HR, finance and purchasing system replacement: equality impact assessment

6. Actions taken to drive accessibility

Part 1 - The ‘off the shelf’ system may require adaptations to meet accessibility standards and this may create barriers for users

Scottish Government, as a public body, must comply with the Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018. This requires all IT systems and websites to be “perceivable, operable, understandable and robust”, and to be accessible at launch.

These Regulations require Scottish Government to meet Web Content Accessibility Guidelines (WCAG version 2.1) and to publish an Accessibility Statement which sets out all areas where the system does not meet WCAG 2.1, and what steps are being take to remedy this. Please note that at the time of procurement the WCAG Guidelines were at level 2.1. They are currently at 2.2.

The vendor stated that they meet WCAG 2.1 apart from known areas set out in a number of VPATs (Voluntary Product Accessibility Templates) relating to all the components of the system. An initial assessment of the accessibility of a small part of the system was done by Digital Accessibility colleagues in September 2022, prior to any application configuration being completed. This highlighted a number of accessibility issues. Digital Accessibility specialist colleagues have advised that there is unlikely to be a product of this type on the market which would be fully accessible. All bidders were scored on accessibility during the procurement exercise.

To ensure that issues were identified and remedies developed, a specialist Accessibility Workstream was set up in the Shared Services Programme. This workstream was focused on:

• understanding where there are accessibility concerns with the system and how this will impact users.
• working with the vendor and third party suppliers make on-system changes to improve the experience for users.
• putting in place the right guidance and support so that everyone can use the system.

The Accessibility Workstream has brought together technical accessibility specialists with knowledge of WCAG accessibility regulations, user researchers and content and service design professionals.

The Accessibility Workstream have audited and tested a range of prioritised HR, Finance and recruitment processes. This has identified a range of product-level accessibility issues. Of these, some are known bugs, already covered in product documentation, and some are new bugs that are now with development teams for resolution. Work has taken place to improve accessibility through configuration choices.

Cloud software means that product improvements are delivered through quarterly releases. This means that the biggest improvements to user experience, including accessibility, will come from regular updates . A number of issues that have already been fixed in releases or are due for release in the coming 6-months. This will include the introduction of an improved user interface which will resolve a number of known issues that have created barriers for users in testing. The barriers identified are most experienced by assistive technology users, particularly screen-reader users. Therefore, focus has been on reducing barriers for these users through on-system improvements and off-system guidance and support.

Part 2 - All issues identified will not be resolved on system ahead of launch

Given this is a complex multi-functional SaaS product used by large organisations world-wide, it is challenging for any one entity to address individual issues. SG accessibility specialists are engaging with suppliers on an on-going basis. We will continue to explore routes to influence, such as combining with wider civil service user organisations, particularly so that quarterly releases deliver improvements to user experience, including accessibility.

Part 3 - Standards for accessibility have changed between the time of procurement, and the date of launch

Work on accessibility is part of continuous improvement as standards and user needs are evolving. For example, improvements to the accessibility of the system to comply with updates to WCAG guidelines (WCAG 2.2).

An approach is being developed to ensure that new accessibility issues are not introduced through updates. The DG Corporate support functions will run regressions tests to check the impact of upgrades, once the programme has closed. Accessibility specialist resources will be included in these processes.

The procurement Accessibility EQIA stated that SG SSP procured in line with SG standards by completing an “Equality Impact Assessment Not Required Declaration Form” with the recommendation “that a full Equalities Impact Assessment is not required as the new procurement exercise does not impact on the protected groups in the community’’. The Crown Commercial Services – Back Office Software Contract has built in measures, via the tender to the processes and contractual conditions relating to the Equalities Act 2010 to ensure suppliers demonstrate and confirm their compliance with the Act. Post award, as part of our supplier and contract management, we shall monitor the successful contractor’s continual compliance with the Act and commitment to continuous product development.

Part 4 - It may not be possible to reconfigure the system to remedy/mitigate issues

SG Accessibility Specialists have worked to understand what parts of the system are configurable. This involved understanding WCAG standards and how configuration options could be made to improve the experience for users. An example of an improvement that was possible through configuration is employing the SG Design System to improve scalability and colour contrast.

Changes were made, where possible. Opportunities were limited, however, as parts of the system are ‘hard coded’ meaning that elements like content in the interface was not possible to change for the most part. This impacts users who rely on text content to navigate the system to complete tasks.

Part 5 - Sufficient resource will be dedicated to end to end service improvements to improve the accessibility of the corporate experience

For the first time across our corporate systems, the Accessibility Workstream has built a specialist team including user researchers, accessibility specialists and service and content design specialists. The Accessibility Workstream have taken a user-centred approach to this work. They have worked with a diverse group of over 100 volunteers from Scottish Government and customer organisations. Users have been involved in over 85 testing sessions where they have tried out using the system, including with the various assistive technologies available on SCOTS.

Users have also worked with the Accessibility workstream to co-design guidance and support that would help them get up to speed with a new system. Guidance and demo videos will be available to support assistive technology users to navigate the system and complete core tasks. This will cover:

• JAWS screen reader
• Dragon Pro
• ZoomText
• Keyboard navigation
• High Contrast users

Guidance will be supported by a series of 'Masterclasses' to offer in person sessions. These will cover getting started and pointers to complete common tasks.

There are multiple factors that interact to provide an accessible experience, as well as product and system configuration. This also includes:

• provision of up to date assistive technology.
• user proficiency in using assistive technology.
• Third party software
• Inclusive and accessible end-to-end service design

The Accessibility Workstream has worked to understand the experience of staff, more broadly, including off-system parts. This work has identified elements that require improvement, beyond the system. This includes:

• Work to ensure that assistive technology users are upgraded to the latest versions of technology available on the Scots network.
• Procurement of an assistive technology training provider to support colleagues to develop their skills.
• Improvements to the support model to provide on-going support to users who experience barriers using the HR, Finance and Purchasing system.

Part 6 – There are known issues within the system

The review undertaken by Digital colleagues on a small part of the system in September 2022 initially highlighted 24 issues. The experience of other government departments in a similar implementation was that they had to produce specific guidance for Assistive Technology users.

Since September 2023, a robust approach to auditing and user testing has been completed on a series of priority journeys:

• HR (flexi, leave, payslip, inputting diversity and inclusion information, on-system learning)
• Finance (purchasing and invoicing)
• Recruitment (hiring manager and applicant).

From this, a range of common issues were found. These have been triaged to identify those that are likely to create issues for users completing tasks. From this, the Accessibility Workstream have worked to put in place appropriate mitigations and support to provide the best possible experience for users.

Part 7 - Accessibility auditing

This is a large and complex system and conducting a full accessibility audit would not have been possible in the given timeframes nor desirable. Lessons were learned from the approach taken by UK Civil Service counterparts who recommended that focusing on a ‘defect-only’ approach would not result in reducing barriers nor a better experience for Scottish Government users.

Instead, the Accessibility Workstream focused on understanding the issues on a range of priority processes and identifying where there are product-level issues that create barriers across journeys. Digital Accessibility specialists have been embedded in the programme to support this work and a proactive approach was taken to identifying and co-designing appropriate mitigations with users. The Accessibility Workstream have worked with users to develop effective guidance, a series of Masterclasses will support users to transition to the new system and enhancements to the support model will be in place to support users who encounter issues. The Accessibility Workstream have also focused on understanding the product roadmap so that we are able to understand and communicate where improvements to user experience are in the pipeline.

Part 8 - Sufficient resource will be required for the Accessibility workstream

The Shared Services Programme was reset in January 2023. A new horizontal workstream was added – the Accessibility workstream - tasked with ensuring the system is as accessible as possible. The work should be appropriately resourced in order to fulfil its remit. A new Workstream Lead began work in August 2023 and has built a multidisciplinary team to deliver on this objective, including:

• User research capability to conduct research and testing in house.
• Accessibility specialist resource to conduct manual testing, auditing and solution design with suppliers.
• Service design resource to look at the end to end experience for staff who may experience barriers using HR, Finance and Purchasing systems.

Some of these resources will be in place to provide enhanced support to users in the months following launch. Work is ongoing to support users in a more sustainable way.

Part 9 - Training and guidance

A training workstream has been in place on the Shared Services Programme. To give everybody an opportunity to prepare ahead of using the new system, there is a comprehensive range of training resources available, as well as new on-system support. New functionality is delivered through the system to help users to complete more complex tasks themselves.

The Accessibility Workstream have taken a co-design approach to developing supplementary guidance and support for users who might experience barriers to using HR, Finance and Purchasing systems. This has involved working directly with users to develop content that works. The accessibility workstream have developed accessible guidance for assistive technology users who require specific knowledge to use the system. Guidance documents to support assistive technology users to navigate and complete core tasks. This will cover:

• JAWS screen reader users
• Dragon Pro users
• ZoomText users
• Keyboard navigation users
• High Contrast users

This will be available ahead of launch. A communications plan is in place to ensure that users can access the training and guidance that they need.

Guidance will be supported by a series of 'Masterclasses' led by Accessibility Specialists in September and October. These will cover getting started and pointers to complete common tasks.

An Accessibility Statement will be made available.

Part 10 - Testing, by people with particular accessibility needs, to help us understand the system, issues and remedies

We invited many colleagues with disabilities and neurodiversity into testing, to help us get first hand experience / feedback from those users. This was a very helpful set of tests.

The Accessibility Workstream has completed over 130 hours of testing with users, this has captured accessibility issues, usability issues and bugs. We focussed on accessibility, rather than useability, as we have very little control over the overall usability of the application, as a software as a service product. With this level of testing, it is unlikely that new issues would be raised through specific usability testing. For example, many of the issues identified, e.g. around system content, would impact in the experience for all users.

The scope of testing for recruitment was broader than that undertaken with internal users. This is to reflect the diversity of external users. For example, around device, assistive technology and digital confidence.

Where the scope of testing being more narrowly focused on accessibility could create issues is in untested touchpoints for users, such as system-generated emails or specialist tasks. This has been added to the backlog for continuous improvement.

Part 11 – Our ability to collect diversity data

The collection and reporting of diversity data is vital to meet statutory obligation and corporate commitments. No diversity data will be transferred from the outgoing systems. The completion of this data by colleagues, at launch, is therefore critical. SG had more complex and detailed requirements for its diversity questions than those used in the standard product and so had to utilise a different form functionality. The unanticipated technical limitations of this means that most of the questions and answers had to be modified or simplified in some way. This has the following implications:

• SG are committed to the principle of harmonisation of diversity questions and encouraging data collectors across the public sector to follow the SG approach.
• There may be discontent from staff who will be unhappy that wording has changed and that a question on disability has had to be omitted.

Members of Analytical Services team and the D+I team have been engaging with the staff diversity networks to reassure them that the changed wording of questions will not affect how the data is used, and to encourage all colleagues to complete the data form.

Part 12 - There are a large number of critical “documents” generated by the system which must be made accessible.

On 20th September 2023, SSP Joint Business Design Authority approved Option 2 of SSP Accessibility Documents. Option 2: Prioritised approach to implementing Accessible Document Guidance for go live

• Triage circa 150 documents
• Prioritise documents by volume/criticality
• Identify documents required to be in place for Day 1
• Establish prioritised accessible document backlog to be implemented pre (April 24) and post go live (post May 24)

The following documents have been built using Accessible Document Guidance:

• HR Letters
• Finance custom Excel reports
• Offer Letters and Recruitment Custom Reports

Part 13 - Disabled colleagues might have a poor experience of the change because of the volume of tasks to complete and information to consume

The Accessibility Workstream have carried out research and testing with a diverse group of colleagues, including neurodiverse colleagues and assistive technology users. One of the main insights has been concern about experiencing change negatively. In particular, feeling pressure from line management and unrealistic timescales to get up to speed with the new system. For assistive technology users, there may be additional time needed to understand how to use a new system with their assistive technology. One user described this as being on two learning curves at once. It is essential that the culture around this change is inclusive, giving time and space to adopt the change.

To support users with this, the Shared Services Programme have developed simple, clear and concise content to:

• Support end-users to navigate the tasks they need to complete and learning and support available.
• Give practical pointers to leadership and line management to help their staff have a better change experience.