- The National Library of Scotland (NLS) provides a digital library for anyone with an interest in the recorded knowledge, culture and history of Scotland. NLS is committed to widening access, and aims to provide a welcoming, accessible and inclusive service for anyone who can benefit from its collections and services.
- Users of the NLS digital library should be able to locate the information they require online, or be able to identify whether it is available in non-digital collections if it is not available online. User should be able to gain any assistance they need when navigating the NLS digital library. Increasingly, users should be able to gain access to services previously only available offline, e.g. an online registration system to become Library readers, access to password-protected resources.
- NLS maintains an awareness of its target audiences needs and behaviours through market research and user testing. This information informs the development of the site and its content, and research and testing are repeated to test success in meeting identified needs. NLS will ensure it is user-focused, with user needs at the centre of the entire design process.
- The NLS ethos is to aim for the highest standards in everything it does, including digital access. It is not sufficient simply to achieve a particular legal threshold. NLS takes a broad view of 'accessibility' which includes taking account of the needs of those with physical, mental and sensory impairments.
- In cases where it is not possible to reach the highest-possible standards, NLS will adopt a utilitarian approach, and aim to benefit the widest community whilst taking into account the needs of the minority. NLS recognises that it is not sensible to deny the majority the benefits of technological innovation as a result of issues facing a minority.
- Under the terms of the Disability Discrimination Act (DDA), legal advice suggests that it is unlikely that a web-based service could unequivocally be described as illegal. Therefore, there is no absolute standard which prevents NLS from taking the utilitarian approach described above, providing reasonable adjustments are taken to address outstanding accessibility problems and manage the risk of legal action. NLS lawyers have confirmed that this policy is in line with the provisions of the DDA.
- It is generally accepted, however, that the the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines 1.0 (WCAG 1.0) is the standard most likely to be used in any legal dispute about accessibility. The existence of WCAG 2.0 is noted, but as this standard remains in working draft status, NLS will develop against version 1.0. This position will be reviewed should version 2.0 become a W3C recommended standard.
- NLS acknowledges the Central Office of Information guidance document 'Delivering inclusive websites', which was in formal consultation at the time of writing, and which defines the minimum accessibility standard for all government websites as WCAG 1.0 Double-A. NLS will develop on the assumption that this consultation will result in adoption within the e-GIF policies and standards framework and, by extension, the OpenScotland Information Age Framework (OSIAF). NLS is mandated to comply with OSIAF.
- NLS will deliver web-based services which are measured against the WCAG 1.0 standard, and will aim to comply with level Double-A as a minimum, and, additionally, with any level Triple-A checkpoints used by the RNIB in accessibility audits under the auspices of their 'See it Right' standard.
- NLS recognises that accessibility is not solely about the way websites are coded, but also about how the content is written. NLS will ensure it adopts good practice for web writing, and will use the Plain English Campaign Internet Crystal Mark as the standard against which content is measured.
- NLS recognises the severity of the reputational risk arising
from not providing accessible services online, and will ensure that
this risk is managed as follows:
- A prominent accessibility statement will explain the Library's obligations and standards and make it easy for users to make contact with issues.
- Regular audits of the NLS web presence will be conducted.
- Regular usability studies will include testers with disabilities.
- Consultation will take place with disabled people and their representative organisations about the online services offered by NLS.
- NLS will work with relevant organisations within the library and disability rights communities to make the case to suppliers that they must build accessibility standards into their design processes.
- Where NLS has dealings with suppliers offering inaccessible
systems which fall short of the above accessibility standards, the
following steps will be taken:
- Suppliers will be asked if the failings can be addressed, and at what cost and in what timeframe.
- NLS will make a decision about whether to proceed based on this response, and this decision will be filed for audit purposes.
- If the decision is to proceed, NLS will prepare an interim plan which ensures reasonable adjustments are made to address the needs of users who are unable to use the system, and liaise with relevant organisations (such as the Royal National Institute for the Blind) to seek their support, and to mitigate against the risk of legal action.
24 January 2008