Disproportionate Burden Assessment
Boston Borough Council is committed to meeting the requirement to make websites accessible, set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 ("the accessibility regulations").
However, we have a complex collection of websites and limited resources to check them all for accessibility issues.
Our approach to carrying out accessibility checks
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 have undertaken a detailed accessibility check in preparation for the development of the new main Boston Borough Council website. This has included manual testing based on GOV.UK's guidance on doing a detailed accessibility check.
As part of the launch of the new website we will also introduce automated testing of the new website using accessibility monitoring software (Silktide).
We carry out basic accessibility checks on Boston Borough Council websites that are independent of www.boston.gov.uk as part of the project plan to align with the approach for the new website.
These basic checks will be carried out by the service responsible for the website, based on:
- GOV.UK's guidance on doing a basic check
- our own internally produced guidance
Services will check samples of content, which will include:
- their homepage
- content pages that are mostly text based
- images, video and audio content
- interactive tools and transactions, like forms
- pages including login functionality, if the website has them
- PDFs and other document types they have
- dynamic content like pop-up windows
- navigation pages, including their sitemap and pages with search functionality
Disproportionate burden: checking websites
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.boston.gov.uk. We have been undertaking detailed checks of these as part of the development of the new website.
However, we do not believe the benefit of paying for detailed checks of our other websites would justify the impact on our organisation.
In addition to the Boston Borough Council main website there are a further five independent of www.boston.gov.uk
These sites cover a variety of purpose, size and content. Some of which are paid for by an individual council service or directorate.
Most of our independent sites are relatively small in scale, usage and complexity, and do not provide essential transactions.
Examples of these sites include:
- Think Boston
- Visit Boston
- South & East Lincolnshire Councils Partnership
- South & East Lincolnshire Local Plan
- One Team Hub
We have assessed that it could cost between £13,000 and £149,500 for an external expert to do a detailed check (and later re-audit) on our full collection of websites.
These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. This includes:
- a third-party day rate of £1,300
- about 1 to 3 days to audit a small website
- about 5 to 20 days to audit a large website
We will be reviewing and relaunching the additional websites after the launch of the new main site.
Disproportionate burden: fixing documents
We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on www.boston.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.
As part of the development of the new website all existing documents have been reviewed and only relevant information has been transferred to the new website in an accessible format.
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 1,656 would take 224 working days (based on a 7.4-hour working day at Boston Borough Council).
We believe that:
- The costs of paying for detailed checks for all our websites and fixing all documents would be a disproportionate burden on our organisation considering the recent launch of the main website and the planned review and relaunch of the additional websites.
- The benefit to users of paying for detailed checks on the independent websites (taking into account the frequency and duration of use of these websites) and assigning staff to fix all documents (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on Boston Borough Council
Assessment of costs and benefits
In reaching this decision, we have considered the following:
Our organisation's size and resources
Boston Borough Council is a local authority managing increasing front-line service demands but reducing annual budgets.
Since 2020 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services.
The nature of our organisation
We do provide services aimed at people with a disability, but these are generally included on our main website, www.boston.gov.uk, and associated transaction platforms.
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 up to £150,000 just on audits (before we've actually fixed anything) is unreasonable in the context of the recent launch of the main website and the planned review and relaunch of the additional websites.
Many of the services that maintain sites independent of mybostonuk.com provide front-line services to the public, e.g. waste recycling, homelessness housing allocations.
We believe that:
- maintaining statutory and essential front-line services should be prioritised over paying for independent website audits
- it would be reasonable within the meaning of the No. 2 Regulations for our services to carry out basic checks of their independent websites, and use any available budget to fix the main issues found on their sites
Our services will be assisted in their basic checks by:
- internal guidance and support from the Digital Content Team (a specialist web content and user experience team)
- support from our Public Sector Partnership Services ICT partners
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.boston.gov.uk accessible would be approximately 224 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.
How much users with a disability would benefit from making things accessible
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 relaunching the new websites, and ensuring that new documents are accessible where they are required for essential services or used by people with disabilities.