Document type
Making HR documents accessible
Job adverts, application packs, offer letters, contracts, handbooks and policies: why HR PDFs fail accessibility, the duties behind them, and the fixes.
HR documents are produced in two ways, and each fails differently. Offer letters, contracts of employment and change letters are merged from an HR or recruitment system into a template, so one defect in the template repeats in every letter sent. Handbooks, policies and application packs are long documents edited by many people over years, pasted between versions until their structure is gone. They reach two groups the law protects: people applying for a job and people already employed. In the EU, Council Directive 2000/78/EC applies to public and private employers in relation to conditions for access to employment, including selection criteria and recruitment conditions, and to employment and working conditions. Article 5 requires reasonable accommodation: employers must take appropriate measures, where needed in a particular case, to enable a person with a disability to have access to, participate in or advance in employment, or to undergo training, unless the measures would impose a disproportionate burden. National employment equality laws give the Directive effect. In Great Britain, section 39(5) of the Equality Act 2010 applies the duty to make reasonable adjustments to employers, and Schedule 8 says it is owed to applicants for employment and to employees. Section 20(6) says that where the duty concerns the provision of information, the steps can include making sure it is provided in an accessible format. The duty is tied to a particular person, and Schedule 8 says it does not arise where the employer does not know, and could not reasonably be expected to know, about the disability; an application pack or handbook that is already accessible means a request can be met at once, not converted under the pressure of a closing date. Normfluss checks each 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, with documents processed in the EU. The record documents conformance within a stated scope; whether an employer meets its legal duties is for the employer and its advisors to decide.
Where HR documents typically fail accessibility
- Application forms are fillable PDFs whose fields have no names or labels, tick boxes that announce only 'check box', and a tab order that jumps around the page, so an applicant using a screen reader cannot tell which answer goes where.
- Some application packs are a scanned form to print, fill in by hand and return, which leaves an applicant who cannot read or write on paper without a way to complete it independently.
- Job adverts and person specifications set out essential and desirable criteria in a two column grid of positioned text, so each criterion is read without the column heading that says whether it is essential.
- Offer letters generated from an HR system put the start date, salary and conditions in a letterhead area or a floating text box, so the reading order reaches them after the footer or skips them.
- Contracts of employment and staff handbooks number their clauses by hand and style headings as bold text, so there is no outline to navigate a sixty page handbook and no way to jump to the sickness absence or grievance section.
- Pay scales, holiday entitlement tables and benefit summaries have no header cells, so a figure is read without the grade or length of service it applies to.
- Organisation charts and process diagrams in policies are single images with no text alternative, so who reports to whom, and the steps of a grievance or disciplinary procedure, are simply missing for a reader who cannot see them.
Remediation checklist
- Fix the letter and contract templates in the HR or recruitment system, so every offer letter and contract produced from them starts out tagged.
- Give every form field a label and an accessible name, group related tick boxes, and set a tab order that follows the form (WCAG 3.3.2 and 4.1.2).
- Offer a form that can be completed on screen in place of a scanned paper form, and OCR any scanned document that must stay in use.
- Tag criteria tables, pay scales and entitlement tables with header cells, so each figure or criterion is announced with its row and column.
- Apply real headings and bookmarks to handbooks, policies and contracts, and encode clause numbering as nested lists so a reader can move by section.
- Set a logical reading order in letters that puts the offer, start date and conditions before reference numbers and footers.
- Describe organisation charts and procedure diagrams in text, either as alternative text or as a list in the document, and set the document title and language.
- Check each file against PDF/UA-1 and the WCAG AA success criteria that apply to PDF before it is published or sent, and keep the signed record alongside the template or policy version it covers.