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Statutory obligations

Statutory obligations

Below, we answer questions you may have along the way in implementing digital accessibility on websites and mobile applications. If you have further questions on this matter, we encourage you to contact us individually.

What is an accessibility statement?

‘An accessibility statement is a description of the accessibility of a public entity for persons with disabilities. It informs them about the solutions, but also about the problems they will encounter on the website, mobile application and buildings of the public entity in question.’ Source: www.gov.pl – How to prepare an accessibility statement.

Is an accessibility statement good practice or is it mandatory? What legal act regulates it?

As of 23 September 2020, such a statement is mandatory for any website and as of 23 June 2021 for any mobile application that belongs to a public body. This obligation stems from the Act of 4 April 2019 on the digital accessibility of websites and mobile applications of public entities. 
‘The statement describes the state of accessibility. Even if a website is inaccessible it must have a fully accessible statement that describes this state.’ Source: www.gov.pl - How to draft an accessibility statement

When does the accessibility statement need to be updated?

According to Article 11 of the Digital Accessibility Act public entities shall review and update the accessibility statement by 31 March each year and immediately whenever a website or mobile application undergoes changes that may affect its digital accessibility. 

Who at the UJ is responsible for digital accessibility, including accessibility statements?

According to Article 4(1) of the Ordinance No. 20 of the Jagiellonian University Rector of 22 February 2023 on the principles governing the implementation of the accessibility policy of the Jagiellonian University concerning the needs of persons with disabilities and persons with specific needs, ‘Any person employed at the Jagiellonian University within the scope of their assigned tasks shall be responsible for the implementation of accessibility’. 

This means that unit/project managers and persons who have been assigned the task of editing websites or mobile applications are responsible for accessibility statements. 
The statutory obligations are recalled in the Communication No. 7 of the JU Vice-Rector for Development of 21 March 2023. 

 

Who is responsible for creating accessibility statements? Is there a unit that drafts them for the entire JU?

The Jagiellonian University communicates with the public through more than 1,000 websites. It is not physically possible for a single unit to develop accessibility statements for all websites and mobile applications and monitor their accessibility. Hence, the responsibility lies with the individual units that run the websites (ensuring accessibility is the same legal requirement as complying with copyright or privacy policies). 

We recognise that meeting the obligations may be a concern at first. That is why the JU Accessibility Centre, in cooperation with the JU Portal Section, addresses these challenges in the form of training, consultation, and the creation of a knowledge base (useful links, instructional videos). We are working closely with the JU Portal Section to address systemic accessibility deficiencies in the JU Portal. 

As part of the Responsible Support and Sustainable Development project, we are supporting page editors to create accessibility statements (applies to pages on the JU Portal) until the end of 2023 where possible. More information on the project website under Online training -> For JU staff. 

 

Is there a template for the statement?

Yes. The Ministry of Digitalisation has published the Technical Conditions of Publication and the structure of the electronic document ‘Accessibility Statement’.

What does a sample accessibility statement look like?

A sample accessibility statement.

 

How to guarantee the accessibility of a website or mobile application?

According to the principles of ensuring accessibility expressed in para. 4 of the JU Accessibility Policy Ordinance, the principles of universal design (for all) and reasonable accommodation should be followed. All JU organisational units are obliged to take measures:

  1. taking into account the needs of persons with specific needs in the activities planned and carried out;
  2. removing and preventing barriers within their activities and competences.
If the task of creating and maintaining a website or mobile application is entrusted to an external entity, care should be taken to ensure that appropriate provisions are included in the contract to guarantee accessibility. 
 
A basic condition will therefore be ‘that the website complies with the WCAG 2.1 guidelines at the level set out in Annex 2 of the Digital Accessibility Act (as amended)’. 
Sample clauses have been proposed by the Public Procurement Office in the file ‘Clauses to the ToR and contracts for the creation of an accessible website NEW’ at uzp.gov.pl.

Which WCAG 2.1 guidelines must be met?

A list of the required guidelines is included in the Annex to the Digital Accessibility Act, pages 10–11.

Where can I find out more about WCAG 2.1?

A translation of the guidelines into Polish with an explanation can be found on the website of the organisation W3C.

Does the JU offer any training on implementing digital accessibility?

Yes, a list of current free-of-charge training courses can be found on the Responsible Support and Sustainable Development project website under Online Training -> For JU staff.
Individual consultations are also possible. Please feel free to contact Radosław Zaremba by email at ​radoslaw.zaremba@uj.edu.pl, phone number (+48) 12 663 43 38.