Accessibility for Digital Communications Policy

Purpose

This accessibility for digital communications policy commits the Department of Communities and Justice (DCJ) to existing legislated and other applicable standards.

The purpose of this policy is to ensure the department’s digital communications:

are accessible and inclusive of all users regardless of their ability and environment
meet the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standard
comply with legislative requirements under the Disability Discrimination Act 1992 and the UN Convention on the Rights of Persons with Disabilities
comply with Government accessibility standards for Information and Communication Technologies (ICT)
align with the DCJ Disability Inclusion Action Plan 2020 – 2024, ensuring that people with disability are aware of, and can use information services and programs.

This policy provides a framework for ensuring that DCJ digital content is accessible.

Background

Accessibility is an essential feature of all digital content produced by government bodies. People may not have a choice when using a public sector website or mobile app, so it’s important that they work for everyone. Accessible digital communication ensures everyone has the same access and opportunity to:

read publications
use websites
understand and access visuals (for example: images, data depictions, diagrams)
attend events
be able to participate in public consultation
respond in emergency situations and
find out about government policies and programs.

The NSW Government’s Circular on Website Management encourages the agencies to streamline their websites and apply NSW Design System to ensure a consistent user experience. The Design Standard provides the minimum expectations for delivering a product or service, and the supporting guidance on how to meet these minimum expectations (for example: how to meet Web Content Accessibility Guidelines (WCAG) 2.1 at an AA level).

The Digital Transformation Agency strongly encourages all Australian, state and territory government websites to meet WCAG 2.1 Level AA to provide a more accessible experience to all users of the online channels.

Accessibility as a value

DCJ will ensure the digital communications are accessible and inclusive of all users regardless of their ability and environment.

Our users include people:

with a permanent or temporary disability such as:
- blindness and low vision
- colour blindness
- learning disabilities
- cognitive disability
- limited movement
- speech disabilities
- photosensitivity
- neurological disability
- auditory disability
with changing abilities because of ageing
with lower literacy
from diverse language backgrounds
with device limitations such as devices with images disabled or without audio enabled
with restricted bandwidth to download large media content files
with a need for reasonable adjustment at DCJ workplace for accessing digital communications

and/or any combination of these.

Definitions

Term	Definition
Assistive technology	Assistive devices and technologies help to maintain or improve an individual’s functioning, independence, community participation and overall well-being. For example: use of wheelchairs, prostheses, hearings aids, visual aids, and specialised computer software and hardware that increase mobility, hearing, vision, or communication capacities.
Digital Content	Digital content is the information you see on a web page, in a web application or in an email. It may include for example, diagrams, maps, graphs, dashboard, photo, graphics, a piece of written text, a form you need to fill in, audio content, video content and or a combination of any of these.
Disability	Under the Disability Inclusion Act 2014 (NSW), “disability" relates to a person’s experience. It describes a long-term physical, psychiatric, intellectual or sensory impairment that, in interaction with various barriers, may hinder a person’s ability to participate in the community on an equal basis with others.
Easy Read	Easy Read combines text with layout and imagery to simplify and explain information.
ICT	Information Communications and Technology
Plain English	Plain English is a set of writing principles that guide people who write as part of their everyday work. Plain English guidelines recommend keeping sentences short, use of active voice, avoid slang, to write with the reader in mind and with the right tone of voice, that is clear and concise.
Social Media	Websites and computer programs that allow people to communicate and share information on the internet using a computer or mobile phone.
User	A user is a person who uses something such as a place, facility, product, or machine. In this document, user/users refer to public users and DCJ employees.
WCAG	The Web Content Accessibility Guidelines (WCAG) are internationally recognised and give a universal standard for web content accessibility. WCAG 2.1 is based on four design principles: content should be perceivable, operable, understandable and robust. By focusing on principles, not technology, the guidelines emphasise the need to think about the different ways people interact with content. The three levels of WCAG compliance include A (minimal), AA (acceptable) and AAA (optimal).
Web page	A page of information on the internet about a particular subject, that forms a part of a website.

Scope

This policy applies to digital content on all DCJ websites, applications, tools, and platforms, including:

intranets and public facing websites including web content and documents (PDF, PowerPoint, Excel, Word and other text formats)
DCJ websites hosted by third-party providers, for example careers.dcj.nsw.gov.au
websites created through collaborative partnerships with a non-government organisation and hosted on DCJ technical platforms
DCJ content on social media channels including and not limited to YouTube, Instagram, Facebook, Twitter, LinkedIn and related technologies such as the Digital Asset Management (DAM) system
any digital content in the form of data, text, sound or images that is available through DCJ web applications, tools, or devices (such as email applications and Microsoft Teams)
online events such as and not limited to webinars, meetings, virtual tours
online employee training.

Policy statement

DCJ will:

meet WCAG 2.1 AA compliance requirements for digital content presented on:
- public facing and internal websites
- social media channels
- applications, tools and platforms.
write content in plain English
make all online documents accessible
consider if content should be supplied in Easy Read format
consider if content should be supplied in languages other than English
ensure procurement of technologies will comply with the accessibility requirements.

Compliance requirements

It is mandatory for all digital content and applications to:

comply with WCAG 2.1 AA standard
publish content in a web page format
make all document formats (Word, PDF, Excel etc.) accessible so that the documents may be read by assistive technologies
be written in plain English so that it can be understood by a person of age nine reading level. If there's a need for advanced technical language, content should be written so that it can be understood by ages 12 to 14.
comply with Government accessibility standards for ICT.

It is also essential that consideration be given to providing content in:

Easy Read format (for example, resources such as factsheets and information on how to find and use department services)
languages other than English.

Business areas are responsible for deciding if content requires translation and/or Easy Read format.

Risks of inaccessible digital experience

The risks of inaccessible digital experience include:

users unable to access or act on digital information relating to DCJ services
making DCJ liable to complaints under the Disability Discrimination Act 1992 or the Anti-Discrimination Act 1977
loss of trust in the reliability of DCJ digital content and therefore the DCJ brand
reducing the productivity of DCJ staff members because non-accessible documents take longer to read and comprehend
exposing DCJ to the risk of adverse findings following an audit by the NSW Auditor-General or complaints from peak bodies and the public
not supporting an inclusive culture for staff by excluding people with:
- permanent or temporary disability such as and not limited to blindness and low vision, learning disabilities, cognitive limitations, limited movement, speech disabilities, photosensitivity, neurological disability, auditory disability
- changing abilities because of ageing
- device limitations such as devices with images or audio disabled
- lower literacy
- diverse language backgrounds
- restricted bandwidth to download large media content files
- reasonable adjustments at DCJ workplace to access digital communications.

and/or any combination of these.

Commonwealth legislation

The Disability Discrimination Act 1992 (Commonwealth) requires government agencies to give information and services in a non-discriminatory and accessible way. This ensures people with disability have the same basic rights as other people in the community.

In 2008, the federal government ratified the UN Convention on the Rights of Persons with Disabilities. Articles 9 and 21 of the convention recognise that having equal access to information, communications and services, including on the internet, is a human right.

NSW legislation

The Disability Inclusion Act 2014 (NSW) makes it clear that people with disability have the right to access information from government agencies in a way that is appropriate for their disability and cultural background, and enables them to make informed choices.

The Multicultural NSW Act 2000 (NSW) specifies the need to respect and make provision for the culture, language and religion of others within an Australian legal and institutional framework. NSW Government policy is that the NSW Government agencies fund the provision of language services (that is, interpreters and translated materials) when dealing with clients, in order to provide all clients with access to Government services.

Responsibilities

Executive directors, directors and managers will promote compliance with the Accessibility for Digital Communications Policy to their staff.
All staff involved in:
- creating or modifying digital content, including text, data information, diagrams, graphs, flowcharts, maps, images, videos and similar resources
- procuring ICT goods and services

are required to comply with the Accessibility for Digital Communications Policy.

All business area managers who:
- commission interactive applications or content from third parties to make it available as a DCJ digital product
- make departmental content available on third-party social media sites (such as YouTube)
- create or commission external services to publish online resources in languages other than English

will ensure vendors are made aware of and comply with the Accessibility for Digital Communications Policy and that the content made available on third party applications complies with the policy.

Document information

Version: 1.0

Due for review: August 2022

Last updated:

20 May 2022