Accessibility in Further Education
All Able have been commissioned by the Thomas Pocklington Trust to investigates how blind and partially sighted students access information and assistive technology in mainstream further education (FE). The 2021 research had widespread impact and we hope the 2022 update will continue to support policy decisions and sector wide accessibility improvements.
Research to understand how blind and partially sighted students access information and assistive technology
Many young people when leaving school choose to study at college. This is an exciting time for any student as they take that next step towards employment and independence.
However, for many blind and partially sighted students, we know that their journey can encounter many barriers that aren’t experienced by their sighted peers. To help get a better understanding, we commissioned All Able Ltd to investigate accessible information practices, compliance with accessibility regulations and how blind and partially sighted students access information and assistive technology in mainstream further education (FE).
2022 Update
2021 Research
When asked about if the environment was more accessible:
… it would be good for me because I'd have way more confidence in what I'd like to learn and be able to get a lot more things done... I honestly think it would help a ton, mean me being able to actually move up in what I wanted to do. It would give me a lot more confidence in the work. And would make me feel a lot better about learning.
- (Student with a visual impairment)
Outcomes
The 2021 research was well received by colleges and a wider audience interested in improving accessibility for all students. The research directly led to the following events:
Thomas Pocklington Trust published the Making College Accessible resources area to help college staff improve accessibility.
The research was discussed on Radio 4’s In Touch programme
Press attention - Further Education (FE) Week
1 in 4 colleges have a Good or Complaint statement as of the 2022 update. A 7.72% increase since the initial research findings (up to 24.45%).
Drop in poor quality and no statements - 63.18% (down 11.82% since 2021)
A direct impact through collaboration with the Association of Colleges, appearance on national radio, and used as a primary source in the Lord Holmes DSA paper to the House of Lords, leading to an increase in compliance across the sector and raised awareness.
“There was a report in FE Week last year that the Equality, Diversity and Inclusivity (EDI) Committee reviewed and shared this link colleges fail legal requirement to inform visually impaired (feweek.co.uk)... As a result ‘we acknowledged that our website accessibility was not sufficient and even though we are building a new website to launch next year, we refused to wait and made a number of other changes on the back of the report’.”
- FE College Marketing Director
Findings
Compliance
All further education (FE) colleges are legally obliged to develop accessible websites, learning, teaching and assessment materials. Our research has shows that FE colleges are behind in compliance across the sector when compared to other groups such as Higher Education, NHS, or Local Government.
In 2021 the research found eight out of ten colleges in the UK did not provide the legally required accessibility information on their websites. in the 2022 update we found that through the work of All Able, Thomas Pocklington Trust and the Association of Colleges there has been a significant drop in missing guidance.
We also found that for those that make claims of full compliance, not a single one could prove the claim with all websites having many issues. This shows that there is still plenty more to be done before colleges are meeting their legal compliance and all are presenting the required information to support users.
FE statements growth October 2019 to August 2022
October 2019
Compliant: 4
Good: 10
Partial: 21
Poor: 131
No statement: 222
May 2020
Compliant: 11
Good: 5
Partial: 55
Poor: 136
No statement: 177
November 2020
Compliant: 27
Good: 27
Partial: 26
Poor: 190
No statement: 134
April 2021
Compliant: 39
Good: 32
Partial: 34
Poor: 195
No statement: 127
August 2022
Compliant: 46
Good: 57
Partial: 52
Poor: 151
No statement: 115
Disability support information
The 2021 research tested the pathways blind and partially sighted students may use to find out about support a college may provide. The responses indicated a worrying mixture in the quality and usefulness of information provided to prospective blind and partially sighted students and almost half (45%) of colleges contacted did not even respond.
“Every blind and partially sighted student should have access to a quality college education but our research shows there is a lack of inclusive practice creating a barrier to accessibility. This was seen in inaccessible software, systems and processes, and a prevailing culture in colleges where student support departments are viewed as the only teams that have a responsibility to consider the needs of people with disabilities.”
-Tara Chattaway, Head of Education at Thomas Pocklington Trust
Disproportionate Burden
Disproportionate burden is a clause in the public sector accessibility regulations that allows organisations to avoid full compliance without penalty (not indefinitely) if the organisation proves that to achieve compliance would be a ‘disproportionate burden’.
To do this they must thoroughly evidence, that compliance would for example:
Incur costs greater than the organisation has funds for
Not significantly impact disabled users
Be wasted effort if new products are to supersede current platforms
FE disproportionate burden claims are up 2.9% since 2021 (now at 10.21%) with some claims being duplicated across conglomerates. Most cases looked at in the research represent a misunderstanding of the clause and legal obligations on evidence, with only 12 of 32 claims being not in direct contradiction of the government advice. This growth can be seen as growth in maturity sector wide. We propose that the FE sector is entering a phase of maturity where awareness is higher, but expertise is still to grow - leading to more claims, but not supporting evidence.
Overlay products
Also of concern is the growing use of ‘overlay’ products, not just in the FE sector but everywhere and should be flagged as a risk to those looking for “easy” routes to compliance.
Overlays are products marketed to improve or fix accessibility issues on a website, by adding a small snippet of code, or a button to your web pages which will “fix” the user experience. Some of these products market themselves as using artificial intelligence while others advertise user customisability. We are concerned that colleges are a vulnerable sector to these such offers.
We advise that colleges avoid paying for or utilising overlay products in all cases for the following reasons:
The UK regulation monitoring body states that overlays are not considered when monitoring for compliance. Therefore, any spend on an overlay product will not help to meet compliance requirements.
Overlays often do not fix accessibility issues, or provide the service advertised. There has been a concerted effort across the accessibility sector to call out the false advertising of these products.
In recent conferences, representatives from the US Department of justice have referred to the use of overlays for compliance as “legal suicide”, which is very strong language to represent multiple cases of these overlays now in legal disputes because of false compliance claims they made to customers.
There is no alternative to an accessible by design website that you have developed in the correct way.
Recommendations
The report recommends urgent actions that Government, college leadership and college staff must take to improve support for blind and partially sighted students. These include:
Improve legal compliance with accessibility regulations across the FE sector for digital systems and learning resources.
College leadership should deliver an accessible-by-design approach in FE colleges.
FE colleges must support Special Education Needs and Disabilities (SEND)/Assisted Learning Support (ALS) teams to encourage organisational adoption of inclusive mainstream accessibility practices.
FE colleges must ensure access to accessible technology and effective training for partially sighted students in FE.
FE colleges should embed accessibility training for all students in FE colleges as a core employability skill.
Practical recommendations for colleges to embed an accessible-by-design approach include:
Implement a digital accessibility policy, making it clear that delivering an accessible-by-design approach is the responsibility of all staff, not just SEND/ALS teams.
Map the college digital estate, identify accessibility issues for each website / platform / learning resource system and prioritise remediation.
Ensure policy and processes are in place and followed by digital content teams. Creators of web pages and learning resources must deliver content which meets basic accessibility standards.
Invest in training to support staff in learning basic accessibility principles and adjustments to improve and create accessible content.
All colleges must not procure new digital systems that do not meet accessibility standards.
Engage with students to foster a more inclusive community.