Why Accessibility Policies Are Important, And What Can Be Learned From The BBC.

This article is not just an explanation of the BBC’s policies and wider regulatory framework for accessibility, but it is also intended to be a resource for anyone writing an accessibility policy for their organisation.

If your organisation does not have a policy, then I would recommend you consider one as it can be a useful cornerstone for any accessibility programme.

What can an accessibility policy achieve?

It can achieve a lot of things, but it has to be developed as a collaborative effort with teams such as Legal/Policy, Diversity, HR and Comms, for the framing, and with UX Design, Editorial, Marketing and Product for any commitments.

Framing the policy is important as it help everyone gain a common understanding of why accessibility is important, how it fits in with things like regulatory frameworks or the organisation’s brand values, mission statement or diversity policy.

This context answers the question, “why?” for the whole organisation, and as all organisation’s policies are signed off by the Executive Committee (or equivalent) the weight for the rationale and the commitments comes from the top.

Policies should not be about ambitions. If you try to use a policy to strong arm anything new into an organisation you can risk undermining everything it could achieve.

When it comes to commitments make sure they have already been proven. Make sure they have already gone live or have already been trialled as processes or resources. Policies should commit to what is possible and proven.

This way no-one can say that anything in the policy is not deliverable. You can’t deny what has already been delivered.

A policy does not just help with creating a common understanding of accessibility within an organisation, but it also frames discussions with lobbyists and representative organisations. They can then see what you have achieved and what standards they should reasonably expect to be maintained.

Lastly, make sure everything in the policy is objective and direct. “We will deliver this by doing that”. If the policy is too ambiguous then it will have limited use.

Regularly reviewing a policy and adding new achievements as commitments is also a great way of reducing the risk of losing any positive outcomes. It keeps the accessibility programme evolving without losing any of the goodness so far achieved.

Please use this article as a way of help you think about your organisation’s policy.

If you know the BBC’s accessibility programme, but have never read the BBC’s accessibility policies, then you might not have grasped why accessibility is so important to the worlds oldest public service broadcaster.

It all starts with a single word.?Everybody.

“Everybody”, “everyone” and “all” are the most important words when it comes to accessibility, as they simply explain what accessibility sets out to achieve. When an organisation uses these words in its values, principles or mission statement, and does not have an effective accessibility programme, it is effectively caveating the objectives with, “except disabled people”, which undermines not just the integrity of the whole statement in which they appear and the integrity of their own brand.

At the core of the BBC’s regulatory framework is a Royal Charter. This forms the basis of the BBC’s obligations to make all of its output accessible, so far as it is practicable and reasonable.

The Royal Charter,?“The Royal Charter is the constitutional basis for the BBC. It sets out the BBC’s Object, Mission and Public Purposes. The Charter also outlines the Corporation’s governance and regulatory arrangements, including the role and composition of the BBC Board.”

The Agreement,?“The Agreement between the Secretary of State for Culture, Media and Sport and the BBC sits alongside the Charter. It provides further detail on many of the topics outlined in the Charter including the BBC’s funding and its regulatory duties.”

The BBC Mission, was initially created by it’s first Director General, Lord Reith, and it has changed very little since the 1920’s, and has the important words, all audiences.

“To act in the public interest, serving?all audiences?through the provision of impartial, high-quality and distinctive output and services which inform, educate and entertain”.

Public Purposes, “…all audiences?can engage fully with major local, regional, national, United Kingdom and global issues and participate in the democratic process, at all levels, as active and informed citizens.”

“The BBC should help?everyone?learn about different subjects in ways they will find accessible, engaging, inspiring and challenging…”

The charter is a legal document and it sets out the governance framework for the organisation. Because it has such a clear regulatory framework already the BBC has carve outs from parts of the Equalities Act and the EU Accessibility Directive. This is to reduce the risk of different regulatory frameworks contradicting each other when put into practice.

History has proven that the BBC’s framework works because it has so many landmark achievements such as pioneering; in-vision signing in the 1950s, TV and online closed captions, audio description production systems, accessible children’s games and being the first large scale content producer to deliver support for open digital accessibility standards at scale.

With regards to accessibility being mentioned or implied, there are three key articles in the?Royal Charter?and one in?The Agreement:

Article 5:?“The Mission of the BBC is to act in the public interest, serving all audiences through the provision of impartial, high-quality and distinctive output and services which inform, educate and entertain”

Article 6, 4th Public Purpose:?“To reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions and, in doing so, support the creative economy across the United Kingdom”:

NOTE: the word “communities” can be read widely and include identity.

Article 14:?“The BBC must ensure it reflects the diverse communities of the whole of the United Kingdom in the content of its output, the means by which its output and services are delivered (including where its activities are carried out and by whom) and in the organisation and management of the BBC”.

(In the Agreement) Clause 61:?“The BBC must do all that is reasonably practicable to ensure that viewers, listeners and other users (as the case may be) are able to access the UK Public Services that are intended for them, or elements of their content, in a range of convenient and cost effective ways which are available or might become available in the future.”

All BBC policies cover?commercial subsidiaries?and their joint venture partnerships as well as public service activities. The accessibility policies take all of the above and give it context in terms of the digital content services and products the BBC creates distributes. These policies are designed to leave everyone in no doubt what they should expect and how it will be delivered.

So here is a breakdown of the two key BBC policies:

BBC Product Accessibility Policy.

Firstly there is the context to the policy. It makes it very clear what is in scope and it gives context to the following commitments in the policy and how the delivery of the policy will be monitored. This is really important because it contextualises the importance of accessibility with regards to the regulatory framework and mission.

The BBC Digital Accessibility Policy is about ensuring the BBC’s digital products, services and digital environments are accessible to everyone by removing barriers and facilitating inclusion.

Digital Accessibility can relate to: websites, mobile applications, TV platform applications, video games, voice skills, XR experiences, digital learning experiences, online live events, content re-purposed from broadcast TV, off-schedule AV content, content published on social media platforms, provision and publication of information and organisational practices — the way we do things in relation to audiences.

Being inclusive and accessible to disabled people is an integral part of the BBC’s Diversity Strategy. Accessibility is therefore a key objective in the BBC’s ambition to ensure that the BBC delivers, “value for all”.

Disabled people are a diverse group that makes up over 20% of the UK’s population. This policy relates to anyone who has an impairment or condition that requires specific consideration

For disabled people accessibility is vital for rights of access, social inclusion, participation and opportunity. As such the BBC designs its products and services in a way that aims to provide disabled people with an inclusive experience that is comparable to that enjoyed by non-disabled people. The BBC will also seek to include disabled people in all audience and design research programmes.

To ensure this is both achieved and maintained, accessibility is part of a programme of continuous research and improvement. Digital accessibility will also be regularly reported at board level.

Now the scene is set. We all know why the policy is important, who it impacts, why accessibility isn’t worthy but worthwhile, where it should be applied, what the approach is and how it will be monitored.

This part of the policy is unlikely to change as all it does is explain the rational and framework for the commitments, which is the section that should evolve.

The commitments are retrospective. To be robust, meaningful and actionable the policy should take the legal regulatory framework and align current accessibility activities to show how they are intended to be met. Each commitment should be tried and tested to prove that it is deliverable and it should have been reviewed by the Chief Product, Chief Technology and Chief Design officers, or their equivalents. This way the policy will be seen as supporting ambition and culture, rather than forcing it.

Next up are the commitments themselves. The BBC has ten and after each one I will explain its relevance:

The commitments:

1. Accessibility will be considered from the start when developing new products and services, or partnership proposals, ensuring accessibility is built and iterated in a way that is both scalable and sustainable.

This, or something like this, should be at the start of every policy. It sets out the intention, where in any process the planning should happen and the breadth of what this covers.

2. Accessibility is recognised as a joint responsibility of the Product, Design and Editorial teams in respect to their function.

Where responsibility sits is important because everyone is responsible for an embedded activity. Accessibility is more about how you approach design, content and development than anything additional. So if the product is accessible but the content isn’t, this helps identify who should be involved in the conversation. An accessibility team should be an enabler, a networker and a negotiator, it should not try to do everyone else’s jobs for them.

3. The BBC’s digital design system,?BBC Global Experience Language?(GEL) has accessibility built-in to every pattern and resource it provides. This includes designed experiences for both sighted and vision impaired users with support for voice, keyboard, point or touch control input where appropriate.

Inaccessibility is the result of a design that did not consider a specific impairment or impairments, situation, environment or any combination. For any accessibility programme to be successful it has to be grounded in user experience, so ensuring the accessibility of the design system is part of the policy is paramount.

4. All digital projects will utilise BBC GEL as well as supporting all platform level accessibility features, as well as other assistive technologies, through compliance with?BBC Product Accessibility Guidelines?for UK or?WCAG AA?(mobile, web, IPTV and XR) for international or commercial products and services.

When it comes to the support of guidelines the BBC has been building against?its own guidelines since 2007, which is all good and well for domestic services, however there can be situations where services can be covered by other regulatory frameworks or have to align with different audience expectations.

Internationalisation also needs to be considered especially where?accessibility is also a socio-economic concern.

5. All mobile, online or console games will comply with age appropriate Games Accessibility Guidelines?for up to 12?or?12 and over.

The BBC has two brands for children, Cbeebies (0 to 6 years old) and CBBC (6 to 12 years old), and a large proportion of the use if the websites and apps is for accessing the many games. The BBC has created guidelines specifically for Children’s content, and for games produced for any of the BBC’s commercial subsidiaries there are the internationally recognised guidelines.

Be aware of age related issues. Young disabled children can have very different requirements to those covered by WCAG.

6. The Digital Accessibility Team provides: guidelines, training, skills development, advice and resources. These resources enable and support inclusive design, editorial and technical delivery of digital products.

The function of accessibility should be covered by the policy. This short statement covers not only the existence of the team, but also the function it performs within the organisation.

7. The BBC Accessibility Champions Network ensures every project will have at least one person representing the voice of disabled users.

Culture is a big part of embedding accessibility into organisational culture, and?champions networks are a proven way of enabling organisational change. Whether it is a formal or an informal network, having it recognised in policy will give it some weight. Create some separate terms for the network so it’s objectives and function are understood.

8. All content on BBC iPlayer originally broadcast with access services will include those access services: sign interpretation, audio description and subtitles, where supported by the platform.

When you know there is?future regulations on the horizon?and consultation is happening, and your product is already aligned with the proposed changes, secure that in policy. It not only shows how far ahead of the game the product is but it also reduces risk from falling short of the potential regulation due to changes in product design or changes in service provision.

9. All off-schedule streamed or downloadable content on either BBC or social media platforms will follow best practice as outlined in?BBC Editorial Policy.

Try not to duplicate policy and also link up with existing related policies, and even be part of their evolution so the polices are complimentary.

10. The BBC will actively share knowledge in this area with wider industry groups and partners in order to facilitate greater access and consumer choice in the marketplace for disabled people.

If you want to build up trust with external organisations then openness is a great policy. How open? That’ll be different depending on corporate culture and commercial sensitivity.

BBC Editorial Policy?(1.7)

The BBC’s editorial policy covers all content produced by the BBC, whether it is broadcast or digital, and the?Editorial Content Guidelines?add context to the policy.

The BBC is committed to being inclusive and accessible to all our audiences. We are required by law to make ‘reasonable adjustments’ to our content to ensure disabled people can access our output.

The BBC provides subtitling, audio-description and sign language services, but what is considered ‘reasonable’ will evolve as technology develops.

Ofcom also sets mandatory requirements for all broadcasters.

Decisions taken throughout the production process will affect whether output is accessible to people with some visual impairment (including colour blindness), hearing or speech impairment (for voice recognition). Producers must take account of the requirement that, as far as reasonably practicable, our content is accessible to those audiences.

This policy is straight to the point is setting the objective for all content. This goes beyond access services and the guidance focuses on the production of the content itself.

Guidance and guidelines should support the policy and be included as links. This way they both carry the weight of policy, but also support the organisation making delivery as frictionless as possible.

BBC Accessibility Guidance

BBC Editorial Policy Guidance

BBC Global Experience Language

BBC Global Experience Language Technical Documentation

BBC Digital Product Accessibility Guidelines

BBC Diversity Strategy

OFCOM’s code of Television Access

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