> just go back into their 'archive' courses and delete everything if it is deemed that a lot of work is required to make them conform, which is a definite backwards step for student experience.



Some HEIs have close to half a million documents on active courses so this is clearly something that isn't going to be fixed manually. The publishing industry have problems on this scale with legacy content - eg scanned PDFs from 2002 but now needing them as accessible PDFs to be compatible with new platforms and processes. 



I'm currently exploring the tools and services publishers use and trying to get a demo to see if there's potential compatibility (and affordability) for the education sector. I'll keep this list updated on anything I find but of anyone already has experience of this either in their institution or in a former life, please do contribute your wisdom!



Alistair





Alistair McNaught

Subject specialist - accessibility

M 07443984111

Skype alistair_techdis

Twitter @alistairm

One Castlepark, 

Tower Hill, Bristol, BS2 0JA

jisc.ac.uk 



At Jisc we work flexibly - so whilst it suits me to email now, I do not expect a response or action outside of your own working hours. Also, please note I use voice recognition. It can introduce creative (but entirely erroneous) interpretations. Apologies if I failed to spot any. 



-----Original Message-----

From: Digital accessibility regulations for education <[log in to unmask]> On Behalf Of Tubman, Philip

Sent: 06 March 2019 12:15

To: [log in to unmask]

Subject: Re: Intranets, VLEs and Substantial Revisions



We do not change the URL each year, rather move to a new version, but we are working on the assumption that the VLE framework (Moodle in our case) is accessible to the EU directive by September 2019. In terms of content, and this relates to q.3 - we are also assuming that all office doc/ pdf content published after 1st Sept 2019 will be accessible (headings and alt tags etc) from day one.



As I understand it, there is also a 2020 deadline for ALL content regardless of its publication/ substantial revision date, so even if we decide that some content or parts of the framework are not accessible on 1/9/2019, or give ourselves a bit more time by deliberately not upgrading, it needs to be by 1/9/2020, making the point of what constitutes a 'substantial revision' a little moot.



It is interesting to clarify the 'office file formats' point though, as this will determine what needs to be 'backported'. Students here have access to courses from Y1 to Y3/4 at all times, so this would imply that all content from 17/18 and 18/19 will need to comply from the 1/9/2019 deadline, as these files may constitute 'active administrative processes'.



The danger we have here is that some unscrupulous staff members may just go back into their 'archive' courses and delete everything if it is deemed that a lot of work is required to make them conform, which is a definite backwards step for student experience. 



It would be useful to discover if 'upon request an accessible version is produced' is satisfactory for these older office file types.... They may not be 'actively used' for a module, but for the 'programme or scheme' they most definitely are active....



Confused!?



Phil









Question 1.

    If we say that having a new instance of a VLE each year with a different url (albeit with substantially the same content) constitutes a substantial revision, then am I correct in thinking it should conform on the date it is published, i.e. 1 September  2019?

    

    Question 2.

    If we say that the new instance of the VLE is not a substantial revision, then is material produced before 23 Sept 2019 exempt but additions to the VLE after that date should conform?

    

    The regulations do not apply to 'office file formats' published before 23rd September 2018, "unless such content is needed for active administrative processes relating to the tasks performed by the public sector body."  Teaching and Learning would seem to qualify as active administrative processes relating to the tasks of a university. 

    

    Question 3.

    Therefore, am I correct in thinking that all Word and PowerPoints on our 2019-20 VLE (which is launched on 1 September 2019) should conform from day one?

    

    Finally, there is this sentence (it's at the start of Part 2 of the regs)...

    

    "This Part applies as follows—

    (a) for a website of a public sector body not published on or after 23rd September 2018, on or after 23rd September 2019"

    

    Question 4.

    Does than mean that from 23 Sept 2019 the regs apply to websites published before 23 Sept 2018?





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