Paul Smyth offers guidance and advice on how disabled people can provide feedback when encountering online barriers with websites, in this complaints guide.
Website owners have many priorities for changes and improvements, and the more an organisation hears about accessibility from people who use their digital service, the more likely it is that accessibility will become a higher priority.
Some organisations are not even aware of the importance of making their website accessible despite there being clear accessibility legislation (UK Equality Act 2010).
Your feedback to an organisation can help improve the accessibility of websites, mobile apps or kiosks for you and many other people who use the digital service.
Who’s this guide for?
People who encounter challenges when attempting to use a digital service (such as a website) because it does not take into account their accessibility needs arising from, for example, impaired vision, hearing, dexterity, or ability to remember and process information.
Why is this guide needed?
- There’s a lack of practical, clear guidance on how disabled people can provide feedback when encountering online barriers with websites, mobile apps or self-service kiosks, e.g. where to go, what to say and how to say it in order to influence organisations to make positive change for you and other people with access needs.
- Whilst accessibility legislation gives clear requirements of how organisations can build accessible digital services, it’s often unclear as to how this is enforced and how users can raise complaints and/or escalate these to an ombudsman.
Why is this important?
- Did you know that for every 10 disabled users encountering barriers online, only one will bother complaining whilst the other 9 will give up or take their business elsewhere? (Click Away Pound research). This is because complaining in itself can be complicated, involve inaccessible feedback mechanisms and leave consumers feeling like they probably won’t get listened to in any case.
- What’s clear is that we need to make complaining about accessibility issues (& escalating these issues) more simple to encourage more disabled people to use their voice and point out where barriers still exist.
- Likewise, government, service providers and ombudsman need to ensure that legislation is enforced and complaints are listened to and acted upon.
What this guide covers
- Step-by-step practical guidance on how to complain to an organisation or service provider when you’ve encountered an online barrier.
- What to say, how to say it assertively and where to direct your feedback or complaint to maximise the chance that your voice is heard and feedback acted on.
- What to do if you get no response from the organisation or service provider and need to escalate your complaint.
- Charities and consumer advice groups who can support you to escalate your complaint and/or take legal action if appropriate.
Complaints steps when encountering online barriers
Step 1: Give feedback direct to the organisation
Identify key contacts
- Does the service provider have an Accessibility help page with any useful information or contact channels you could use such as an Accessibility team?
- Failing that, does the service provider’s website have a general ‘Contact Us’ mechanism or a Complaints process that you could use to provide your feedback? What about Twitter?
Describe the problem
To help the organisation diagnose and fix accessibility barriers, clearly describe where the problem occurred, what the problem is, what you were trying to do, and what computer and software you’re using.
- Where is the problem? Include the web address (also called URL), or a description of the page.
- What is the problem? Provide details about what you were trying to do, and why it was difficult or impossible to do it.
- What computer and software are you using? Provide details about your computer and software While most accessibility barriers are caused by poor website design, remember that some accessibility problems might be related to settings in your web browser or assistive technology.
- Share accessibility guidance: It’s helpful to assume that the organisation is unaware of accessibility and to signpost off to useful information where they can find out more. In a nutshell though,
- organisations have a legal duty under the UK Equality Act to deliver digital services that are accessible – ensuring they are easy for everyone to see, hear, understand and use. They can achieve this by developing their sites to be compliant with the Web Content Accessibility Guidelines (WCAG).
- Failure to do this means that organisations will have made it difficult or impossible for disabled users to access and use their site as well as breaching their legal obligations under the Equality Act.
- Ask for a response: As well as being specific on the problem you’re encountering, be assertive in requesting a response back and your preferred communication method (email, phone, etc.). It’s useful to keep a detailed record of dates when you’d encountered the problem as well as subsequent conversations you’ve had.
- For more detailed guidance on key information to include check out the W3C’s useful guide on contacting organisations about inaccessible websites.
Step 2: Escalate to the organisation
If you do not receive satisfactory responses within a reasonable timeframe, consider taking further action
- If you haven’t done so already, raise a formal complaint with the organisation
- Large organisations may have dedicated complaints teams and timescales for responding to you. If you don’t hear anything back, you may want to consider routing your query to their senior management / CEO.
- If you’ve raised a formal complaint, there may be an industry regulator or ombudsman for escalating your complaint to if the organisation is unable to provide a satisfactory response.
- Consider contacting a disability charity or advocacy group for advice and support on escalating your complaint
- Consider using social media or blogs to more publicly raise your concerns with the organisation.
- Consider engaging the press, your local MP or starting an online petition.
It’s always preferable to have a constructive dialogue with the organisation directly. However, in rare instances where the organisation is unwilling or unable to discuss, commit to or make improvements to the accessibility of their digital services, you may need to escalate your complaint further or take legal action.
Step 3 – Escalate to the Equality Advisory and Support Service (EASS)
- The Equality Advisory and Support Service (EASS) advises and assists individuals on issues relating to equality and human rights, across England, Scotland and Wales.
- Online accessibility issues encountered with public sector websites (e.g. local authorities) or private sector websites (e.g. online retailors or banks) should be escalated to the EASS.
- If you have an issue of discrimination with a service provider, then you could contact the EASS Helpline who can offer bespoke informal advice on a person’s rights under the UK Equality Act. Their helpline and online resources explain how a disabled person is protected from discriminatory treatment under the Equality Act and how to raise an informal grievance with the organisation.
- If you follow the EASS advice to raise an informal grievance and are still unhappy with the response you receive from the organisation (or you don’t get a response at all) the EASS can engage the organisation on your behalf in the hope of achieving an informal resolution.
- In rare instances you may need to consider escalating further and taking legal action with a discrimination claim. It’s recommended that you exhaust all other routes of raising formal complaints first and be mindful that a discrimination claim needs to be raised within 6months of the barrier being experienced.
Paul Smyth is the Web Accessibility Disability Sector Champion for UK Government and Head of Digital Accessibility for Barclays, where he is responsible for ensuring that the bank’s digital services work for everyone, including disabled customers & colleagues. Views expressed in this article are his own.
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