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Disproportionate Burden Assessment | May 2024

Introduction

Velindre University NHS Trust is committed to making its website accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications (No. 2) Accessibility Regulations 2018.

Providing information that’s accessible is important to us so we can ensure donors, patients and members of the public can access our services.

Our Accessibility Statement outlines how we comply with accessibility regulations. The accessibility regulations state that if we believe that a process to comply would impose a disproportionate burden on us, we can negate that element of accessibility.

Scope

This assessment concerns a small number of specific areas of the Trust’s website. These sections are within the ‘About us’ part of the website, including the ‘Public Trust Board,’ ‘Committees,’ ‘Freedom of Information (FOI) Disclosure Logs’ and ‘Policies.’

These sections exist as we have a legal obligation to publish all our board papers, committee papers, reports, disclosure logs, policies and procedures. They hold many PDFs.

There are two primary purposes for information on this website:

  1. General information for patients and members of the public

Information that’s intended for patients and members of the public has been made available as HTML webpages. If there is a PDF available, that is for download purposes only and it will be in addition to a HTML webpage.

  1. Corporate and technical information.

We make many documents available to the public in the interest of transparency. However, these documents haven’t been designed with the general public in mind. They are instead focused on the needs of the technical/expert audience.

The following sub-sections of the website contain collections of information that Velindre University NHS Trust is claiming a disproportionate burden:

These files do not consistently meet accessibility standards, such as:

  • Page titles
  • Headings and labels
  • Non-text content
  • Table headers
  • Contrast (Minimum)
  • Focus order
  • Meaningful sequence

Out of scope

Corporate and technical information (for example: Public Trust Board meetings, Committee meetings, FOI Disclosure logs, Policies and Procedures) is not essential to providing our services. The accessibility regulations, Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, do not require us to fix PDFs or other documents published before 23 September 2018 (opens in new tab) if they are not essential to providing our services. Therefore, we do not plan to fix any PDFs or other documents published before 23 September 2018.

Benefit

The benefit to making these documents into accessible formats are:

  • The information would be accessible to all, such as those who use assistive technologies.
  • Users would not have to get in touch to request accessible versions of documents.

Burden

We have conducted an objective assessment of resources required to convert the non-compliant PDF that are in scope.

Assessment

We found:

  • There are more than 800 PDFs that have been uploaded within the area outlined in scope.
  • These documents are as follow: 26 Public Trust Board meeting documents, 95 committee meeting documents, 4 Annual Reports, 160 policy documents, and 518 FOI Disclosure Logs.
  • Over a six-month period from 1 November 2023 to 30 April 2024, these sections of the website accounted for a combined 1,186 webpage views. (Please note, analytics are only available on individual webpages and not for specific documents due to the limitations of Google Analytics.)
  • We tested several sample documents to estimate the time it would take to convert them to an accessible format. We did this both by using Adobe Acrobat and Microsoft Word to make accessible updates. In both cases, this took at least one hour for moderately sized documents. For larger documents (such as Trust Board and Committee meeting papers), this would take considerably longer. Although more familiarity with the process would reduce the time it would take to convert all 800 PDFs to accessible documents, a conservative estimate to fully convert all of the documents is comfortably over 1,000 hours. This would equate to more than six months for one full-time member of staff working solely on document conversion.
  • The Corporate Governance team is responsible for most of the 800 PDFs. It is a small team and has limited resource. Based on their existing workload, asking them to convert the documents would place them under disproportionate burden in terms of human resource, cost, and time. Another option could be an external agency on short term contracts but due to the financial constraints facing NHS Wales, this is not viable.
Additional information:
  • The website has been live since 2020 and we have never received a complaint about a user not being able to access a PDF. In addition, a notice has been added to webpages that host PDFs with instructions on how to request an accessible version of the document.
  • As most of the documents are for previous meetings, they are unlikely to be reflect the current position of the Trust. They only offer a historical snapshot of our position at that time and have limited value if a user is seeking the current position.

Based on the assessment above, we consider the conversion of 800 PDFs to accessible documents to be of limited value to the public and a poor use of the Trust’s resources.

We have assessed that fixing all PDFs published on our website since 21 September 2018 would place a disproportionate burden on the Trust.

This assessment was prepared in May 2024.

Supporting breakdown of data (1 November 2023 - 30 April 2024)

Public Trust Board Meetings
Total number of PDF documents: 26
Unique visitors over a six-month period: 44

Quality, Safety and Performance Committee
Total number of PDF documents: 17
Unique visitors over a six-month period: 141

Strategic Development Committee
Total number of PDF documents: 14
Unique visitors over a six-month period: 59

Audit Committee
Total number of PDF documents: 12
Unique visitors over a six-month period: 63

Charitable Funds
Total number of PDF documents: 9
Unique visitors over a six-month period: 106

Charitable Funds Investment Performance Review Sub Committee
Total number of PDF documents: 3
Unique visitors over a six-month period: 21

TCS Programme Scrutiny Sub-Committee
Total number of PDF documents: 31
Unique visitors over a six-month period: 110

RD&I Sub Committee
Total number of PDF documents: 9
Unique visitors over a six-month period: 62

Annual Reports
Total number of PDF documents: 4
Unique visitors over a six-month period: 111

Policies
Total number of PDF documents: 160
Unique visitors over a six-month period: 389*

*Note: The potential reason for a higher number of visitors to the policies page may be because it is the main location for all staff-facing policies for Velindre University NHS Trust’s 1,600+ staff. Corporate Governance made the decision to host the policies in one place to avoid duplication between the intranet and internet sites. The number of unique visitors account for those who land on the main policies page and not its associated sub-pages.

FOI Disclosure Logs
Total number of PDF documents: 518
Unique visitors over a six-month period: 80