Disclosure of Information Request document - Disproportionate burden assessments for digital accessibility

Accessibility legislation states that public sector websites must publish content in an accessible format, unless doing so would impose a disproportionate burden on the organisation. If that is the case, an assessment of the extent to which compliance with the accessibility requirement imposes a disproportionate burden must be conducted.

This is a Disproportionate Burden Assessment for the Disclosure of Information Form which is in Word format.

The benefits of creating an HTML version of this document would be:

• a fully accessible version for all users to access
• an easily searchable and indexable version

The form allows for Council records to show that another person has authorisation to discuss personal matters relating to an individual. The Data Protection Act 2018 allows such an agreement to take place to protect the rights of an individual.

The HTML process would need to have functionality for a person to be able to leave their ‘mark’ to allow stated information to be shared with another. Without this option, it could open the data to fraudulent behaviour, as the Council will not be able to cross reference any marks against data held historically.

The form would need significant development to enable the stated ‘marks’ to be made on an electronic device, for submission to the Council. The annual average number of 200 applications the council receives each year, would be disproportionate to the investment in technology required to provide an online only form.

Also relevant to this decision are that:

• The Council is legally required to make the document available to the public, so the document must be published on the Council’s website
• Interest in the document is low – only 200 residents accessed a previous version of the document
• Requests for additionally accessible versions are rare – We have not had a residents requested an accessible version of a previous version of the document
• The document does meet accessibility requirements for most users, although some groups will find it disproportionately difficult
• We have and will always assist with accessible versions on request

Oxford City Council supports residents with accessible needs as much as possible and we will respond to all requests from users that relate to this form.

The current PDF version of Disclosure of Information meets the needs of the public and the legal requirement of the Council. It can be printed locally to allow a mark to be made. Where printing is not an option, the Council can provide a paper version to be sent to the home for completion.

For visually impaired residents, the form can be provided in Braille.

17 January 2025