Accessible Communications Policy

Purpose

This policy commits the Department of Communities and Justice (DCJ) to:

• follow the legislative requirements under the:
  • Commonwealth Disability Discrimination Act 1992 (DDA)
  • NSW Anti-Discrimination Act 1977 No 48
    
  • NSW Disability Inclusion Act 2014 No 41
• use the latest World Wide Web (W3C) standards 
• meet the latest Web Content Accessibility Guidelines (WCAG) standards at a minimum Level AA standard
• use the procurement standard AS EN 301 549 (EN301)
• provide equitable access to the department’s information services to all users regardless of their ability and environment.

This policy replaces the former Accessibility for Digital Communications Policy.

Definitions

Term	Definition
Accessible Communications	Accessible communications provide information that is clear and easy to understand. Accessible communications: recognise people have different communication needs remove barriers that prevent people from accessing engaging and sharing information, and are inclusive.
Assistive technology	Assistive devices and technologies help to maintain or improve an individual’s functioning, independence, community participation and well-being. For example, the use of wheelchairs, prostheses, hearing aids, visual aids, and specialised computer software and hardware that increase mobility, hearing, vision, or communication capacities.
Auslan	Auslan is Australian Sign Language. The term Auslan is an acronym of Australian Sign Language, coined by Trevor Johnston in the early 1980s, although the language itself is much older. Sign languages use manual communication and gestures instead of sound to express the speaker’s thoughts and meaning. It is a distinct visual language and not English conveyed through signs or a manual code.
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.
Employees	Include all individuals engaged by DCJ as ongoing, temporary, casual or, as contingent labour staff.
Inclusive Communications	Inclusive communications accommodate and value the different ways people: receive information, express themselves, and take part in the world around them. Inclusive communications are accessible and take the intersectionality of the audience into consideration.
Intersectionality	Persons with disabilities are not a homogenous group. Communications should cater for intersection of disability together with other factors, such as gender, age, race, ethnicity, sexual orientation, literacy level, and socio-economic status.
Plain English	Plain English is a set of writing principles. Plain English guidelines recommend keeping sentences short, using of active voice, avoiding jargon, avoiding slang, writing with the reader in mind and with the right tone of voice, that is clear and concise. Plain English is also known as plain language.
Social Media	Websites and computer programs that allow people to create, share and exchange information on the internet using a computer or a mobile device.
User	A user is a person who uses something such as a place, facility, product, or service. In this policy, the term ‘users’ refers to all individuals interacting with DCJ information and services including and not limited to department staff, NSW citizens, service providers and other agencies.
WCAG	The Web Content Accessibility Guidelines (WCAG) provides universal standard for web content accessibility. WCAG 2.1 lists 4 design principles: content should be perceivable, operable, understandable and robust. The 3 levels of WCAG compliance include A (minimal), AA (acceptable) and AAA (optimal).

Scope

This policy applies to all DCJ employees. This policy extends to contractors, consultants, external suppliers, and service providers engaged by DCJ to deliver communication services. 

DCJ will deliver accessible and inclusive communications to all users regardless of their ability and environment. Our users may include people:

• with
  • blindness and low vision
  • hard of hearing/deaf
  • colour blindness
  • learning disability
  • cognitive disability
  • physical disability
  • speech disability
  • photosensitivity
  • neurological disability
• with changing abilities because of ageing or other factors
• with lower literacy
• from diverse language backgrounds
• with device limitations for example, with images disabled or without audio enabled
• using assistive technologies
• with restricted bandwidth to download large media content files
• with a need for reasonable adjustment at a DCJ workplace for accessing communications
• who live in rural, regional and remote areas
• who are unable to attend physical premises for events or activities and, or any combination of these.

Policy statement

Accessibility matters

Accessibility is an essential feature of all communications produced by government bodies. People may not have a choice in how they access government communications. So, it is important that information is available and works for everyone. Accessible communication ensures everyone has the same access and opportunity to:

• use textual content (print and online) for personal use or delivering services
• access and understand visuals, for example, images, videos, and diagrams (print and online)
• use online content (for example, websites and social media)
• attend meetings, events, or activities – in person and/or online
• respond in emergency situations
• provide feedback (print and online)
• take part in public consultation, and
• apply to access NSW government information under the Government Information (Public Access) Act 2019 (GIPA Act).

Risks of inaccessible communications

• Users are unable to access information relating to DCJ services.
• Reduced efficiency in accessing information as non-accessible content takes longer to process, read, and act.
• Makes DCJ liable for complaints:
  • under the Disability Discrimination Act 1992 or the NSW Anti-Discrimination Act 1977
  • from peak bodies and the public.
• Public perception that DCJ does not support an inclusive culture by excluding people with communication support needs. 

Accessibility is everyone’s responsibility

This policy applies to:

• content produced and shared with internal and external users
• printed content, signage and other communication material (for example, posters)
• content in the form of data, text, video, sound or images that is available through DCJ online applications on mobile or desktop devices (such as email applications, learning management systems, human resource management systems, collaboration tools, interactive forms, online chats, etc.)
• content shared through social media channels including and not limited to YouTube, Instagram, Facebook, Twitter, and LinkedIn
• intranets and public-facing websites
• content shared through documents (Portable Document Format (PDF), Microsoft Office Programs and other text formats)
• digital content and applications hosted by external suppliers on behalf of DCJ that a user may interact with
• digital content and applications created through collaborative partnerships with other NSW agencies and or a non-government organisation that a user may interact with
• the entire lifecycle of a product (scope, buy, deliver and support) that delivers communication services – print or online (various formats and devices)
• events such as and not limited to in-person events, webinars, meetings (in-person and online), and virtual tours
• the setup of physical spaces for example, lighting, sound, hearing loops, other sensory needs, neurodiversity, seating, building access and other venue related accessibility that may impact the access, delivery and receiving of information services.

Making communications accessible

This policy identifies 5 focus areas that will enable DCJ’s communications to become more inclusive and accessible. These are: Buy, Prepare, Create, Support, and Monitor.

Buy

DCJ will:

• use the Australian ICT procurement standard AS EN 301 549 (EN301) to buy
• follow NSW Buying guidelines to engage vendors for supplying accessible communication services
• consider accessibility risks when buying digital products and services
• follow Government accessibility standards for scoping, purchasing, upgrading, and developing ICT
• seek accessibility compliance evidence from the suppliers
• confirm the accessibility compliance evidence provided by the supplier before buying the product
• communicate to users about known issues of accessibility compliance
• make available and communicate about reasonable accommodation for products with known accessibility issues.

Prepare

DCJ will apply consistent accessible and inclusive communication practices to:

• identify target audiences and their communication support needs
• conduct research with diverse users to document accessibility requirements
• recognise diversity in communication support needs
• ·consider providing content in a variety of formats, such as:
  • Easy Read
  • Auslan
  • languages other than English
• provide alternative options where legacy content or technology creates accessibility barriers
• follow the NSW Design Standards and NSW Design System for creating digital products and services
• seek information for accessibility accommodations before hosting meetings and other events
• consider accessibility first design principle at all stages of preparation.

Create

DCJ will:

• write content in plain English at age 9 reading level and not exceed age 12 – 14 reading level for advanced technical language
• Follow the standard for Australian Government writing and editing
• use inclusive and respectful person first language, imagery and video content that celebrates diversity
• provide alternative options (summary document, video, audio etc.) to understand communications with language level higher than the reading age 14
• embed accessibility in brand guidelines
• make all content for print legible including background pictures and patterns
• make all information used at activities and events accessible, or available in person
• meet AS EN 301 549:2020 including WCAG 2.1 AA or higher compliance requirements for digital content presented through:
  • websites and intranet
  • interactive digital content (for example, dashboards and forms)
  • mobile applications
  • social media channels
  • other online or offline applications, tools, and platforms.
• follow NSW Inclusive Design standards for creating online content by:
  • publishing online content as HTML by default, without any alternative format
  • creating PDF or Word document as an alternative format based on user needs
  • ensuring documents and forms are accessible
  • ensuring all online images have meaningful alternate text
  • providing caption and transcript for all video content
  • checking the captions and transcripts if using auto-captioning software
  • providing an online summary of content for lengthy publications (such as reports)
• where appropriate provide content in:
  • Easy Read
  • Auslan 
  • languages other than English (check the machine-translated content for accuracy and cultural appropriateness)
• provide information on how to request:
  • accessibility accommodations for meetings, recruitment activities and other events (online or in-person)
  • alternative versions
  • interpreter (such as Auslan and other languages), National Relay Service and Telephone Typewriter (TTY) services.
  • information on how to access Auslan (Australian Sign Language) and or other interpreters, National Relay Service (NRS), and or Telephone Typewriter (TTY) services in online or printed material
  • provide contact details for answering questions or seeking clarification with options i.e., email, phone etc. 

Support

At DCJ, creating accessible communications is everyone’s responsibility. DCJ will support employees to create accessible and inclusive communications by:

• providing a central library of resources on the DCJ Intranet – Accessibility Hub to:
  • understand the basics for creating accessible communications
  • use accessible templates for document type and formats (for example, letterheads, factsheets, presentation deck etc)
  • conduct user research for a range of abilities
  • write inclusive content
  • use inclusive digital designs
  •  provide alternative formats for a range of abilities
  • create and remediate accessible content
  • make events and venues accessible
• providing guidance for creation of content in:
  • languages other than English
  • Easy Read format
  • Auslan
• providing a capability uplift to understand and apply minimum standards for procurement, design, content creation and technology (WCAG 2.1 AA or higher)
• enabling consistent processes and practices to embed accessibility testing of content and technology before releasing it to the users
• enabling systems and processes for staff to seek guidance, training, and consultation for creating accessible communications
• leading an Accessibility Community of Practice (ACOP) to learn and share knowledge for making communications accessible.

Monitor

DCJ will:

• regularly monitor, evaluate, and review the effectiveness of our policy, and amend it as necessary
• monitor user feedback around suggestions for improving accessible communications
• create and use Monitoring, Evaluation Learning Framework (MELF) to assess, learn from and improve inclusive and accessible communications, including:
  • reviews of what’s working and areas for improvement
  • reviewing and respond to community feedback
  • providing reliable data on inclusive and accessible communications work that can inform budgeting decisions and ongoing work
  • the collection of baseline data, undertaking annual reviews and reporting via existing channels such as DIAP report.
• undertake an annual usability and technical review of our websites and fix any compliance issues
• assess and record the shift in awareness and delivery of accessible communications
• identify areas for continuous improvement in delivering accessible communications.

Responsibilities

Employees

All employees of DCJ must:

• ensure they understand the need for creating accessible communications and seek guidance to comply with the policy requirements
• create or modify content, including text, data information, diagrams, graphs, flowcharts, maps, images, videos, and similar resources in conformance with this policy
• where applicable accommodate accessibility requirements for delivering technical reports, complex content such as flowcharts, face-to-face and/or over the telephone client services, organising meetings, webinars and training
• undertake any training available relevant to this policy
• report suspected breaches of this policy by emailing accessibility@dcj.nsw.gov.au.

All employees of DCJ who:

• buy or source communication technology
• commission external suppliers to create communication products
• engage external suppliers to use their platforms for hosting communication products and services
• engage external suppliers to deliver interactive applications
• commission third-party services to create and/or publish online resources in languages other than English including sign language
• commission third-party services to create resources in Easy Read format
• organise or engage external suppliers to host external and internal events

must:

• ensure suppliers and providers accommodate accessibility requirements for workshops, webinars, meetings, tools, and technologies used for events, co-design activities – both online and in person
• adhere to accessibility guidelines for procuring ICT goods and services
• make suppliers and providers aware of and comply with this policy
• validate evidence for accessibility compliance from the suppliers.

Senior executives and managers

In addition to the employee responsibilities, senior executives and managers must:

• communicate and promote this policy with their staff
• champion the creation of inclusive and accessible communications
• ensure new staff understand their obligations under this policy as part of the on boarding activities
• support staff with training, tools and time required to deliver inclusive and accessible communications
• consider accessibility compliance before approving the release of communication products and services
• ensure accessible communications for recruitment activities
• ensure that accessible communications related complaints in their areas are managed and resolved
• monitor and report on compliance of their business area generated communication products and services with this policy.

Digital Experience unit

The Digital Experience team will:

• provide consultation and advice for creating accessible communications
• provide consultation and advice to make online content accessible on DCJ websites, intranet, applications, and platforms
• create and maintain resources on the DCJ intranet to support employees in creating accessible communications
• foster awareness and facilitate capability uplift for creation of accessible communications
• monitor and triage reported incidents of policy breach to applicable business areas for review and action
• lead the annual review of DCJ websites and intranet for technical compliance with the latest WCAG requirements
• lead, support, and collaborate with Disability Employee Network (DEN) and other stakeholders across the department to monitor the implementation of the policy requirements.
  

Related legislation/regulation and other documents

Commonwealth legislation

The Commonwealth Disability Discrimination Act 1992  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 NSW Anti-Discrimination Act 1977 (NSW) states that it is unlawful to discriminate against a person on the ground of the person’s disability if the provision of the goods or services would impose unjustifiable hardship on the person who provides the goods or services goods and services.

The NSW Disability Inclusion Act 2014  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 NSW Disability Inclusion Act 2014 No 41 general principles states that people with disability have the right to access information in a way that is appropriate for their disability and cultural background, and enables them to make informed choices.

The Multicultural NSW Act 2000 specifies the need to respect and make provision for the culture, language and religion of others within an Australian legal and institutional framework.

Other

The DCJ Disability Inclusion Action Plan 2020 - 2024 affirms that DCJ will ensure we are inclusive of people with disability in our workplaces and in our engagement with the community.

The DCJ Inclusion strategy 2021 – 2025 sets out the direction and goals that we are working towards to create an inclusive, diverse and accessible workplace.

NSW government’s All of Government Communications Framework specifies creating simple and accessible information as one of the six (6) principles of customer-centric communications.

M2021-04 Language Services Provision in Multicultural NSW states that the NSW government agencies fund the provision of language services (that is, interpreters and translated materials) when dealing with clients, to provide all clients with access to government services.

NSW Government accessibility requirements for buying ICT products and services standard (AS EN 301 549:2020) specifies the functional accessibility requirements applicable to ICT products and services. It also provides description of the test procedures and evaluation method for each accessibility rule in a form that is suitable for use in public procurement within Australia.

The Web Content Accessibility Guidelines (WCAG) 2.1 are a set of guidelines that provide recommendations for making digital content more accessible to people with disabilities. The NSW Government recommends meeting a minimum AA level. Accessibility basics on the Digital NSW website provides simplified version of the POUR principles, foundation of the WCAG guidelines as:

• Perceivable: Make sure your product can be perceived by all users, including those with vision or hearing impairments.
• Operable: Ensure that users can easily navigate and interact with your product using different input methods, such as a keyboard or screen reader.
• Understandable: Ensure your content is easy to understand for all users, regardless of their cognitive ability.
• Robust: Make sure that your product can be accessed using a wide range of assistive technologies, such as screen readers or braille displays.

The Department of Customer Service Circular DCS-2020-01 NSW Government website consolidation encourages agencies to streamline their websites and apply NSW Design Standards for creating a consistent user experience to deliver online information services.

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