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Applying to all new or significantly upgraded applications, the purpose of the Online Accessibility Policy is to define accessibility requirements for all content and functionality of South Australian Government’s online presence.
This policy applies to all SA Government online applications including:
- Public-facing websites
- Intranets and extranets (accessed within SA Government)
- Public-facing native apps
- Online documents (Portable Document Format (PDF), Word, ePub etc.)
- Online forms and surveys (public-facing and accessed within SA Government)
- Closed client systems (Learner Management Systems, payment gateways, online accounts etc.)
- Multimedia (audio, video etc.)
- Non-web-based software
This policy applies to all SA Government online applications referenced above, regardless of whether they are provided solely by the SA Government, or are partly or wholly provided by external parties on behalf of the SA Government.
3.1 Commonwealth Legislation
Disability Discrimination Act 1992 requires providing equitable access to people with disability. It is unlawful Under the Act, to discriminate against a person with disability by excluding access to information and services, which includes those delivered online.
3.2 South Australian Legislation
It is unlawful under the Equal Opportunity Act 1984 to discriminate against an employee or member of the public with disability by excluding or limiting their access to SA Government information and online services.
The Disability Inclusion Act 2018 provides a legal framework to support a whole of Government approach to improving the inclusion of all South Australians with disability in all areas of life in this State (see 6 Reporting Requirements). This is supported by the Digital by Default Declaration: “Digital services will be available online, mobile-ready, easy to use and accessible.”
3.3 Other guiding legislation and international conventions
Australian Human Rights Commission: World Wide Web Access, Disability Discrimination Act Advisory Notes, 2.2 Equal Access is Required by Law.
The Australian Government, through the 2010 Web Accessibility National Transition Strategy (NTS), implemented a policy of web accessibility for federal, state and local governments.
The Australian Government also approved the UN Convention on the Rights of Persons with Disabilities (UNCRPD). Articles 9 and Article 21 state access to information, communications and services (including the internet) is a human right.
Australia’s response to the UNCRPD, the National Disability Strategy 2010-2020, identifies the achievement of accessible, reliable and responsive communication and information systems as a key policy direction.
It is the intention of the Parliament of South Australia that, to such an extent as may be reasonably practicable, the operation, administration and enforcement of the Disability Inclusion Act 2018 is to support and further the principles and purposes of the UN Convention on the Rights of Persons with Disabilities, as well any other relevant international human rights instruments affecting people with disability, as in force from time to time.
All new or significantly upgraded SA Government online applications referenced in “2. Scope” must conform – at a minimum – to Web Content Accessibility Guidelines (WCAG) 2.0 Level AA (or WCAG 2.1 Level AA).
WCAG 2.1 is the extension of the accessibility guidance to include mobile, low vision, and cognitive provisions, and conformance to Level AA is encouraged at this time.
Accessibility must be addressed at every stage, from planning to development by integrating a user-centred design approach. Refer to "4.3 Accessible by Design".
4.2 Additional requirements
Multi-jurisdictional online applications and content created through public-private partnerships should meet the accessibility requirement determined by the main authoring agency.
Accessibility requirements apply to the information structure and formatting of online content, navigational elements, and interactive elements, such as contact us forms or similar, maps and interactive data visualization.
Social media integration (such as Twitter and Facebook) must be optimised for accessibility. Content published on these platforms must not be the primary source of information especially where external users can post content and accessibility cannot be controlled by the content owner.
4.3 Accessible by Design
Online services must be accessible to everyone who needs them. If it isn’t, you may be in breach of the Disability Inclusion Act 2018 and the Equal Opportunity Act 1984. Agencies must consider the varied needs of users, and plan for accessibility from the outset. Follow Australian Government guidance:
- Digital Service Standard: best-practice principles for designing and delivering government services. Accessibility requirements are specifically addressed in Criterion 9: Make it Accessible: noting that Criterion 6 and Criterion 7 also cross with accessibility in requiring responsive and consistent interfaces and common platforms.
- Design System: incorporates the highest usability and accessibility standards and helps deliver a consistent experience for all users, in line with the Digital Service Standard.
- Content Strategy Guide: user needs are woven through the guide with accessibility standards covered in the Guidelines and standards checklist.
- Content Guide: a supporting resource for online content authors, accessibility is covered throughout the Guide and covered in more detail in Accessibility and Inclusivity. The Guide also aligns with WCAG criteria 3.1.5 (Level AAA) in providing advice for the creation of readable online content - see Readability.
- Service design and delivery process: an agile approach, helping teams build better services for all users.
Beyond technical conformance of WCAG, the Australian Government, Australian Human Rights Commission and the W3C all recommend usability testing with people with disability or age-related impairments using various adaptive strategies to assess online accessibility. See Digital Service Standard Criterion 10: Test the service and the Australian Government User Research Digital Guide: understand the needs of all your users at every stage.
4.4 Accessibility Standards
How to Meet WCAG 2 is a customisable quick reference to WCAG 2.0 and 2.1 that includes all the guidelines, success criteria, and techniques for authors to use as they are developing and evaluating web content.
Australian Accessible ICT Standard AS EN 301 549:2016 is an adoption of European Standard EN 301 549. The standard supports access to information, communication and technology (ICT) for people with disability and provides ICT procurers with accessibility guidance and certainty.
4.4.1 Native Apps
Accessibility for the mobile platform refers to making online applications accessible for users with disability while they are using mobile phones, tablets etc.
The W3C covers accessibility for these techniques through additional Success Criteria in the WCAG 2.1 which includes recommendations to implement accessibility across web pages, online applications and content designed to be used through mobile devices.
Mobile Accessibility at W3C includes recommendations designed to improve the overall user experience of the web on mobile devices.
4.4.2 Portable Document Format
Due to the lack of support for PDF in mobile environments, agencies are reminded that Portable Document Format (PDF) alone is still not considered a sufficiently accessible format.
This shortcoming means that although PDFs can incorporate WCAG techniques, it may still be necessary to provide the same information in another format for mobile users, ideally accessible HTML (HTML should be the default format for all government information).
- PDF accessibility: guidelines on structuring PDF, hyperlinking, and offering an alternative format to PDF.
Accessibility of multimedia is covered under WCAG in Guideline 1.2 – Time-based Media.
4.4.3 Non-web-based software
The Australian Accessible ICT Standard AS EN 301 549:2016 is an adoption of European Standard EN 301 549. The standard address access to electronic products and information technology for people with physical, sensory, or cognitive disability. The standard contains technical criteria specific to various types of technologies and performance-based requirements that focus on the functional capabilities of digital products.
Specific criteria cover software applications and operating systems.
SA Government agencies are responsible for implementing this policy in relation to their own public facing online content as defined in 2. Scope.
4.6 Web technologies
Agencies should not rely on any online technology solutions that cannot demonstrate WCAG 2.0/2.1 conformance. Web technologies that claim accessibility support must prove WCAG 2.0/2.1 conformance.
All SA Government procurement documents that relate to the development and/or implementation of SA Government’s digital properties must clearly state SA Government’s accessibility requirements as per this policy.
Australia has adopted an internationally aligned standard for the procurement of accessible ICT.
The Australian Accessible ICT Standard AS EN 301 549:2016 is an adoption of European Standard EN 301 549. The standard supports access to information, communication and technology (ICT) for people with disability and provides ICT procurers with accessibility guidance and certainty.
Vendors must provide sufficient evidence to demonstrate their compliance with these requirements.
Evidence may include:
- Documentation detailing the level of accessibility of a product (against WCAG 2.0/2.1 or AS EN 301 549:2016).
- Past case studies where accessibility requirements have been addressed.
- Details of how accessibility is represented on the future product roadmap.
- Identification of specific reference sites where people with a disability are using the solution.
Any product or supplier selected by SA Government must demonstrate how the solution meets the relevant standards as outlined in "4.3 Accessibility Standards", or the capability to deliver this as part of the implementation.
Any purchase arrangement or contract must include terms confirming the vendor’s commitment to meet SA Government’s accessibility requirements.
If the product or supplier cannot demonstrate the required level of accessibility, then the business area must engage an internal accessibility subject matter expert (SME) or a third-party digital accessibility consultancy to validate compliance before entering into any arrangements with the product or supplier.
The Disability Inclusion Act 2018 (the Act) provides a legal framework to support a whole of Government approach to improving the inclusion of all South Australians with disability in all areas of life in this State.
Part 5 (16)(3)(d)(ii) of the Act states that Disability Access and Inclusion Plans (DAIPs) must include strategies to support people with disability to access information and communications.
In addition to a State Disability Inclusion Plan, under Part 5 (17)(1) of the Act each State authority is required to prepare a DAIP and publish it online, by 31 October 2020. The authority must then report annually on the operation of its DAIP, with the first report due by 31 October 2021.
Reporting examples that support the Act may include:
- Measuring success in delivering and/or procurement of online services in line with this policy.
- Evidence of directly engaging assistive technology users/people with disability in the community (see 4.3 Accessible by Design)
- Evidence of WCAG 2.0 Level AA or WCAG 2.1 Level AA compliance through internal or external auditing.
- Where accessibility problems are known, agencies must provide a clear implementation plan to address the problems, then commit to minimising their future risk by using standards-based web technologies and best practice content management processes.
- Published by: Department for Premier and Cabinet
- Status: across government policy
- Compliance: Mandatory
- Original authorisation date: 16 May 2019
- Contact: email firstname.lastname@example.org or phone +61 (8) 8429 0506
- Supporting policy: South Australian Government Digital Service Standard policy
- Supporting resource: Online Accessibility Toolkit - accessibility.sa.gov.au
Policy developed and published with acknowledgement.