Shaun  Conner 

So you're compliant; now what?

Congratulations! You've achieved accessibility compliance, a crucial first step. But what about the forest beyond the compliance trees? This talk dives deeper, exploring the limitations of solely focusing on checklists and advocating for a shift towards proper inclusive design.

We'll uncover hidden gaps in accessibility that compliance often misses and discuss actionable strategies to bridge the gap between compliance and true inclusion. Join me as we explore how to move beyond the "check-the-box" mentality and build experiences that truly work for everyone.

Hi, everyone. So, yes, my name is Shaun, I'm a digital accessibility worker and I currently work at Government Digital Service where I work on the gov.uk one log‑in programme. The image on the deck is myself, my wife, my little boy and little girl. That's my crew. And this is Daisy.


So I've been really fortunate throughout any career to lead on accessibility, at some cool places. I'm particularly proud of my CV. But I always feel like an impostor which is weird, having good job titles at places like these. So my job is about reminding people that disability is not just part of somebody else's story, it's a chapter in your story, if you are lucky enough to live a long life.


So what we are going to talk about today is accessibility compliance, a little bit about how we begin to shift left and then a bit of some of what I think beyond compliance would look like. My mother is here today, so I'm going to go into keeping this very high level so she understands, and one of the instructions on number 3 there is, even if this is a bit, just give us a clap at the end so my mam can hear it! To be honest, I'm a bit worried. The number of people applying for visibility jobs has gone through the roof, which is really good news, as somebody who leads Accessibility Teams. Recently at GDS, we had a recruitment for a senior accessibility specialist, we got a shit tonne of applications, high‑quality. But there's a problem. It's a problem because, applicants are forgetting about what's important. And that is people. Only two applicants from nearly 60 actually mentioned user‑focus on what the impact of their work does. It was very heavily focused around tactical compliance and work harder and this, and complying to this and working with the developer and doing this... in fact, very few people mentioned disabled people at all which I couldn't quite wrap my head around. I'm thinking,  we have got all of this interesting accessibility, surely people aren't forgetting about disabled people in all of this. The interviews were really difficult. They were hard, because technical compliance was just front and centre of everybody's approach to the work that they were doing. This is understandable, because a lot of accessibility or a lot of people in the profession currently, are either recovering developers who then move on to become accessibility people, so we sort of have the lens of right, okay, well we are going to focus on the technical stuff. And that creates a barrier, because other people who might not necessarily be technical think they can't apply for the jobs because they don't have the technical information and it creates a bit of a scenario where people just don't apply in the first instance. We have a profession full of ex‑developers or current developers, and it's not very good.


When we think in this way, it concerns me and I think the best way of describing it is that we are starting not to be able to see the forest for the trees, we are focused on literally the compliance thing and forgetting everything else. The screen is a black circle, and it says web content accessibility guidelines or WCAG, and this is what I think a lot of people think accessibility is. In reality, WCAG is the dot in the middle and the green bit is the bit that gets me out of bed in the morning, all the stuff we don't know and the problems we haven't solved.


I would say, if you are applying for accessibility jobs, remember what got you interested in accessibility in the first place, remember what motivated you. Everyone's got a personal story, everybody knows somebody who is disabled, you might be disabled yourself. Never lose sight of that. Not for the sake of WCAG or technical compliance anyway. We do this, or at least I do, because I want to drive change, because I care about people, I want to make things work for people and give everybody a chance to complete what it is that we want them to do.


So yes, the result was, our thing was fully accessible. That was a lot of the conversations during these interviews. And that's not true. Sorry. The image description is a puppet looking left and looking forward. Nothing is fully accessible, it's just more accessible. We are always excluding somebody. And I think we have to get comfortable with that. Compliant doesn't always mean accessible and a lot of the problem, or a lot of the time the problem lies in job adverts themselves. If you have seen a job description for an accessible role, there's about 700 bullets where every possible thing about accessibility and then people look and think, I can't even do half of that! The technical WCAG developer side bit is the thing that I think puts the most people off. For me, we need more diversity of thought and experience in the profession. I'm aware that a lot of accessibility or a lot of places don't have the luxury of an Accessibility Team, so you might have a champions network, which is really good, but I wanted to talk specifically about an example of why with I think this is important, and if any of you are familiar with Laura Parker who is sat up there, Laura did, along with a few other people, some research and guidance around deciding numeracy for people with dyscalculia, and it was one of the top pages last year. If you sit ten developers in a room, they would still be arguing about the wording of WCAG and never would have got to the good guidance that ever with put out there. We are putting more guidance out there and people are desperate for it. The other thing I would like to touch on is, we can't blame the applicants when compliance is the strategy for a lot of places. With that said, I think we are becoming complacent with compliance. So for the sake of my mother, I'm going to talk about what we mean by compliant. So, when we talk about compliance, it's compliance to a law, so in the UK, it's specifically in the public sector, we have the public sector accessibility regulations which means we have to create services accessible to the WCAG standards to AA. We have the equality and accessibility things, a lot of things outside of the public sector as well.


So, I put these slides in because yesterday or the day before, WCAG turned 25. So I was 12 when the first verse came out. In that time, they've went from 1.0 to 2.2, which is not a lot of progress when you think about it. Between 2000 and 2018, is when they got to the next version, so it's slow. To those they think WCAG3, we'll all be retired when that comes out so let's not hedge our bets on ever seeing that!
probably a reason for that. A lot of the accessibility problems happen because of the HTML standard. The web is moving at an extraordinarily fast pace where enhancement is sometimes used when developers are that smart, but often not used at all. WCAG is broken down into three levels. A, AA and AAA. You encompass all of A if you meet AA. AAA is to be honest, ignored. And that's because it's not required. So, the unfortunate part about that is a lot of the cognitive accessibility guidance sits within AAA. So it just gets ignored. We can translate the guidelines into a lot of things like checklists or design things. Checklists can be handy, but accessibility is about more than checking lists. And I would also say the same about design systems, design systems are really good, but the people who use them aren't very good. So, the amount of times we have seen something where people misuse components, put components within components, start changing all of the code and break it, this off the shelf relatively accessible thing becomes a bit of an accessibility nightmare.


So there is no silver bullet and there will never be, no AI, nothing, we just don't know too much about it.


I'm aware that compliance can be mandatory, so we have to focus on it specifically in the public sector where I work. WCAG is definitely a useful resource and accessible teams tend to be small. When I joined GDS, I responded to us on‑boarding a in supplier. It was a lot to do with compliance and we didn't have the groundwork done so I understand teams having to officially focus on that but it shouldn't be the strategic goal only. WCAG definitely are not perfect. Far from it. You haven't lived until you've been in a meeting with some developers where they start arguing about the wording of coo WCAG. Marit used to be on my team at HMRC and I used to think to myself, end it! Because I would be in meetings with technical people arguing about, well, I interpret this to mean this and blah blah blah and mean while I'm sitting there thinking, does it really matter?! Probably not!


When we fail to look past the guidelines, we are sort of accepting that that's all there is, and I'm seeing that more and more. I spend a large amount of time outside work helping other people so I try to make myself available, I'm mentoring other people, hearing stories of different organisation, and they seem to be doing the same thing and making the same mistake, in my opinion. The thing with WCAG which I touched upon is that they are open to interpretation. So, I could look at something, and five others look at it and we'd come to different conclusions about what we think is accessible and what is not.


Often, again, we are not putting disabled people in front of the thing to use, we just go, well we think that it might be this, and then we hope that people don't complain.


WCAG also doesn't apply to all contexts. So, the service that I'm working on at the minute, sort of hands off, so you get half way down the web journey, hands off to a mobile thing, you come back from the mobile into the web journey. There are different contexts where WCAG doesn't apply to that specifically because it's the web accessibility guidelines and not mobile. I try to think of accessibility more as digital accessibility, so how do we apply some of the themes and concepts to other things.


The guidelines are ironically inaccessible. Something on Twitter like a year ago or something, and set a challenge to be like, everyday I'm going to read www.of the successful criteria and I sat there thinking, I couldn't think of anything more miserable than spending time reading through each of the criteria. It's soul‑destroying. They are written in technical language, not easy to read, it's a bit of an inaccessible nightmare. Of course, there's not a lot in there about cognitive accessibility. They also create a tick the box mentality, and from my experience, when people can't pin a WCAG on something, those often get coined as useability issues. I say this a lot. If follow with me on any of the socials,  this is something that comes out my mouth probably once a week. Things can be technically accessible, but not useable, and therefore not accessible at all. This is because the WCAG, you can't pin the WCAG thing on it so we put it on useability where it's possibly inaccessible.


When we settle for compliant, we are settling for the bare minimum. How do we begin to shift left, and that is something that is talked about a lot. I don't really here a lot of people talking a about what it is and how to do it. What is it? Basically, what tends to happen is, it's not considered, accessibility, so we have to fix the stuff, it goes through design, test, reaudit, design and retest and it goes through a cycle. We can't change. We got into bad habits because we are auditing, so when we say shift left, we want to move goalposts down here to project requirements and make sure that's fed in throughout. With that said, we can't influence change if we don't have a seat at the table. So wherever I've worked, when I first joined Monzo, if there was a meeting, I was in it. I had to be everywhere all the time to try to figure out, where can I get a seat at the important meetings and start to talk about this work.


Things that happen in the past. We have a thing at GDS called a digital review board and steering group. These are essentially meetings where we'll talk about ideas and that for me is where we can begin to think about accessibility. You can embed content, or design crits. At HMRC, we used to have mock service assessments, but I never got a seat at that table, that would have been an ideal opportunity to get in. And ceremonies as well. Be unapologetically optimistic about the work. Now, this can be very hard in this work. Burn‑out is rife, we are all trying really hard. For me, we just have to approach it with real optimism and try to empower people to make people realise, we can do this, not, here is a problem, you solve the problem, like we have to support the problem.
I'm talking about the type of militant optimism that can cause people to spontaneously combust and cringe into flames. I'm always overly optimistic, passionate about this stuff, I really enjoy my job, I'm one of those people who'll go in and constantly bleat on about this. I'm going to mention Laura again, I had a conversation with her and she said to me, and it stuck with us, am I being too much? If that is what you are asking, you are probably at about the right level of like optimism. Not a lot of people ‑ not a lot of people are going to care ability accessibility ‑ is what I am trying to get across here. It's a cartoon of one person head‑kicking another person. How we deal with people who don't care about accessibility. For me, it's something that I had to learn very quickly. We try to empower teams we don't police. When I joined GDS, when I asked to be part of meetings, people were like, what are you assessing, are you checking up on us. It was like, we are trying to collaborate to create more accessible experiences for people. And that's because people are used to being policed. So you have done this wrong, you need to fix it, we have become a headache for people. And we are not going to win every battle, so pick your BA les and fight fiercely for the ones worth fighting for. A quick example of this. At the minute, we are working with a chat supplier, it's been difficult. But getting that right has been extremely important. So that's been my hill to die on, like that thing is going to be much better than it is. It's figuring out which will have the most impact for the users. I say to people, start with the simple question, literally who might this be excluding? Whatever you are doing, the context of your work, ask the question, who might this be excluding?


This is Craig Abbott, I am sure you know him and his work, some of you. He done a brilliant article on accessibility strategy which I have used when I went to Monzo. I used these principles. It focuses on a culture of, you can succeed. What I found at Monzo when I was there, if you take care of culture and education, compliance tends to take care of itself. A key thing is that your strategy should be a reminder of all of the things that you shouldn't  be doing. There's a really bad habit within this profession that we take too much on, we say yes to everything, want to fix everything, and that just detracts from the work that you should be doing. My advice, if you have an accessibility strategy, make sure the things that you are doing are measurable, so if you are doing training, measure, let's say, I don't know, developers making the same mistake, do the training and measure that the failures are coming down. So, it's going to help with getting the additional buy‑in for more work going forward.


I wanted to turn on burn‑out. It's something that we see time and again. I've seen multiple podcast articles and I've been there myself. It's absolutely brutal, so just look after yourself in this work. Very quickly, I wanted to shine a light on the three pillars of Craig's strategy work. Things that you can do in the context of your own work to bring the strategy to life. For your culture, you could focus on accessibility clinics, lived experience, speakers, embedding the communities into practice, celebrating initiatives. Something that worked for me at Monzo was accessibility principles. So, we looked at things like the WCAG guidelines and universal guideline principles and how did those fit within the context of Monzo and what we were trying to do. That was a collaboration with senior designers and developers across‑the‑board, and they were really good. I can't stress enough the importance of role‑based training, not just random training for everybody. It's very important that we are teaching people within the context of their role. What it is they can do to make things more accessible. Assistive technology training, so give the developers the tools to test the things they are building. When I was at the NHS, I did that there. It started to create a culture where the developers were setting themselves a challenge to make stupid things work. It worked because it got the conversation going and improved things. Workshops and talks, as I briefly touched on, accessibility champions network can be a real force propellant for the work you are trying to do. Bring in all different kinds of experience and jobs and all of that stuff. And, you will see great benefit in that as well.


In terms of compliance, governance and assurance, a thing I'm looking at at the moment is non‑functional requirements, making sure they were build into all the JIRA tickets. Policy is one I focussed on on Monzo. Monzo's tagline or whatever was like make money work for everybody which is essentially a commitment in itself to accessibility. But, it didn't mean anything if we didn't have the policy to underpin the messages we were trying to send, so everything we did was focused on people. Also, creating support channels for people help as well. That is really important. Beyond compliance, if we change nothing, nothing changes. For me, it's about solving real problems for real users. I want to just talk a bit about when I was at Monzo. So I was a developer for many years at the NHS. I supported the NHS when the public sector accessibility regulations came in. That was a really responsive piece of work and a huge strategic piece. Then I moved to HMRC where I became an accessibility lead, so again it was all about compliance and I was just burned out from compliance, I was sick of it, I was thinking, this is not what this is about. So when I went to Monzo, it was an opportunity to take a step back from the compliance and look at the real problems. I didn't have to look far to start finding issues. When you zoom out and take the WCAG hat off, you go, there's an obvious problem, there's an obvious problem.

So for me, an example, and this is not to do with digital accessibility but just an inclusion thing, I would listen to loads of customer complaints, I was trying to build a picture of what are the problems and what customers are saying. Monzo tag all of their calls, so if you came through, and you were happy to log that you had a disability, it would get tagged so I could filter that and monitor the calls. Hearing so of the call centre staff talk to disabled people was enraging . But it wasn't their fault, because they had no training, they didn't know how to talk to disabled people. It was horrendous. That for me was a gap. 2,000 people got training. And that was, you know, beginning to solve that problem.

Another thing, anyone have a Monzo account? The cards, bright, coral I think they call it. White text. Contrast colour issues. A really bad badge trend in the industry now where they are taking away, embossing and all of that stuff, numberless cards, taking away the things that serve as accessibility features for people. So that was another issue. There was loads of different things. One particular example I want to talk about is a feature when you sign up for a Monzo account, you will hold your phone up and say, hi my name is Shaun and I want a Monzo account. And that's not very inclusive. So, I'm laughing at the note ‑ nudes in the shower ‑ so what we found, and of course in we are asking customers to hold the phone out we have non‑verbal customers, not everyone can hold the phone in front of their face. There is a host of inclusion issues in there. And also, we need to think about preferences as well. So, some people, like me, just don't like holding the phone up to our face and seeing my face. Now, I would love to say that this is my quote. But realistically, I went on Google Gemini and said, this is what I'm trying to say, make us a quote. Accessibility is the symphony of design where users need to harmonize the experience. What did we do to make this thing more inclusive? Actually, I need to talk about the problem a little bit more first. So, one of the issues that we found was that when we were asking customers to take a picture of themselves, a lot of people with visual impairments weren't in frame, they didn't know, we were getting shoulder shots, because they didn't know what they were taking a photo of, they would bounce the Monzo account, the customer gets notifications and there were complaints. That leads me into nudes on the shower. Amazing how many people sign up for a bank account in the shower! (Laughter)

And this also brought up an inclusion thing here as well. We were not telling people that a human could view the thing that they were saying or the video that they would send. And, you know, for religious reasons, like some people might wear head scarfs and, you know, we are asking people for a picture of their face and there was a host of problems there.


What we did do is, we changed it to say, sign or communicate how you usually would. So no need for somebody to say, hi my name is Shaun. It was to do with security but it wasn't less secure by people signing or writing down or communicating how they usually would. We produced sound and feedback when the person was in the frame. The thing turned green, pinged and set the thing off in your hand. We provided an alternative as well because we had a realness check that would strobe for users and we also told users, by the way, a human might be able to see this. So immediately, we get a reduction in all of those complaints and it's just better and more useable, not fully accessible, just more accessible. I want to talk quickly as well about the time that Uber introduced contactless delivery. For me, that was probably one of the best examples of accidental conclusion I've ever seen. So two weeks ago, I was diagnosed as autistic. I think the turning point for the assessor was when I said, I got in touch with Uber about a complaint that the drivers weren't respecting contactless delivery because I don't want to have to deal with people when I get my food. Leave it, pick it up. They didn't realise it but it's solving a problem for a whole bunch of people. It's not just for me that prefer not to talk to people. It's also for people who have 17 meetings that day, can't be arsed, leave the foot, see you later! Bad assumptions equals disabled users. This is really important, because we talk about the medical model and the social model of disability, and we all say yes, the social model of disability, but when we talk about accessibility, we revert back to the model of thinking and it's the things we make in the assumptions we make, that disable our users. I love this quote by Gareth Ford‑Williams. Better data leads you to better assumptions, which in turn leads to better outcomes. Hayden Pickering, design for the tools, not what you think you know about the users. I think this is a really important distinction to make. Like we can just make it technically work, we don't know how people use the tools, so like, another example of something that we were going on with the chat solution, they said it technically works, then they give us a list of instructions, that were like 100 pages long, go to 270 page of Google, scroll through and da‑da‑da, and it was not technically working, make its work and let the user choose how they use the assistive tech.


Not all assistive tech users are disabled and not all disabled people use assistive tech. I read some stats last night and it was about captions, Facebook saying 80% of people are using captions. This is really important for accessibility, because what we need to do is distinguish between user needs, so people who need to use the technology and people who prefer to use the technology. People these days are using the accessibility features without realising that they are using accessibility features. So if you ‑ you wouldn't look at the data and say 80% of the people use captions, therefore all of those people are blind.


I wanted to sort of start wrapping up by saying we did some user segmentation research recently, there will be a blog about this and keep an eye on this because it's absolutely fascinating. This research was, I think 2‑3,000 people, can't remember the exact numbers, but the research we did changed our perception on everything. We were wrong on so many fronts, it was unbelievable. I want to call out one key thing here, it was that 16% of users reported using assistive technology. Which is significantly higher. Usually if we are talking about screen readers or if we were to measure it from Monzo, for example, it would say like, half a percent of people use screen readers. This number is significant. It's not because there are more disabled people, it might be actually, we don't know, but it's because children are coming through school now with all of the reasonable adjustments and what I want to point out as well is, a lot of the huge proportion of this data, it was kids and young adults. So they are coming out of school having all the reasonable adjustments and they are expected to be able to use all of the new tech essentially. We need to join up the data. I focussed on complaints, social media, research, call centre and analytics, there's so much quantitative research and we can begin to pull out people's needs and preferences and I think it's important that as much as this is about accessibility, it's like of course, making things work on assistive technology, especially for disabled people, but we are now, there's a lot of people using these features and functions as preferences as well. So we need to measure that. I think the we widen the lens by doing that, rather than we say, we are focusing on blind users, if we just say we focus on people who can't see very well, which is 75% of people wear glasses, we get better outcomes when we begin to think that way as well. Interesting thing from Monzo is that, they were capturing all sorts of metrics that you shouldn't  capture. But one of them was about dynamic type, which is the font scalability. And over 30% of Monzo customers had that scaled up by at least two sizes. That begs the question, if 30% of the users do that, design it not to be as frigging small! It should go without saying, we need a co‑design researchability test. There's not enough of it going on, point blank. Research within the context of the product service, I like to talk about HMRC with this, because what I found, the researchers would give all this data every month, like we have researched with 700 people, and then they would say, then we have researched with four assistive tech users or disabled people. I would say, well, hang on, just, if you researched 700 people, at least 25% of those people are going to be not asking the right questions for. Rather than just focus on Screen Reader user, focus on people who might be dyslexic or struggle reading numbers. It's a service that's heavily policied. Those are the users that you need to go and research with in the context of that service. You get much better outcomes, if you just think about it, who might we be excluding, go for those people. Use WCAG as a sprint board. This is really important. We need to not let WCAG define the whole approach. It's the floor, not the ceiling, of accessibility, it's very, very important that we begin to look past it. And I just want to finish up by saying that, whenever there seems to be like a, you know, we are looking, people are looking for perfect solutions and perfectly accessible WCAG, there was an article that a colleague Richard Moreton, the head of accessibility at the Cabinet Office shared, and he said, look, this service have got nothing on their accessibility statement, and then all of the accessibility people went, we'll go and find a problem. So, this is about progress, not perfection. I speak to a lot of people. People are trying hard. But I think we need to shift the focus from audit, test, audit, test, into just thinking more broadly and accept it for what it is, where nobody is expecting anything to be perfect. So just focus on progress over perfection. I want to end with a quote by somebody who is very important to me and she's sat right in front of us. Thank you very much. (Applause)