Accessible documents policy

This notice explains the Certification Office’s approach to publishing accessible documents on GOV.UK. It covers the Offices’ approach to PDFs, spreadsheets and other types of document. It does not cover content published on GOV.UK as HTML, which is covered by a [separate notice published by GOV.UK](https://www.gov.uk/help/accessibility-statement).


Using our Documents

The Certification Officer publishes documents in a range of formats including Word, PDF and Spreadsheets.

We want as many people as possible to be able to use those documents. For example, when we produce documents we make sure to:

  • Provide an HTML option where possible
  • Tag headings and other parts of the document properly, so screen readers can understand the page structure
  • Make sure we include alt text alongside non-decorative images, so people who cannot see them understand what they are there for
  • Avoid using tables, except when we are presenting data
  • Write in plain English

How accessible our documents are

New documents we publish and documents you need to download in order to access one of the services we provide should be fully accessible. However, documents received from Trade Unions and employers’ associations that have to be available for public inspection need to be preserved in the original form so may not be fully accessible.

We know that some of our older documents (published before 23 September 2018) are not accessible, For example, some of them:

  • are just photocopies and are not marked up in a way that allows screen reader users to understand them
  • are not tagged up properly - for example, they do not contain proper headings
  • are not written in plain English

This mostly applies to documents received from Trade Unions and Employers’ Associations, but also includes the Certification Officer’s annual reports and decisions. These types of documents are exempt from the regulations, so we do not currently have any plans to make them accessible.

If you need to access information that is not currently accessible, you can contact us and ask for the information to be provided in an alternative format.

What to do if you cannot use one of our documents

If you need a document we have published in a different format:

Email: [email protected]

Call: 0330 109 3602

Write to:

Certification Office
14 Westfield Avenue
London
E20 1HZ

We will aim to respond within 10 days of having received the request.

Reporting accessibility problems with one of our documents

We are always looking to improve accessibility of our documents. If you find any problems not listed on this page or you think that we are meeting accessibility requirements, contact us on the contact details above.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you are not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Technical information about the accessibility of our documents

The Certification Officer is committed to make our documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018.

The documents the Certification Officer publishes are partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances listed below.

Non accessible content

The content listed below is non-accessible for the following reasons.

  • Decorative image of the Certification Officer had been provided without being hidden from screen reader users. Failed Success Criterion 1.1.1 Non-text Content.
  • Image of the office building does not contain appropriate alternative text. Failed Success Criterion 1.1.1 Non-text Content
  • File types for documents created by the Office and received from Trade Unions and Employers’ Association had not been specified as part of the link. Failed Success Criterion 2.4.4 Link Purpose (In Context)
  • Duplicated form labels (search box) has been used on the Guidance and regulation page, causing confusion for a screen reader user that navigate out of context. Failed Success Criterion 2.4.6 Headings and Labels

We are currently working to address these issues.

When we publish new content, we’ll make sure our use of images meets accessibility standards and file types are labelled.

Disproportionate burden

There are hundreds of historical PDF documents on our website. The vast majority of the documents are of historic interest only and we do not intend to make them accessible. If you want a particular document in an accessible format please contact us using the contact details above.

Content that’s not within the scope of the accessibility regulations

Most of our PDFs don’t meet accessibility standards - for example, they may not be structured in a format that makes them accessible to a screen reader. This does not meet WCAG 2.1 success criterion 2.4.10 (section headings). These are Public documents therefore need to be preserved in the original form received by the Certification Officer.

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services. For example, we do not plan to fix the Annual Reports or case decisions prior to this date.

Any new PDFs, MS Word or spreadsheet documents we create and publish will meet accessibility standards.

How we tested our documents

The Certification Officer is committed to making sure our website and other digital products are accessible to all users and comply with level AA of the internationally recognised standard – The Web Content Accessibility Guidelines – WCAG 2.1.

In order to help us achieve and maintain our objective we commissioned The Digital Accessibility Centre (DAC) to carry out a WCAG 2.1 level technical compliance audit, that also include extensive testing by users with a wide range of disabilities

Our audit took place on place on 14 September 2020. The Accessibility and usability issues reported are currently being addressed.

We tested a representative sample of:

  • PDF documents
  • HTML documents
  • Spreadsheet documents
  • Word documents

What we’re doing to improve accessibility

All our guidance is published in HTML. All Certification Officer decisions and Annual Reports will be published in an accessible format. We are working to publish all our documents in MS word in HTML.

This statement was prepared on 16 October when it was first published.