Under the Number 2 Regulations: Interpretation, we have determined that it would be a disproportionate burden to pay for the services of an external auditor to perform a detailed check on our entire collection of websites. 

The majority of our important content and transactions for residents are provided on our main website, our partner platforms and external portals. We periodically run detailed checks on these. See our accessibility statement.

We use a combination of methods to perform these checks, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the Number 2 Regulations. - GOV.UK website

Review of existing documents 

Some PDFs and Word documents published before 23 September 2018 may not be accessible for several reasons.

Due to the high number and age of some of the documents on the website, we are still working across our services to ensure these documents are brought in line with WCAG 2.1 standards. 

We review all new documents to ensure they meet accessibility standards before adding them to the site as part of our website governance.

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, therefore these documents fall under disproportionate burden and are not being reviewed.

As of 23 November 2021, there are 1,012  download files on our main website (this does not include those in applications such as ModernGov – Council agendas and reports). 

These files may contain several documents that are made up of PDF, CSV or Word documents, of which 513 have been published since 23 September 2018.

Our time, effort and resources will be focused on fixing the most viewed documents and ensuring that any new documents are fully accessible. 

Time and cost of making all downloads accessible 

We have worked hard to reduce the number of downloads on the Oldham Council website and to instead work with the services to present the information as fully accessible web content.   

On average, we estimate that it could take at least 1 hour of work to make each download accessible on oldham.gov.uk. 

Presuming 7.5 hours in a working day, the time needed to convert all 1,012 existing downloads would be 134 full working days. 

This would be the minimum amount of time that it would take to review all documents, as many documents could be longer than one page and so would require more time and resources.  

Resource limitations

Oldham Council is a local authority and due to competing priorities, the resources available to tackle outstanding accessibility issues of low priority are limited.

While we do all we can to address accessibility issues, the resources required to address many of the lower priority accessibility issues in a short period of time would mean resources would need to be diverted from maintaining essential services and continuing current development.

We continue to utilise our existing resources to perform accessibility audits and address outstanding accessibility issues.

Presuming 30 minutes per page, with 4,500+ pages on the main site alone, a rough estimate for a full site audit would take 2,250 hours.

Presuming 7.5 hours in a working day, this would take 300 days.

The coronavirus (COVID-19) pandemic has also lead to resources being prioritised on continuing essential services.

Other burdens 

Several of our website’s subdomains are hosted on separate platforms, 

These include:  

  • committees.oldham.gov.uk - a Modern Gov platform for historic council minutes, meetings and agendas, this area of the website is managed by our Constitutional Services team. On this site, information must be collated and published publicly within a short legal timeframe.    
  • myaccount.oldham.gov.uk - is a customer account providing information on Council Tax and Housing Benefit
  • planningpa.oldham.gov.uk  is our planning portal which is managed by our planning team  

These subdomains predate accessibility legislation and are not WCAG 2.1 AA compliant.

We are working with these teams and the platform providers on making their content accessible going forward or developing alternate solutions which will be WCAG 2.1 AA compliant.

Capita payments 

Our payments are processed through a third-party payment platform, E-paycapita. E-paycapita is not WCAG 2.1 AA compliant, however we have raised this with the supplier and are developing an alternate solution.

Weighing the cost of internal and external audits 

Our accessibility audits have been performed internally using accessibility analysis tools such as WAVE, Adobe Acrobat DC Pro and NVDA screen reader. 

These have been performed on a selected sample of our websites’ most frequently visited webpages. 

We also use the SortSite accessibility tool to highlight accessibility issues with our content pages. 

In our view, it would be a disproportionate burden to: 

  • Pay for a detailed checks for all pages on our corporate website and included documents
  • Audit every webpage on our subdomains  
  • Audit every page on our organisation’s third-party sites
  • Make all documents on oldham.gov.uk WCAG 2.1 compliant due to the low usage of a large number of them

Mitigating burden

We currently perform internal audits of our websites and prioritise our most frequently accessed pages for our samples.

We have also brought in guidelines so that, where possible, content being added to the site is now being done so in a way in line with accessibility regulations.

We are dedicating web team resources to supporting content authors in gaining the knowledge and skills to produce accessible content. This activity is aimed at addressing the accessibility issue ‘at source’ and so reduce the need for retrospective remediation of documents.

We hope to resolve outstanding issues as we reassess our resources when we run our internal audits.

Last update

This statement was prepared and published on 23 November 2021