Renfrewshire Council, like all public sector bodies, should not use PDFs or office documents to communicate information on the web, except in a few very limited circumstances, as doing so is unlawful and degrades the user experience.
Web accessibility is the practice of making sure that everyone can interact with our digital services and their content without needing to adapt them, while supporting those who do need to adapt them.
This means removing accessibility barriers so that they can be used by people with a wide range of different abilities, including those who have:
- permanent or temporary disabilities such as visual, hearing, motor, or cognitive impairments
- situational circumstances such as being a new parent or in a noisy environment
- socio-economic disadvantage or restrictions such as limited digital skills, low bandwidth connections, or old technologies.
Not only is web accessibility essential to improve the usability for everyone, but not offering an accessible digital service means we could be breaking the law.
Digital services include:
- Virtual Learning Environments (VLE)
- mobile apps
- any software which uses the web browser as the interface.
Renfrewshire Council, like all public sector bodies, is required by law to make the content published on our digital services accessible, including PDFs and office documents such as Microsoft (MS) Office Excel or Word files.
This means following the accessibility requirements and making sure that all content is:
- perceivable – people must be able to perceive the content, by seeing it, hearing it, or another method
- operable – people must be able to find and use the content, regardless of how they choose to access it (for example, using a keyboard or voice commands)
- understandable – people must be able to understand the content and how the digital service works
- robust – the digital service and its content can be interpreted reliably by a wide range of technologies including reasonably outdated, current and anticipated browsers and assistive technologies.
This is required under two main pieces of legislation:
- The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018
- The Equality Act 2010.
These rules apply equally to content which is:
- restricted to certain users
- internal only.
PDFs (short for Portable Document Format) and office documents serve a purpose where something needs to be printed out such as a leaflet, stored on record like regulations or minutes, or referred to when the information is too complex or detailed for a web page, such as a map or detailed financial report.
These documents are incredibly popular because any of our colleagues with a council device can create them. Unfortunately, PDFs and office documents are meant for printed materials, and when published on the web they create major accessibility and usability problems.
Common accessibility problems
Almost all PDFs and office documents published on the web will create accessibility barriers, making it difficult or impossible for people to perceive, understand, navigate, and interact with the content from these documents. For example, they:
- don’t work well with assistive technologies such as screen readers, which people with disabilities often use to navigate and read web content
- often have problems with zoom, scroll, audio, image and keyboard navigation, especially on mobile devices
- lack structured data such as the use of proper headings and hierarchy, which means people with a visual impairment may not be able to navigate and orientate themselves
- don’t include ‘alt text’ for images – alt text provides a necessary alternative way to convey the information provided by the image to people who cannot necessarily see the image
- don’t allow people to change the colour, contrast, or size of the text.
It is possible to create PDFs which meet the accessibility standards, and these are called PDF/UA files, where UA stands for Universal Accessibility. However, it is technically challenging and time consuming to create accessible PDFs and office documents, and most accessibility issues can’t be addressed.
Consequently, they are unlawful as they violate the accessibility regulations and Equality Act 2010 which we are legally required to comply with.
Common usability problems
On top of being unlawful, inaccessible PDFs and office documents published on the web degrade the user experience. They make our content harder to find, use and maintain on the web. The Nielsen Norman Group, world leaders in user experience, strongly advise to never use a PDF or office document to display content that users need to read online because:
- not all users have the right software on their device to open PDFs and office documents
- they are difficult to load for users with slow internet connections
- they can be large files and take space on a user’s device
- they take users away from the website, opening in a new tab, window or software
- they lack navigation and other interface elements that help users maintain context and move through digital content with speed and ease
- they rank lower than web pages on search engines
- they are more likely to remain online once they’re out of date, which cause serious issues when people read outdated or incorrect information
- it’s difficult to collect data on how people use them, and that makes it difficult to identify problems and improve them.
Moving away from publishing PDFs and office documents on the web is challenging. It means a fundamental shift in how we communicate with our local communities or colleagues, especially when publishing lengthy publications and legal information.
The main format is to publish most content as web pages, also called HTML copy. The content you’re reading right now is in this format. Web pages are better because:
- if developed correctly, they comply with the accessibility regulations and Equality Act 2010
- they can be read by assistive technologies used for web browsing such as screen reader and magnification software
- they are easier to navigate and can automatically link to related web pages
- their content is in one place, which means our users don’t need to download a separate application to read something
- they are easier to use on mobile devices
- they are quicker and easier to update and remove.
In most cases, you will need to publish the content from your PDFs or office documents as web pages on our digital services, when of course there is a need to publish this content online.
In some case, your content might not belong to any digital services at all. We’re legally required to make certain information available, but that doesn’t mean they have to be published on the web.
And in rare cases, we might publish PDFs and office documents on the web, only when it’s appropriate.
Sometimes, you may need to create documents for your project or service for print distribution. But if you want this information to go on one of the council digital services like Renfrewshire.gov.uk, it most likely needs to be as a web page.
However, there are a few exceptions when publishing an accessible PDF or office document on the web might be appropriate. These exceptions include:
- documents which must be published on the web in a specific document format like PDF, Excel, or Word, as explicitly stated in a statutory requirement
- forms that someone needs to print out and fill in – these forms should also have an online form option
- complex structured data documents, like financial information in a PDF, Excel spreadsheet or CSV file – a short list of entities like contacts or council schools doesn’t constitute complex structured data
- technical detailed documents unlikely to change, like an architectural drawing or complex housing sites data – legal information or a flowchart often doesn’t constitute technical information
- maps that are not used for navigational purposes, like for highlighting boundaries or physical features
- leaflets, posters, and signage for users to print out and use.
In these exceptions, you must still consider accessibility and usability, and this usually means:
- making reasonable adjustments to the PDF and office document published on the web to ensure it meets the accessibility requirements as much as possible
- making the content within the PDF or office document available in a web page format.
Step-by-step guide to when you can and cannot publish PDFs and office documents on the web
You can use this step-by-step guide when you can and cannot publish PDFs or office documents on the web. It follows four simple steps and asks a series of questions.
There are many PDFs and office documents which have already been published on our digital services.
If they are part of the list of exceptions, this is acceptable.
If there aren’t, the accessibility regulations under the Equality Act 2010 are very specific. Your content will need to be accessible depending on:
- its type
- where it was published
- when it was published
- if it’s about to receive a major revision
- if it is used for active administrative processes.
The “active administrative process” stipulation isn’t defined or explained in the regulations, so the cautious, good practice approach is to ensure that the content from any PDFs or office documents that people need to use for a service is converted to an accessible format.
For example, content from old documents that people need to get informed with current information, follow a process, or complete a task such as guidance, policies, strategies, user manuals, plans, procedures, or forms do qualify as active administrative processes and must be accessible.
PDFs and office documents published on an external website
“External website” means a website that is available to the public.
If your document published on an external council website:
- isn’t an exception; and
- is the current version for an active process; or
- was created after 23 September 2018, or
- requires to be updated once or more
then it must, by law, be made accessible and converted to a web page format.
PDFs and office documents published on an extranet, intranet, or Virtual Learning Environment (VLE)
“Extranet, intranet, or Virtual Learning Environment (VLE)” means a website that is only available for a closed group of people and not to the public.
If your document published on a council extranet, intranet, or Virtual Learning Environment (VLE):
- isn’t an exception; and
- receives any major revision after 23 September 2019; or
- was created after 23 September 2019
then it must, by law, be made accessible and converted to a web page format.
If you’re concerned about how your service will adapt without relying on PDFs or office documents, or you would like digital advice on an upcoming project, get in touch using our online request form. This is where you can request any support from the Digital Experience team, including updating existing web pages, creating new pages, and ensuring your content and campaigns comply with the accessibility regulations and Equality Act 2010.
You can also find more accessibility guidance on The Thread: