Kent Digital Accessibility Working Group (KDAWG)

Ensuring our digital content is accessible to all 

The University has joined forces with other public sector bodies to ensure Kent becomes a digitally inclusive county. 

The Kent Digital Accessibility Working Group – made up of the University and its ‘Kent Connect’ partners including local authorities, police and fire – aims to meet rules outlined in the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations (2018). 

Members of the group from across the University are already working on a training plan for all organisations involved, as well as adding to the team of experienced accessibility auditors across the county to ensure that all Kent websites are accessible to all. 

The Kent Digital Accessibility Working Group are also taking steps to ensure the University’s own digital content is fully accessible.  

The aim is to improve access for all and this work compliments the Kent Inclusive Practices (KIPs) that the University has already endorsed. 

In addition, the new web template – Site Editor – is designed to be highly accessible, and digital guidelines are being shared with schools and departments to help prepare content for those webpages. i.e a review current content and removal of obsolete information. 

The following principles can and should be applied to all digital material at Kent to help ensure a fully inclusive environment. They include: 

·       Keep content simple

·       Keep it efficient

·       Make sure the text is accessible to other applications

·       Structure your text with style sheets/semantic tags

·       Ensure text can be personalised and reflows when magnified

·       Use short image descriptions known as alt-tags

·       Test it! 

You can see the digital guidelines for more detailed support and information. 

The working group also have created a Digital Accessibility e-learning package in Moodle to give more detail about the regulations and how they will be rolled out across the University of Kent. 

To find out more about the work of the Kent Digital Accessibility Working Group, please see the terms of reference below. For any questions in relation to the guidance please contact a member of the Kent Digital Accessibility Working Group.  




Introduction  1

What do the regulations say?  1

What is the timeline for compliance?  2

Governance  2

Terms of reference  2

Objectives  2

Membership  4

References  4



This paper proposes the initial founding, remit and membership of a University of Kent working group in response to the evolving Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations (2018) (henceforth, ‘The Public Sector Accessibility Regulations’) which are now law in the UK and implement the EU Directive on the accessibility of public sector websites and mobile applications.

The Kent Digital Accessibility Working Group (KDAWG) will aim to understand the scope of the regulations to ensure consistent, sustainable, timely and meaningful compliance with the regulations to help Kent meet the requirements of the regulators and improve the experience of all students.

The group builds on the Accessible VLEs report by PolicyConnect and will benefit from associated communications channels (e.g. JiscMail: to contribute to the national conversation and assimilate central guidance and sector good practice. In addition, Kent staff are founding members of the Further/Higher Education Digital Accessibility Working Group (FHE DAWG) which seeks to benchmark sector approaches to the adoption of the regulations in order that this wider view can feed directly into the strategic direction at Kent.

What do the regulations say?

  1. The regulations require us to take action to ensure that relevant web content[1] and mobile applications comply with the international WCAG 2.1 AA accessibility standard.
  2. The websites and applications of public sector bodies must include an ‘accessibility statement’ that will:
  1. Inform the user of any non-accessible parts of the website and what alternative provision the institution has made to allow the user to access that information (e.g. phone support).
  2. Provide a feedback mechanism for users and a link to the government’s enforcement procedure.

What is the timeline for compliance?

  • The deadlines for compliance are different for different types of content. The key dates are:
    • 23rd of September 2018
      • The regulations become part of UK law
    • 23rd of December 2018
      • The European Commission publishes the harmonised accessibility standard and a model accessibility statement.
    • 23rd of September 2019
      • The following must be accessible:
        • Most web content that was created or substantially revised after the 23rd of September 2018.
        • Intranets that were created or substantially revised after 23rd of September 2019.
    • 23rd of September 2020
      • The following must be accessible:
        • Most web content, regardless of when it was created
          • Exemptions are office documents published before September 2018 (unless they are part of ‘active administrative processes’) and videos published before 23rd September 2020).
    • 23rd of September 2021
      • The following must be accessible:
        • Mobile applications (regardless of when they were created).


To report to the eLearning Strategy Group (ELSG) and to the Web Management Board on matters of strategy and policy in relation to compliance with the new Public Sector Accessibility Regulations.

Terms of reference

To advise on the development of an action plan for relevant Kent web content and oversee its implementation to ensure compliance with the Public Sector Accessibility Regulations.


The initial objectives of the Kent Digital Accessibility Working Group (KDAWG) working group are to:

  1. Define Kent web content categories that ‘count’ in terms of being covered by the scope of the regulations and the types of documents that are required to be accessible.
  2. Review Kent web contents and document types to understand which meet accessibility standards[2] and which require improvement.[3]
  3. Make a roadmap/action plan to show how we’ll take action to meet accessibility standards by resolving issues in order of priority:
    1. Define minimum standards for the creation/amendment of accessible key resource types – referring to the materials already available in the Kent accessibility pages.[4]
    2. Produce guidance on creating content that meets the accessibility standards used by the regulations, e.g. checklists for lectures. (Where such resources already exist we will check them against the new standard rather than start completely afresh).
    3. Collate examples of best practice and approaches for implementing the regulations’ requirements.
  4. Identify potential or perceived legal barriers such as copyright law and determine appropriate solutions to maximise accessibility.
  5. Create a digital accessibility statement for platforms used at Kent such as Virtual Learning Environments (VLEs).[5]
  6. Identify workflows and responsibility for responding within a reasonable amount of time to requests for information in accessible formats.




To ensure a cross-University approach to meeting these regulations we wanted to ensure appropriate and equal representation from teams across the University to demonstrate shared ownership and enable the distribution of clear communications.


The group membership is designed to be flexible so that experts can be brought in at appropriate times where a work package requires particular expertise and experience. This includes but is not limited to members of the Kent Digital Inclusion Alliance (a partnership between the University of Kent and the Kent Connects Partnership (all the Kent and Medway authorities, Kent Police, Kent Fire & Rescue Service and the South East Commissioning Support Unit – NHS)).



  • Mark Fendley, Web Development Manager, Information Service (co-chair).
  • Daniel Clark, University Learning Technologist, Unit for the Enhancement of Learning and Teaching (UELT) (co-chair).
  • Ben Watson, Accessible Information Adviser, Student Support and Wellbeing (co-chair).
  • Claire Chapman, Learning and Organisational Development Consultant (EDI), Learning and Organisational Development (co-chair).
  • Becky Lammyman (Secretary), Student Equality, Diversity and Inclusivity (EDI) Officer, Student Services.
  • Jonathan Thirlwell/ Matthew Bull, UX Developers, Web Development, Information Services.
  • Angela Groth Seary/Sarah Fisher, User Experience and Digital Content, IS Quality and Marketing Team.
  • Nik Duncan, Assistive Technology Assistant, Student Support and Wellbeing.
  • Silvia Colaiacomo, Curriculum and Educational Developer, Curriculum Development Team (UELT).
  • Allie Burnett, Student Communications and Social Media Officer, Stakeholder Communications and Engagement, Corporate Communications.
  • Omolade Adedapo, VP Welfare, Kent Union.
  • Ashley Shelbrooke, Procurement.
  • Chris Morrison, Copyright, Software Licensing and IS Policy Manager, IS Copyright, Software Licensing and IS Policy.
  • Representative from Enrolment Management Services Digital Communications Unit.

Endorsed by Executive Group 8/01/2019


[1] Although yet to be finalised, the current status of the regulation indicate that for universities, almost all content is covered. This includes office documents, videos, and intranets (but excludes maps, live video, hosted content from third parties, and historical archives).

[2] WCAG 2.1 AA accessibility standard

[3] Option A: Commission accessibility audit? These can cost between £3,000 and £7,000 depending on the size and scope of website.

Option B: Self-testing – the GOV.UK Service Manual has sections on automated and manual testing and getting an accessibility audit.

[4] This includes: ensuring PDFs or other documents are accessible, making sure images are accessible, following conventions for creating accessible content (for example, write descriptive links instead of using ‘click here’). Technologies such as Blackboard Ally will also assist in the identification and remediation of content.

[5] For websites, publish the statement as an HTML page, linked to from a prominent place like the website footer. For mobile applications, make the statement available in an accessible format where users can download the application.

The accessibility statement must say:

  • which parts of our service do not meet accessibility standards and why
  • how people with access needs can get alternatives to content that’s not accessible
  • how to contact the University to report accessibility problems – and a link (to be confirmed) to the government website that they can use if they’re not happy with our response