From compliance to culture

The Public Sector Bodies Accessibility Regulations (PSBAR) provides clear legal requirements for universities in terms of making learning accessible for all students. In turn, most universities have begun a journey towards compliance with PSBAR. This is a good thing, right? Well, not necessarily; at least, not by itself.

Alistair McNaught, a leading champion of accessibility and inclusion for the HE sector, argues that we need to move from an approach based on compliance to one of culture change, a culture in which we minimise barriers to learning and maximise the benefits of different learning technologies. As educators we need to ask: who is consuming our resources, what are their needs, and how can we most effectively meet those needs?

The need for us to shift from a compliance-based approach to one of developing a culture of accessibility maturity is clear when you compare a university virtual learning environment (VLE) with the other types of website covered by PSBAR.

A typical public sector body – a local council, for example – will often run a website that has content that rarely changes, is primarily text-based, and is under the control of a small team of web experts. A university VLE, on the other hand, typically has thousands of academics with a range of skill sets uploading a bewildering variety of content and pointing to third-party tools on a daily basis. A compliance-only approach for universities is thus extremely challenging. In the worst case, a compliance-only approach could lead to unintended consequences that are entirely counter-productive (and there are anecdotal accounts of this happening): an institution could choose to be “compliant” with PSBAR by dispensing with digital diversity and reverting to paper handouts. If they did this it wouldn’t matter if the handouts were poor-quality, smudged, third-generation photocopies – because the accessibility standards don’t apply to printouts. This “compliant” approach would be bad for all students but it would hugely disadvantage disabled students – which is, of course, the opposite of what PSBAR hopes to achieve.

McNaught visited UoP a few years ago when he worked for Jisc as their Accessibility Subject Matter Expert. He played the role of a “mystery shopper”, acting as a disabled student who was trying to access the University VLE, website, and other online systems. He is now an independent consultant and has recently posted some thought-provoking articles about accessibility maturity in an educational context. Throughout 2020 he worked with the charity AbilityNet to build on and update the old TechDis Accessibility Maturity Model. Together they have developed two versions of a maturity model: an institutional model and a course/module model. For anyone interested in issues of digital accessibility and inclusion, it is worth following McNaught’s upcoming series of blog posts.

At the close of 2020, McNaught also published a couple of related posts (part 1 and part 2) that provided an explicit example of how PSBAR can lead to unintended consequences. The example involves something with which UoP and many other universities have been grappling since we all increased the amount of video being produced: captioning.

At face value, the legislation requires us to provide 100% accurate captions for deaf people. A risk-averse institution that lacks the budget to create “compliant content” might remove videos from the VLE. This unintended consequence would have a negative impact on all students, including disabled students. McNaught argues that an approach rooted in accessibility maturity would take into account context, and would provide a roadmap for improving video accessibility.

For example, many courses provide most of their content as text. Alongside this, some tutors provide a video version of the content. If the video explanation provides no more information than a text alternative, then the video does not require captions. It’s only if a video introduces new information, not explicit in the text, that the issue of captioning arises. So that’s one lesson: depending upon the context, videos can be an alternative format.

Here is another example of where context is important, and where the guiding principle must be a pedagogic purpose. Imagine a video of a debate. The video might be used for different teaching purposes: to examine rhetorical devices, to study non-verbal communication, to illustrate legal arguments, to highlight technical recording considerations … there are many possible uses. And the best accessibility solution for each use case might well be different! Captioning might not be the best solution. Thus if you provide a caption and then tick the box marked “compliant video” you might nevertheless have created a barrier, not a solution, to learning needs.

Or consider a video of a long-winded, rambling, needlessly prolix interview: a summary consisting of a few bullet points might well be a better solution – for all students – than captions.

Context is important. As McNaught writes: “digital accessibility is about culture change … we need to steer a path between legalism and realism, a path that raises awareness without raising hackles and that encourages skills rather than excuses”. Steering that path won’t be easy – but the destination makes the effort worthwhile.

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