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From: Jim Byrne Accessible Web Design
Date: Fri, Aug 04 2023 8:27AM
Subject: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Hi,

I'm just trying to get clarity in relation to the map exemptions for Public Sector Bodies Accessibility Regulations.

The The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 state.

"online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use”

This mentions only maps used for navigation use. Does it meant that all other types of maps are not exempt?

The guidance on the UK Government page with the title, 'Understanding accessibility requirements for public sector bodies’ states:

"Your team does not need to fix the following types of content because they're exempt from the accessibility regulations:

* maps - but you’ll need to provide essential information in an accessible format like an address.”

Again the UK Government page seems to suggest that all maps are for giving directions? Or are they suggesting that all other types of map are not exempt?

Re: essential information
Information deemed ‘essential’ surely must be connected to the role/function/information that the map is being used to present?

I'm looking at maps right now that are related to building standards. So, would you agree that all relevant information that the map is designed to show, is ‘essential' information and should be provided in an alternative, accessible format?

I'm aware that maps are also exempt from WCAG 2.1.

Thanks,
Jim







About Jim Byrne
With over two decades of experience Jim Byrne is one of the UK's most experienced practitioners in the area of accessible web design. Jim provided feedback during the development of WCAG 2 as part of the Guild of Accessible Website Designers. He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.

Jim Byrne: Specialist in Accessible Website Design.

Web: http://www.jimbyrne.co.uk

Twitter: http://twitter.com/#!/jimbyrnewebdev

Facebook: https://www.facebook.com/thirdsectorwebsitedevelopment

From: Jim Byrne Accessible Web Design
Date: Fri, Aug 04 2023 8:52AM
Subject: Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Hi,

Here's my logic that non-navigation maps are not exempt from Public Sector Bodies Accessibility Regulations:

The Public Sector Bodies Accessibility Regulations (PSBAR) state that public sector websites must be accessible. However they give an exemption for “online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use”. The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018

So, maps used for navigation do not need to be accessible. However, it does not say that all dynamic maps are exempt.


So we look to, the guidance on the UK Government page with the title, 'Understanding accessibility requirements for public sector bodies’ states:

"Your team does not need to fix the following types of content because they're exempt from the accessibility regulations:

• maps - but you’ll need to provide essential information in an accessible format like an address.” Understanding accessibility requirements for public sector bodies

This is ambiguous, as it starts by saying ‘maps’ - suggesting all maps. However it then suggests that it is referring only to maps used for navigation.

It is however clear that, “you’ll need to provide essential information in an accessible format”. Information deemed ‘essential’ will be connected to the type of information the map is being used to present. So, if the map is not for navigation, the ‘essential information’ you are using the map to put across should be provided in an alternative, accessible format.

Therefore, a map may be the most concise and appropriate way to present your information but it does not make you exempt from UK equality legislation.

That's how I'm interpreting it.

Jm


> On 4 Aug 2023, at 15:27, Jim Byrne Accessible Web Design < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi,
>
> I'm just trying to get clarity in relation to the map exemptions for Public Sector Bodies Accessibility Regulations.
>
> The The Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 state.
>
> "online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use”
>
> This mentions only maps used for navigation use. Does it meant that all other types of maps are not exempt?
>
> The guidance on the UK Government page with the title, 'Understanding accessibility requirements for public sector bodies’ states:
>
> "Your team does not need to fix the following types of content because they're exempt from the accessibility regulations:
>
> * maps - but you’ll need to provide essential information in an accessible format like an address.”
>
> Again the UK Government page seems to suggest that all maps are for giving directions? Or are they suggesting that all other types of map are not exempt?
>
> Re: essential information
> Information deemed ‘essential’ surely must be connected to the role/function/information that the map is being used to present?
>
> I'm looking at maps right now that are related to building standards. So, would you agree that all relevant information that the map is designed to show, is ‘essential' information and should be provided in an alternative, accessible format?
>
> I'm aware that maps are also exempt from WCAG 2.1.
>
> Thanks,
> Jim
>
>
>
>
>
>
>
> About Jim Byrne
> With over two decades of experience Jim Byrne is one of the UK's most experienced practitioners in the area of accessible web design. Jim provided feedback during the development of WCAG 2 as part of the Guild of Accessible Website Designers. He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.
>
> Jim Byrne: Specialist in Accessible Website Design.
>
> Web: http://www.jimbyrne.co.uk
>
> Twitter: http://twitter.com/#!/jimbyrnewebdev
>
> Facebook: https://www.facebook.com/thirdsectorwebsitedevelopment
>
>
>
> > > > About Jim Byrne
With over two decades of experience Jim Byrne is one of the UK's most experienced practitioners in the area of accessible web design. Jim provided feedback during the development of WCAG 2 as part of the Guild of Accessible Website Designers. He is the author of a number of technical books, training courses and accessibility guides. Jim was a winner of the equal access category of the Global Bangemann Challenge.

Jim Byrne: Specialist in Accessible Website Design.

Web: http://www.jimbyrne.co.uk

Twitter: http://twitter.com/#!/jimbyrnewebdev

Facebook: https://www.facebook.com/thirdsectorwebsitedevelopment

From: Steve Green
Date: Fri, Aug 04 2023 9:06AM
Subject: Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Hi Jim, you've actually got it back to front.

Firstly, note that the 2018 regulations have been subject to a post-Brexit 2022 amendment at https://www.legislation.gov.uk/uksi/2022/1097/made. The amended regulations are essentially the same, but there are two key differences:

1. They explicitly refer to WCAG, whereas the original regulations referred to EU standards. This meant that EN 301 549 applied, which contains a few requirements that are not in WCAG 2.1 (not that anyone ever took any notice of this).

2. Conformance with new versions of WCAG will automatically become mandatory. This was not the case with the original regulations - my understanding is that updated versions of EN 301 549 would apply, but it would not automatically be updated to match the latest version of WCAG.

To your question, as is so often the case, explanatory information provided by various sources is misleading or wrong. In this case, the regulations are so simple that no further explanation is necessary. Simply rearranging the awkwardly written clause 4.-(2)(d), we get two statements:

1. For maps intended for navigational use, essential information must be provided in an accessible digital manner.

2. These Regulations do not apply to other online maps and mapping services.

It really is that simple. Unfortunately, some people have latched onto the phrase "essential information" and are saying that all essential information in maps must be provided in an accessible manner. That is not true.

Note that some organisations may require mapping services to achieve a higher level of accessibility, but that is an internal decision not mandated by law. For instance, we are working on a hideously complicated interactive map for estimating air pollution levels arising from proposed building developments. This is exempt from the regulations, but the government department involved would only fund the project if it is designed to achieve a high level of accessibility. GDS insist we aim for more than WCAG conformance, so we are doing user testing with disabled participants over the next couple of months (which of course the regulations do not require).

Steve Green
Managing Director
Test Partners Ltd

From: Jim Byrne Accessible Web Design
Date: Fri, Aug 04 2023 10:03AM
Subject: Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Thanks Steve,

I had an idea there were 2022 changes but I didn't come up with anything relevant - when searching for information on this topic.

Re: having them around the wrong way.

> 1. For maps intended for navigational use, essential information must be provided in an accessible digital manner.

On this point we agree.

> 2. These Regulations do not apply to other online maps and mapping services.

On this point it's not clear to me what you are saying: are you saying other online maps and mapping services don't need to be accessible?

If so can you point me to the where this is stated. I searched for clause 4.-(2)(d) but I couldn't find it. Maps aren't mentioned on the page at https://www.legislation.gov.uk/uksi/2022/1097/made - and I don't see anything called clause '4.-(2)(d)'

Thanks for your help. It is very much appreciated. :-)

Jim



> On 4 Aug 2023, at 16:06, Steve Green < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi Jim, you've actually got it back to front.
>
> Firstly, note that the 2018 regulations have been subject to a post-Brexit 2022 amendment at https://www.legislation.gov.uk/uksi/2022/1097/made. The amended regulations are essentially the same, but there are two key differences:
>
> 1. They explicitly refer to WCAG, whereas the original regulations referred to EU standards. This meant that EN 301 549 applied, which contains a few requirements that are not in WCAG 2.1 (not that anyone ever took any notice of this).
>
> 2. Conformance with new versions of WCAG will automatically become mandatory. This was not the case with the original regulations - my understanding is that updated versions of EN 301 549 would apply, but it would not automatically be updated to match the latest version of WCAG.
>
> To your question, as is so often the case, explanatory information provided by various sources is misleading or wrong. In this case, the regulations are so simple that no further explanation is necessary. Simply rearranging the awkwardly written clause 4.-(2)(d), we get two statements:
>
> 1. For maps intended for navigational use, essential information must be provided in an accessible digital manner.
>
> 2. These Regulations do not apply to other online maps and mapping services.
>
> It really is that simple. Unfortunately, some people have latched onto the phrase "essential information" and are saying that all essential information in maps must be provided in an accessible manner. That is not true.
>
> Note that some organisations may require mapping services to achieve a higher level of accessibility, but that is an internal decision not mandated by law. For instance, we are working on a hideously complicated interactive map for estimating air pollution levels arising from proposed building developments. This is exempt from the regulations, but the government department involved would only fund the project if it is designed to achieve a high level of accessibility. GDS insist we aim for more than WCAG conformance, so we are doing user testing with disabled participants over the next couple of months (which of course the regulations do not require).
>
> Steve Green
> Managing Director
> Test Partners Ltd
>
>
>

From: Steve Green
Date: Fri, Aug 04 2023 11:08AM
Subject: Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Yes, I am saying that according to the regulations, other online maps and mapping services don't need to be accessible. Of course they may need to be accessible for all sorts of other reasons, such as WCAG conformance, Equality Act compliance, public sector equality duty, internal policies etc.



Clause 4.-(2)(d) is in the 2018 regulations at https://www.legislation.gov.uk/uksi/2018/952/made and is not affected by the 2022 amendments. The clause says:



4.—(1) These Regulations apply to a website or mobile application of a public sector body, except a website or mobile application of—



(a)public service broadcasters and their subsidiaries, and of other bodies or their subsidiaries fulfilling a public service broadcasting remit;

(b)non-governmental organisations, unless they provide services that—

(i)are essential to the public; or

(ii)specifically address the needs of, or are meant for, persons with disabilities; and

(c)schools or nurseries, except for the content of their websites or mobile applications relating to essential online administrative functions.

(2) These Regulations do not apply to the following content of a website or mobile application of a public sector body—



(a)office file formats published before 23rd September 2018, unless such content is needed for active administrative processes relating to the tasks performed by the public sector body;

(b)pre-recorded time-based media published before 23rd September 2020;

(c)live time-based media;

(d)online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use;



I have bolded the relevant phrases above.



Steve

From: Jim Byrne Accessible Web Design
Date: Mon, Aug 07 2023 3:01AM
Subject: Re: Map exemptions from Public Sector Bodies Accessibility Regulations - trying to get clarity on what is exempt and what not
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Thanks Steve,

Much appreciated.

Speak soon,
Jim

> On 4 Aug 2023, at 18:08, Steve Green < = EMAIL ADDRESS REMOVED = > wrote:
>
> Yes, I am saying that according to the regulations, other online maps and mapping services don't need to be accessible. Of course they may need to be accessible for all sorts of other reasons, such as WCAG conformance, Equality Act compliance, public sector equality duty, internal policies etc.
>
>
>
> Clause 4.-(2)(d) is in the 2018 regulations at https://www.legislation.gov.uk/uksi/2018/952/made and is not affected by the 2022 amendments. The clause says:
>
>
>
> 4.—(1) These Regulations apply to a website or mobile application of a public sector body, except a website or mobile application of—
>
>
>
> (a)public service broadcasters and their subsidiaries, and of other bodies or their subsidiaries fulfilling a public service broadcasting remit;
>
> (b)non-governmental organisations, unless they provide services that—
>
> (i)are essential to the public; or
>
> (ii)specifically address the needs of, or are meant for, persons with disabilities; and
>
> (c)schools or nurseries, except for the content of their websites or mobile applications relating to essential online administrative functions.
>
> (2) These Regulations do not apply to the following content of a website or mobile application of a public sector body—
>
>
>
> (a)office file formats published before 23rd September 2018, unless such content is needed for active administrative processes relating to the tasks performed by the public sector body;
>
> (b)pre-recorded time-based media published before 23rd September 2020;
>
> (c)live time-based media;
>
> (d)online maps and mapping services, as long as essential information is provided in an accessible digital manner for maps intended for navigational use;
>
>
>
> I have bolded the relevant phrases above.
>
>
>
> Steve
>
>
>
>
>
>