Disproportionate burden assessments
We do not currently believe there are any technical aspects of the website that could be considered a disproportionate burden under the web accessibility regulations.
We are currently working on our accessibility roadmap with our web development team and The Shaw Trust. If this assessment changes we will update this document.
The website contains more than 1,600 documents, in various formats that are not accessible. While we intend to go through these documents and either remove or replace these with a HTML page or other accessible alternative, there are some documents we believe it would be disproportionate to make accessible.
This is based on the impact they would have on the organisation, cost to the taxpayer and the limited benefit they would have to people with accessibility issues.
These documents include those listed below on this page.
Election documents (such as notice of polls, notice of candidates, etc)
Our elections team uses a third party software called Xpress to automatically generate key elections documents such as notice of polling stations and notice of candidates. This software is not able to produce documents in an accessible format currently. This is largely due to the fact the way elections documents are set out is controlled by legislation.
It is not feasible to manually reproduce elections information in an accessible format because of the time it would take, the tight deadlines elections are run to and the fact the elections team is small, consisting of only four people. Making documents fully accessible would risk legal deadlines in the elections process being missed with all the implications for the council in terms of legal challenges to the election result and associated court costs.
Although voting in an election, understanding where to vote and who the candidates are is key information vital to a citizen’s ability to take part in the democratic process, the elections team has well-established processes in place to make sure anyone unable to access this information via our website can do so. This includes providing information in other formats.
For these reasons, we believe making our elections documents accessible would be a disproportionate burden. We are in contact with Civica, who developed the Xpress software, about this issue which has also been raised at a national level as all councils are facing the same issue. Elections officers are working with them on a fix and it will be implemented as soon as it is available. We will keep this situation under constant review.
Anyone who need to access elections information and has been unable to do so through our website should contact the elections team on 01684 862259 or email
Annual Statement of accounts
The Annual Statement of Accounts is a complex document. The content and layout of the Statement of Accounts is prescribed by the Code of Practice issued by CIPFA (Chartered Institute of Public Finance) which is in turn based on the requirements set out in International Accounting Standards.
It is a largely technical document and contains complex tables throughout that do not meet accessibility guidelines. It also contains technical phrasing and concepts.
To meet accessibility guidelines an additional alternative format document would be required. Some of the information required by the Code of Practice would have to be omitted because it is not possible to present it in an accessible way.
We estimate that it would take an extra 10 days of officer time to develop and update the additional document. This document would have to be audited by the external auditors and approved by committee.
We estimate the cost to the Council would be £4,000 to prepare the document each year and up to £5,000 to audit the document each year.
CIPFA have yet to publish anything on accessibility. The Code of Practice is updated annually. The latest consultation on the code of practice published on 4 February 2022 focuses on delays in 20/21 audits and has no mention of accessibility.
CIPFA can update the Code to provide content and layout to meet accessibility guidelines.
However this is likely to be an additional document because of the complexities of the accounting standards that govern the information contained in the Statement of Accounts document. Current CIPFA communications do not make any reference to this for 2022/23.
The Statement of Accounts is not widely reviewed on the website (xx views), with information relevant to residents (such as how the council spends council tax funding) available from other areas of the website in an accessible format.
The finance team work to a strict and short deadline to produce the statement of accounts in the prescribed format. There is significant pressure on both the finance team to prepare the document and supporting working papers and also the external auditors to complete the audit within the national deadlines. The external audit market is suffering significant shortage of resources and additional burdens in terms of the level of examination they have to undertake. An additional document would have to be audited with the same level of examination of the statement of accounts.
This would need an increase in audit resources at a direct cost to the council but also imposes significant pressure on the finance team to prepare the additional document and the supporting working papers.
The finance team are also happy to consider requests from people with accessibility issues for information that may be contained in the statement of accounts in the following ways:
- By phone by calling our customer service team on 01684 862413.
- By email at
This email address is being protected from spambots. You need JavaScript enabled to view it. . Please include the information you would like and the format you would like it in.
We believe based on the assessment above that making the statement of accounts fully accessible would be a disproportionate burden on the council given the impact it would have on delivering a critical, and legally required, council function with minimal benefit to people with accessibility issues.
We will review this disproportionate burden assessment before 10 February 2023.
Planning weekly lists
The planning weekly lists are downloaded from third party software operated by DEF which provides most of the planning software for planning authorities across the UK. As this is a third party operator not directly developed, commissioned, controlled or funded by us it could be said to be outside the scope of the regulations, but we have included a disproportionate burden assessment as we control the data that goes into the system.
When the lists are downloaded each week they are generated in a set template as a Word document or PDF. We don’t have the ability to control what this template looks like. The template unfortunately uses tables for layout reasons that are not accessible as they cannot be fully understood by a screen reader.
To make them accessible would require restructuring and formatting the entire document from scratch each week, and repeating that process 5 other times for the various lists. The number of items on each list varies from week to week but on an average week about 15 and 20 items per list can be expected.
We estimate it would take 4.5 hours of officer time a week to convert each of these lists or 234 hours. This compares to the current 10 minutes for all lists each week.
We have contacted Def, the software provider who tell us they are aware of the accessibility issues and it is affecting all councils across the UK. They are committed to tackling these issues but are finding meeting the regulations challenging.
Def have issued a statement on accessibility on their website.
Read the Def accessibility statement.
Def has indicated they are working on a fix and would be willing to work with us in future to design an accessible template that would reduce the burden and allow us to meet the regulations. We don’t have a timeline for a fix though.
We have checked the lists with screen reading software and they are partially compliant in that a user would be able to get the basic information they need but it is made more difficult by their lack of full accessible functionality.
The lists themselves just provide basic information on what has been validated in any given week. There are alternatives available to view or search for applications using our planning search feature which is accessible.
The planning team are also happy to consider requests from people with accessibility issues for information that may be contained in the lists in the following ways:
- By phone by calling the planning service support team on 01684 862221.
- By email at
This email address is being protected from spambots. You need JavaScript enabled to view it. . Please include the information you would like and the format you would like it in.
Any application that directly affects someone within the legally set distance will trigger a neighbour notification letter and there are already processes in place to make reasonable adjustments to make sure people find out the information they need to know.
The planning team is currently suffering from staff shortages due to national issues in the sector as well as an increase in workload post pandemic which has led to delays in validating and dealing with planning applications.
Taking 4.5 hours of officer time each week, for very little benefit to people with accessibility issues, cannot be justified at this time and would affect the wider performance of the service. We believe the public, including people with accessibility issues, are better served by officers spending their time dealing with planning applications that come in.
We believe based on the assessment above that making the weekly planning lists fully accessible would be a disproportionate burden on the council given the impact it would have on delivering a critical, and legally required, council function with minimal benefit to disabled users.
This disproportionate burden assessment was prepared on 4 February 2022 and will be reviewed before 4 February 2023.
Licensing forms
We are responsible for licensing a range of functions. These require the submission of various forms. The format and content of these forms are prescribed by law. The majority of them are not currently in an accessible format.
Many of the forms would also be of little benefit to people with a disability that resulted in an accessible issue, for example applying for a taxi driver licence.
We investigated the potential for our web team developing accessible version of these forms. It was estimated it would take 12 months of development time. The development team consists of just two people. Taking this amount of time to develop accessible forms that would be of little benefit to the end user would cause significant issues with other areas of the ICT team’s working, including in the critical area of improving cyber security.
A quote was sought for having these forms developed out of house but the cost was estimated to be £170,000.
If anyone found they needed to apply for a particular licence and was unable to fill the form in on the website, our customer service team is available to help fill the form in for the customer over the phone or in-person if they visit our reception.
They can do this by calling our customer service team on 01684 862413 or visit us our reception at the Council House, Avenue Road, Malvern, WR14 3AF.
For these reasons, we believe making these forms would be a disproportionate burden on the organisation.
As part of our accessible document project we will review this position and consider if some of the easier to convert forms could be developed over time.
This disproportionate burden assessment will be reviewed by 31 March 2023.
Agendas, minutes and reports
Modern.gov is the third party software we use to manage our Council agendas, minutes, reports and other committee papers.
There are approximately more than 600 documents on our modern.gov system which were published after 23 September 2018 and are not fully accessible. The documents do read in a logical order but do not have the full functionality someone using screen reading software would require.
There are also minutes of decisions taken, and the agenda itself, published in HTML on the system which would be accessible.
The Member Support team consists of just 2 people and it is a busy section with 45 members to support.
It is estimated converting one document could take up to 20 minutes, depending on the number of documents and accessibility issues to be resolved.
If an average agenda contains 8 items then it could take more than two hours to convert and republish one agenda. Having to do this 71 times to cover all meetings between 23 September 2018 and end of February 2022 would require officer time in excess of 280 hours.
If anyone requires access to information from this period then they can contact Democratic Services on 01684 862416, who will be happy to make the information accessible on request.
A new accessible template has now been issued to officers and all committee reports and agendas should be fully accessible from 1 March 2022.
Given there is very limited benefit to retrospectively converting these documents and the amount of time required to carry out the task, we consider this to be a disproportionate burden under the regulations.
Return to the Malvern Hills District Council accessibility statement.
