NormflussDocument accessibility platform

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Document accessibility for healthcare

In England, the Accessible Information Standard (DAPB1605, previously DCB1605) is issued under section 250 of the Health and Social Care Act 2012. All providers and commissioners of NHS and publicly funded adult social care must have regard to it, including NHS trusts, integrated care boards, general practice, community pharmacy, dental and optometry services, independent providers of NHS funded services and providers of public health services. It covers patients, service users, and carers and family members involved in their care, who have information or communication needs relating to a disability, impairment or sensory loss.

The standard asks organisations to identify, record, flag, share, meet and review those needs. Meeting them includes providing information in formats other than standard print, such as braille, large print, email and audio. Two requirements bear directly on generated documents: where systems produce correspondence automatically, they must recognise a recorded need and generate an alternative format or let staff generate one, and a standard print letter must not be sent to someone for whom it is not accessible. The standard points to section 20(6) of the Equality Act 2010, under which reasonable adjustments include providing information in an accessible format. It excludes corporate communications such as annual reports and board papers, and communications with staff.

Websites are a separate strand. NHS England's own requirements note that the Public Sector Bodies Accessibility Regulations 2018 cover health and social care websites. In the EU, where a hospital or health service is a public sector body within the definition in the Web Accessibility Directive (EU) 2016/2102, its websites and the documents published through them come under the national law transposing that Directive. Healthcare is not one of the service categories listed in Article 2(2) of the European Accessibility Act, although a provider that sells to consumers online can fall within its category for online sales.

An accessible electronic letter or leaflet is one way to meet a need for information a screen reader user can read; it does not replace braille or communication support where that is what the person needs. Normfluss handles the document side: it checks a PDF against PDF/UA-1 and the WCAG AA success criteria that apply to PDF, remediates it, and issues a signed evidence record stating which checks ran and what they found. Documents are processed in the EU. The record documents conformance within a stated scope; it is not an assessment against the Accessible Information Standard, and whether an organisation meets its legal duties is for the organisation and its advisors to decide.

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