1. Preamble

Defining Accessibility

“Accessibility is the degree to which a product, device, service, or environment is available to as many people as possible.

Accessibility can be viewed as the "ability to access" and benefit from some system or entity”.

1.1 The Great Product Exchange Ltd commitment to accessibility

The Great Product Exchange Ltd is committed to providing all our customers with equal access to our digital products and services regardless of ability. We are also committed to enabling equal access to all our staff.

This digital accessibility policy applies to all areas of this The Great Product Exchange Ltd internal and external digital products both current and in the future. It sets out how we are integrating digital accessibility as a standard element of our business as usual processes.

It also determines how we will treat legacy content.

It is a living document and as such will be subject to periodic update.

2. Background

Our digital accessibility policy and individual product accessibility statements are based on a number of aspects, including legal requirements and regulations. Whilst these inform, they do not limit our objective of inclusion and enhancing the lives of disabled and older customers and staff of The Great Product Exchange Ltd.

The Great Product Exchange Ltd will, wherever reasonably possible, publish information and services that are accessible to everyone who uses them, and consideration for accessibility will be built in from the early concept stages of a project.

2.1 Legislation in the United Kingdom and Northern Ireland

The principle legislation relating to both age and disability is the Equality Act 2010, which replaced the Disability Discrimination Act of 1995 in the UK.

This policy deals specifically with disability.

The Equality Act deems it unlawful to discriminate against a disabled person because of their disability unless this behaviour can be justified.

The Act states it is against the law to:

  • Offer a disabled person a service that is not as good as a service being offered to a non-disabled person
  • Provide a service to a disabled person on different terms to those given to a non-disabled person
  • Provide goods or services in a way that makes it unreasonably difficult or impossible for a disabled person to use the goods or service.

This means that organisations have a duty to make "reasonable adjustments" for disabled customers.

2.2 The Great Product Exchange Ltd Governance

The Great Product Exchange Ltd Change Framework has a requirement that all projects should meet.

The Equality Act 2010 and therefore all digital projects and changes must meet accessibility standards or apply for an exception.

This sets the expectation that:

  • Web based digital products - both desktop and mobile would fulfill all WCAG Level A and Level AA success criteria and/or mobile web best practices, whichever is applicable.
  • Native apps will be built according to current best practices such as DAC native app guidelines or BBC mobile and native app guidelines until such time as specific conformance criteria are available from W3C or an equally recognised body.
  • New and/or updated content and existing content provided for our digital products by third-party developers, will conform to the applicable guidelines wherever possible by 31/12/2021.

Where an existing Digital Product cannot reasonably achieve conformance The Great Product Exchange Ltd will ensure basic minimum compliance will be achieved and that users with disabilities will test the product to ensure there are no insurmountable challenges to a positive user experience.

3. Conformance

In order to satisfy our obligations under the Equality Act 2010 - The Great Product Exchange Ltd require that all new and updated digital products, produced or procured will, wherever reasonably practicable, conform to current standards and guidelines such as:

  • W3C Web Content Accessibility Guidelines 2.1 (WCAG), Level AA which is also an international standard ISO/IEC 40500:2012
  • W3C Mobile Web Best Practice MWBP

3.1 Strategy for conformance

The Great Product Exchange Ltd will provide internal resources for training, technical assistance, monitoring, and/or an internal web page with links to such resources.

It is our intention to undertake a programme of accessibility training for those staff directly responsible for the implementation of digital accessibility for our products.

3.1.1 Testing and accreditation

We currently commission digital accessibility testing and subsequent accreditation on some of our existing digital products such as .

This includes testing by users with disabilities.

We intend to ensure that wherever possible our digital products are similarly accredited and that accreditation remains valid or to provide written documentation excepting the non-conformance with timeframe for remediating.

3.1.2 Information and communications

When providing information to, or communicating with, a person with a disability, we will provide, on request, the information and communication in an accessible format or with communication support. We will work in consultation with the person with the disability to provide them with the information in a manner that takes into account the person’s disability.

4. Reasonable adjustments

Taking into account the size and nature of The Great Product Exchange Ltd business and operating model, it is likely that we would be expected to make our Digital Products accessible to all users where appropriate, including, for example:

  • People with visual impairments, who use text-to-speech software and screen magnification software
  • People with manual dexterity impairments, who cannot use a mouse who may use a keyboard or voice activation technology
  • People who are Deaf or hard of hearing
  • People with dyslexia colour blindness and learning difficulties

4.1 Guidance on reasonable adjustments

Advice on what may constitute reasonable adjustments to our existing digital estate, or with regard to its maintenance and development for the future, has been obtained through specialists such as Digital Accessibility Centre .

The duty to make reasonable adjustments, for service providers, comprises 3 requirements:

  • Where a provision, criterion or practice puts disabled people at a substantial disadvantage, compared with those who are not disabled, to take reasonable steps to avoid that disadvantage
  • Where a physical feature puts disabled people at a substantial disadvantage compared with people who are not disabled to avoid that disadvantage or adopt a reasonable alternative method of providing the service or exercising the function
  • Where not providing an auxiliary aid puts disabled people at a substantial disadvantage compared with people who are not disabled, to provide that auxiliary aid.

    5. Individual accessibility statements for each digital product.

    Each Digital Product will have its own unique ‘Accessibility Statement’, which clearly defines the level of accessibility achieved, and states any deviation from WCAG 2.1, MWBP or other guidelines.

    For digital products that have been assessed for assistive technology compatibility, an accessibility statement should provide the results of this testing, including which technologies and versions are compatible and any known incompatibilities or limitations. These may be due to areas of the product being in development, use of third party software or, most commonly, use of non-HTML files such as Adobe Acrobat Portable Document Format (PDF) and Microsoft Word documents that have not been made accessible.