignment, capital letters and fully justified paragraph text!

There are two references to intranets

(34) Member States should be able to extend the application of this Directive to other types of websites and mobile applications, in particular intranet or extranet websites and mobile applications not covered by this Directive which are designed for and used by a limited number of persons in the workplace or in education….

Paragraph 37 was more helpful with regard to accessibility requirements.

(37)

The four principles of accessibility are: perceivability, meaning that information and user interface components must be presentable to users in ways they can perceive; operability, meaning that user interface components and navigation must be operable; understandability, meaning that information and the operation of the user interface must be understandable; and robustness, meaning that content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies. (my emphasis)

So there it is!

If content has to be robust it has to be accessible.

It seems the detail is in the exemptions. The Directive refers to the content of extranets and intranets while the UK statute, the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations also list content under the exemptions.

(2) ‘These Regulations do not apply to the following content of a website and mobile application of a public sector body

  • office file formats published before 23rd September 2018…
  • pre-recorded time-based media published before 23rd September 2020.

Office file formats are defined as ‘a document in a format that is not intended primarily for use on the web and that is included in web pages, such as Adobe Portable Document Format, Microsoft Office documents or their open-source equivalents.’

It sounds like everything uploaded to a VLE has to comply.

The law came into force this week. All new content has to be compliant within one year and existing websites within two years..

I should be delighted, I think.

black silhouette of a person juming for joy against a background of words meaning delight

Instead, I’m not sure what real difference this will make.  Accessibility is an attitude as much as a practice. It’s complex.  While the new law makes it clear the structures of websites and apps must be accessible, it could have done more to define the nature of the digital content it applies to.

PDF, Word, PowerPoint, audio and video are probably the most frequently used file formats by staff who teach and support learning.  Is the law really saying each of these have to be accessible i.e. follow WCA2 and be perceivable, operable, understandable and robust? If so it would be useful to see this stated more explicitly.

MS Office logos

I have questions.

What about teaching and learning material on institutional blogs, or student work posted on sites provided by universities, or feedback given using audio or video on a VLE?

Changing practice requires a sound rationale. You shouldn’t need to be a lawyer to understand the law but this is how it feels with regards to the Regulations .

I feel bad about my lack of enthusiasm but revisiting the Digital Soapbox  shows some of the breadth and scale of digital exclusion issues.

These posts go back eight years. What has changed?

Digital inaccessibility is the scandal of 21st century. The social model with regard to the built environment is broken every day. Categories of ‘disablement’ grow incrementally year on year, while support for equal opportunities for access and participation gets less.

black and white image of a wheelchair on the edge of a kerb

Digital exclusion is part of larger structured attitudes towards difference and diversity. For all legislation is needed as a baseline, I’m not sure these new Accessibility Regulations will make a great deal of difference to day-to-day practice.

Lee Fallin and I have been looking for ways to support digitally inclusive literacy and developed this poster suggesting changes in habits with digital content e.g. selecting a good colour contrast and a readable font.

Following the tips on Designing for diverse learners could make a big difference to how students access text, images and multimedia. The new Accessibility Regulations are big on structures but vague on content. Ensuring accessible resources comes down to the basics with text and image. This is our starting point and the poster is freely available to anyone who wants to use, reuse or repurpose it.

Accessibility was a fundamental ambition of the early web pioneers.

‘The power of the Web is in its universality. Access by everyone regardless of disability is an essential aspect.’ Tim Berners Lee (1997) World Wide Web Consortium (W3C) Launches Web Accessibility Initiative. WAI press release 7 April 1997. www.w3.org/Press/WAI-Launch.html

The impact of this project on the users with disabilities is to give them the same access to information as users without a disability. In addition, if we succeed making web accessibility the norm rather than the exception, this will benefit not only the disability community but the entire population.”  Daniel Dardailler (1997) W3C Web Accessibility Initiative Project Manager Telematics Applications Programme TIDE Proposal.Web Accessibility Initiative (WAI) http://www.w3.org/WAI/TIDE/f1.htm 

Twenty years on digital content is more inaccessible than ever.

Will these regulations make any real difference?

Hating to say it, but I’m not sure they will.

Please, somebody tell me I’m wrong!

political and critical; a personal reflection #ALTC #femedtech

green nd white ALT logo

ALT and motherhood on the same page?

I didn’t see that coming!.

Last week Catherine Cronin and Frances Bell presented A personal, feminist and critical retrospective of Learning (and) Technology, 1994-2018 describing themselves as IT professionals, lecturers, community educators, postgraduate students, researchers, feminists, social activists, and mothers.

Since watching the live stream, I’ve been reflecting on political and critical perspectives and, following my last post Start the Week Backwards have written this response to the zeitgeist mood of the 25th ALTc.

My career’s been shaped by motherhood, divorcehood and resulting single-parenthood.  Built round term-times, it was one long juggling act, never stopping, never resting, life full on until the nest was empty and I woke up one day with the whole weekend ahead and no idea of what to do.

image showing the word start on a road

It’s been liberating to acknowledge a gendered perspective to my decades working with education technology. Last week in Start the Week Backwards I returned to 1989, to my first degree as a mature ‘widening participation’ student, my early encounter with DOS computers running Wordstar and Lotus. I cried during an ‘IT Test’ when I accidentally pressed the Insert key.  I didn’t know it existed, never mind why all my text was being overtyped.

I hope I never forget how that felt.

cartoon showing a person facing angry technology with the caption The Battle we all Face

My first degree was transformative in so many ways. It cost me my marriage.

Apparently, no one likes a clever git.

I moved from country to inner city. It was February 1991. The coldest winter with the heaviest snow. My student loan fixed the boiler and bought a cooker. The second-hand electric shop wanted £5 for delivery. I borrowed a sack barrow and delivered it myself.

The greatest life lesson I learned was this.

Regardless of gender, the parent with the least earning potential takes on most of the childcare. A salutary lesson.  A universal rule like Jane Austen on men and wives (note the primary identity!)

Before the start of the conversation started by Catherine and Frances, the last time I ‘outed’ myself as a parent was five years ago in Who will clean the toilets after the revolution This was my problem with feminism. The personal is political but it has to be practical too.

blue plasticine person leaning over a white toilet

Today I’m comfortable in my empty nest and appreciate my freedom of choice. I admire colleagues who juggle full-time work alongside small children, especially those with babies. Feminism and equality campaigns have made flexible working possible, although I suspect it’s an ongoing struggle, financially, emotionally and physically. The women who make it are stars!

gold stars

A personal and feminist lens shows gender affected me. Being a female of a certain age when I entered HE has influenced opportunities and choices.  During Catherine and Frances’s presentation, I looked for a photo of myself with the children, realising for the first time how few there are.  Lots of babies, with and without their father, but not with me. This was before the days of mobile phones and selfies – not that long ago – all I could find were two.

This is what happens to women in the home. They become invisible. It’s the public work versus the private ‘hearth and home’ binary all made real.

cut out images of domestic tools and tasks

I wouldn’t have it any different, but I do sometimes wonder how different it might have been.

My career in adult, community and higher education has been eclectic, like so many others. An  eclecticness shared so creatively in a timeline by Amber thomas, who gave a keynote at #ALTc. Throughout my working life, I’ve been a mother, step-mother, carer.  Constant but rarely discussed. Why? Is it because I’ve worked mostly alongside men?  I’ve never thought of this before. It shows the power of Catherine and Frances using the motherhood word in conjunction with technology, research, social activism. Been there. Done that. But it’s not often I’ve reclaimed gender in public.

Thank you women of ALTc, for giving us permission to do the same.

We need more stars!

gold starsgold starsgold stars

Like so many women, I’ve done life backwards. Much of my knowledge is experiential. This means I often feel I’m swimming against the tide.

Practice can disempower in the way assumptions discriminate.

Being a female of a certain age, I feel othered in ways I imagine are not shared by men. I write about the digital but have analogue roots The ‘O’ word is banned. I refuse to accept life as linear. For me, it’s circular and spiral, like a a labyrinth. Remember the labyrinths? This is another area of work I’d love to resurrect, but people move on and the early momentum of a movement looking at walking meditative practice for learning development and reflection feels faded. At least the blog and the photos remain Walking the Labyrinth

Women who do too much!

Why are we so driven?

Julian's Bower Turf Labyrinth at Alkeborough, North Lincolnshire
Julian’s Bower Turf Labyrinth at Alkeborough, North Lincolnshire

Age is discriminatory.

Socially, culturally, politically….

Take the phrase Early Career Researcher. It ‘Others’ me. I feel excluded. My PhD is the biggest independent piece of research I’ve done but in terms of time it’s late rather than early. I have two degrees and two Masters. I hold CMALT plus SFHEA. If I’m not an Early Career Researcher, what am I?

Identity has been an issue for some time.

I was Senior Lecturer in Education Development. Now I’m a Teaching Enhancement Advisor in Professional Services.

a white building with the word university in silver

Take the word ‘academic’ off your employment contract and what does it mean?

Who am I within university tradition and practice?  Where do I fit?

Amber’s keynote was inspirational.  It spoke to all women with eclectic careers built round the public face of ed tech alongside the private space of hearth and home. Amber’s timeline reinforced how the industry continually transforms itself, creating new identities to solve the same old issues.

We know.

Our voices may have been silenced but we know what’s going on.

It’s not about the technology.

This is why the promised transformation hasn’t happened.

Like attracts like and technology determinist approaches won’t reach the non-digital whose doors are closed and habits fixed. This is not to belittle either but we need to talk. To everyone across borders and boundaries; to everyone involved in creating opportunities for students to learn.

We need to learn too.

I like an Appreciative Inquiry approach. This assumes the answers are in the room. Rather than investing in expensive external consultancy and the input of perceived ‘experts’,  we should invest in exploring ways of sharing what we already know.

I like Jung’s theory of collective unconscious. I believe in the possibility of univerisal memories, that shared expereinces create energy. It explains the attraction of an open fire and the awe of layng on a hill top below a night sky full of stars.

Memories are strange phenomena. They disappear when you want them then reappear for no apparent reason. Proust’s Madeleine has happened to us all. Sarsaparilla on your tongue. Electric shivers from a full moon.

full moon at night shining on dark waer

Pedagogic practice hasn’t really changed. My first experience of higher education was during A levels. I signed up for an evening class at the Universty of Hull. In the Wilberforce Building. Now I work there. The building has had a facelift but the rooms are fundamentally the same – small with no windows and rows of desks facing the front.

Last year I finished a part-time degree at Hull. Six years of attendance. Twelve modules taught in the same Wilberforce Building in rooms with rows of desks facing the front. No technology was used during the making of this degree. The only time the PC was switched on was student presentations where I used Powerpoint.

lassroom with rows of empty desks and chairs all facing the board at teh front

When is comes to teaching and leaning, technology is not the solution. There’s no magic tool to solve the problems but plenty of technology-based solutions which have added to them.

Learning and teaching is where we need to begin. The design of opportunities for learning with or without the tech. It’s 2018. It’s going to be in there somewhere, in the same way it’s at home and in the workplace.

So what are the problems?

Well, the status of being digitally literate for starters. This is a requirement which needs to be elevated alongside english and maths, but even so, technology is not the answer. Not on its own.

There are bigger issues.

Like widening participation; the opening up of university courses ‘… for all those who are qualified by ability and attainment to pursue them and who wish to do so.”  (Robbins Report, 1963)

The NSS arrived with promises it would not lead to league tables when it was clear this was exactly what would happen.  Today, the NSS combined with student fees, pose a potential (and predictable) perfect storm.

Despite it all, I still believe in the concept of higher education for the public good. The often quoted analogy of public good with lighthouses is – I think – apt. Shining light into darkness, warning of danger.

Danger?

light house on Isle of Skye at teh end f a long rocky prootary looking out to sea

Education can hurt and be uncomfortable. It should be full of liminal spaces and troublesome knowledge. Unfortunately, it can break relationships and create division – but also open hearts and minds, shine light on exclusion and discrimination, be a beacon for socially democratic thinking and provide opportunities for individuals to be transformed and thrive.

Why shouldnt it be for the public good?

person standing in front of the siplay boards in an airport

Across the country, thousands are preparing for arrival on campus. Diverse cohorts are packing bags and preparing to leave home. Others are sitting late at night juggling the school run on paper with nursery pickups and contingency plans for when the grandparents are ill. Those who’ve had unexpected life changes are looking to university with no idea of what lies ahead. To those who are unsure, I’d say feel the fear and do it.

image showing a erson leaping across a chasm at suset

In all of this, the women working in higher education, in partcular in ed tech and digital practice, have their own unique contribution to make. Accustomed to suppressing the maternal and personal, they can add hugely to the collaborative processes of teaching and learning.

We need a platform and a voice.

I hope the conversations started at ALTc are enabled to continue.

table discussion with an open laptop

images from ALT and pixabay