Web accessibility: Because even if your company doesn’t want to, it has to

Web accessibility is self-evidently a good thing. The more people who can access and understand your content, the better, right? But that doesn’t mean that getting people to come on “the accessibility journey” with you is always easy. It sounds difficult, the pay-off isn’t always easy to imagine, and for some people it seems like a touchy-feely way to make your website somehow less sparkly. These excuses are all wrong, but that doesn’t mean no-one believes them.

Some people you just can’t turn into a massive champion of accessibility. Sorry. Some people don’t particularly care – they just want to get stuff online in the most painless way possible. If you’ve exhausted your friendly options, the next logical step is therefore increase the pain that inaccessible content causes them.

In the corporate world there’s at least a chance that your company already has a policy that supports accessibility, even if no-one’s really following it. Invisible policies are easy to ignore, but by drawing attention to your company’s own rules you make it harder for people to force through bad, inaccessible content.

The request: Publish an inaccessible PDF. Now.

I’m settling back into professional life in New Zealand and I still don’t know the web industry’s regulatory background too well. So today I decided to look into it from the point of view of a web content guy who works at a bank here. (Not a huge stretch, admittedly, since I’m a web content guy for an Aussie bank, but they say you should write about what you know.) Taking a common problem, how would I deal with a request to publish an inaccessible PDF?

Let’s assume that the job is urgent, the stakeholder powerful, and the content difficult to extract into any other format. In short, doing things the nice way isn’t an option today. When the way of the carrot fails, one must know how to wield a stick. In this case, what can you do? WCAG 2.0 isn’t a binding piece of legislation, and the best-known national standards only apply to governmental websites.

Digging out a reason to say “no”

Luckily, banks have already made the exact stakeholder-beating stick that we need – it’s just not immediately obvious. Here’s the trail I managed to piece together solely from public websites. For a big, established industry it’s not unusual.

Companies, as part of an industry group, have made a broad promise

I started with the banks themselves.

BNZ’s “Supporting communities” page has a section about “Making banking accessible to everyone” (link updated 14/10/2016, quote updated 24/2/2017), which says in part:

Together with the New Zealand Bankers’ Association and other New Zealand banks, we’ve supported the introduction of voluntary guidelines to meet the needs of elderly and disabled customers.

[Emphasis added. You’ll see why soon.]

Westpac is similar:

We’ve also worked in cooperation with other New Zealand banks and the NZBA to back the introduction of customer service guidelines for our elderly and disabled customers.

Like the others, Kiwibank’s Code of Banking Responsibility tells us that they’re going to follow the NZBA’s lead:

To help ensure we meet our obligations to New Zealand, Kiwibank has signed up to the Code of Banking Practice, which sets out best industry practice and what banks will do for customers.

Worringly, I couldn’t find anything on ASB or ANZ’s websites about this sort of thing (unless you count ANZ’s Australian site, but in this case I don’t). But, just like the others, they’re members of the NZ Bankers’ Association (NZBA), so they’re not off the hook.

Still, all we have are “support”, “best industry practice” and “guidelines” for serving people with a disability. This isn’t much use if you want a solid reason to send a PDF back to where it came from. We need details.

Follow the trail back to the industry group

The NZBA guidelines that our banks “support” and “back” start with the Code of Banking Practice. The code’s introduction, paragraph 1.2c, says:

We will recognise the needs of elderly and disabled Customers to have access to banking services and we will use our reasonable endeavours to enhance access to those services for these Customers.

This broad commitment is better, but we need to know what “reasonable endeavours” we have to take. Is it reasonable to hold back a lump of inaccessible content? Helpfully, the appendix clarifies that “reasonable endeavours”:

Means necessary and appropriate modification and adjustments not imposing a disproportionate or undue burden, where needed…to ensure to persons with disabilities the enjoyment or exercise on an equal basis with others.

Now we’re getting somewhere, especially with that “necessary […] modification” and “equal basis” stuff. But if we’re composing a strongly-worded response to a company senior we still need more.

The industry relies on existing standards

By creating guidelines for the way they should do things, industries are often trying to avoid direct government regulation. This means that “voluntary” guidelines are often written in the style of legislation – strong, detailed and official-sounding.

In this case, unsurprisingly, the Bankers’ Association hasn’t come up with its own web standards. Instead the Voluntary Guidelines to Assist Banks to Meet the Needs of Older and Disabled Customers, paragraph 5.10 [edited below] commits banks to:

consider…use of W3C web accessibility best practice standard, and the accessibility-related New Zealand e-government web standards and recommendations.

We’re getting close to our slam dunk here.

The “New Zealand e-government standards” have been renamed the New Zealand Government Web Standards. The “Technical” section of these standards requires us to aim for WCAG 2.0 success criteria AA, and also adds a few NZ-specific standards (known as the ‘New Zealand layer’).

In the case of the PDF problem, the New Zealand layer is directly on our side, too: “You may publish your document in any format only if you provide an accessible alternative.”

The lesson: What sounds like an empty corporate crap is a lot more than that

This all began with a watery-sounding start along the lines of “support for the introduction of customer service guidelines for elderly and disabled customers”. That’s not exactly a convincing line to quote back at a forceful, disinterested stakeholder. But by following a path through a few dense documents we’ve ended up on incredibly solid ground – an explicit commitment to WCAG 2.0.

This electronic paper trail tells us that all the major banks in this country have all promised to aim for AA compliance with WCAG 2.0. Even though the accessibility statements on their own websites can seem weak (or aren’t even there to start with), a little bit of digging gives us web professionals some very staunch support when we push for accessibility.

So the message to our difficult stakeholder isn’t “we’d rather not publish this document, because some people won’t be able to read it”. Instead it’s “we’re bound by NZBA standards as well as national and international web requirements. All of these things prevent us from publishing this document”.

This is all public. If you don’t do the right thing, someone else will

Everything linked and quoted above is out there on the web. If you don’t make a stand for accessibility and keep your company in line with the promises it’s made, you can expect that one day your customers will pull you up instead. And they’ll have much less reason to be nice and polite (not to mention non-litigious) when they do.


Disclosure: I work for the National Australia Bank (NAB). BNZ is part of the NAB Group, and for a few months now I’ve been working alongside (but not with, or for) some of BNZ’s web team. The example of a grumpy stakeholder pushing an inaccessible PDF is, despite its incredibly realistic appearance, fictional.

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