Prepared: January 2025, to be reviewed and updated to reflect progress, by the end of Q4 2025
Under the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, we are committed to making our website accessible. However, we have determined that meeting certain accessibility requirements would impose a disproportionate burden on our Health Board.
Name: Betsi Cadwaladr University Health Board
We are the largest health organisation in Wales, with a budget of £1.87 billion and a workforce of over 19,000. The Health Board is responsible for the delivery of health care services to more than 700,000 people across the six counties of north Wales (Anglesey, Gwynedd, Conwy, Denbighshire, Flintshire and Wrexham). The Health Board coordinates the work of 96 GP practices, and NHS services provided by 78 dental and orthodontic practices, 70 optometry practices and opticians and 145 pharmacies in North Wales.
The reason for this Disproportionate Burden Assessment is due to the significant number of PDFs on the Health Board's website that are not accessible. These documents, created over several years by various authors across the Health Board, do not meet WCAG 2.2 accessibility guidelines.
In the next 12 months, we will implement a new process which will replace how documents are currently published on this website, and will prioritise our efforts to achieve this Health Board wide. We will ensure that there is an improved process to creating accessible documents for sharing both internally and externally, and more specifically to this assessment - when publishing documents in a PDF format this website. At present we are in the early stages of this development.
The Health Board’s Digital Communications Team is responsible for developing and managing the majority of the HTML information (pages) on this website.
There are two aspects to the content produced and published, the first being content that is essential to providing a service, which is developed in a HTML format for the general public, and the second being content produced in a PDF format (mainly under the About Us tab), which is corporate and technical in nature and is published for transparency and/ or reporting, for example:
We acknowledge that some corporate and technical documents and PDFs may be difficult to read and understand. In the short term, we are providing a method of contact for website visitors to request further information in an alternative format. The information which is essential to users in terms of the services we provide and how to access those services is routinely developed by the Digital Communications Team, as website projects, in a HTML format.
Average monthly webpage views: 1 January – 31 December 2024:
The average monthly page views for the Health Board Meetings, Committee meetings, and About us sections account for approximately 1.07% of the total monthly views on this website.
This indicates that while these sections which contain corporate and technical documents are important, they represent a small fraction of the overall website traffic. It is also likely that a proportion of this traffic comes from colleagues who create, view and upload documents of this nature to the ‘About Us’ section of the website, and colleagues/ stakeholders who require this type of technical and corporate information, as opposed to the general public.
This calculation aims to support the claim that allocating extensive resources to make historic PDFs accessible is not the most efficient use of time and limited resources, given the broader scope of what we aim to achieve in the next 12 months, with the implementation of a new approach.
In August 2023, a Health Board wide Website and Social Media Content Protocol was approved and published on BetsiNet (staff intranet). This protocol sets out a clear approval process for content on this website, and establishes roles and responsibilities, as well as how the content is monitored and evaluated. This protocol defines how this website should provide accessible, relevant, accurate and compliant information.
Documents are no longer published on the website unless deemed essential in a PDF format and a legal requirement and/ or instruction. Information that’s relevant within documents for the general public is presented in a HTML format and developed into accessible and relevant information.
A paper outlining our plan to develop a new process for creating managing accessible documents Health Board wide has been prepared (November 2024), and is under review (February 2025). Following the presentation of this paper to executive directors, a task and finish group will be established by Corporate Governance to take this work forward with input from the Digital Communications Team by the end of Q4 (2024/25). (Update as of March 2025: an imminent update is pending for this section.)
Options include:
Scenario: The Digital Communications Team, review, remove and make changes to non-accessible PDFs
To provide a detailed time vs people analysis, we have considered the following factors:
Based on the factors above:
This analysis shows that it would take approximately 50 weeks for 2 full-time employees (2/3) in the Digital Communications Team to review and remediate 500 PDFs, assuming they can dedicate all of their time to this task and given the scope of this small team is to provide both reactive and proactive communications support across all digital channels and platforms, to all NHS services in North Wales. Given the current workload and other responsibilities, this timeline is even less feasible, further supporting the need for a new process. To progress, available resources Health Board wide should focus on a new way forward as opposed to amending historical issues, and this is the case for this Disproportionate Burden Assessment.
Requests to upload PDFs are being declined by the Digital Communications Team, with the offer of providing an overview of this information in an accessible HTML format if relevant. This will be the case unless the PDF is business essential, and a new process takes into account fixing these issues in time, for example the re-formatting of our Board papers and the other corporate documents referenced to.
We are prioritising the development of a new process to creating, managing and publishing accessible documents. We now have the combined skills, understanding and knowledge across directorates to progress with a new approach.
If you have any difficulty accessing information and PDFs on our website, and/ or require information in a different format, please email: bcu.digital@wales.nhs.uk.
For support with accessing Board and committee meeting papers, please email: BCU.OBS@wales.nhs.uk.
This claim and assessment was checked and approved by the following directors on the 27 January 2025: