Democracy, Digital Accessibility, and EU Member Parliament Websites

With foreword by the European Disability Forum (EDF) This content is the copyright of Siteimprove A/S © 2019. All rights reserved.

You may not, except with our express written permission, distribute or commercially exploit the content.

Author: Jessica O’Sullivan-Munck.

For all enquires please email: [email protected]

Foreword by European Disability Forum (EDF). Content Page

1. Foreword by European Disability Forum 4

2. Executive Summary 5

3. Methodology 6

4. An Introduction to Web Accessibility 7

5. The Accessibility DCI Score Results 8

6. Key Takeaways from the Findings 9

7. Investigation: Common Accessibility Issues Identified 10

Inaccessible PDF Files 11

Images That Aren’t Correctly Tagged 13

Links Identified Only by Color 14

Generic Link Text 15

Inaccessible Forms 16

Conclusion 17

13. Glossary of Terms 18

14. The Accessibility DCI Score Point System Explanation 20

15. About the Authors 22

Page 3 // Foreword – European Disability Forum

The European Disability Forum warmly In addition to the obligations set by the welcomes the Democracy, Digital Convention, the EU adopted its ever- Accessibility, and EU Member Parliament first Directive on the accessibility of the Websites Report by Siteimprove. It is a websites and mobile applications of highly valuable contribution towards public sector bodies, the Web Accessibility ensuring the right to political participation Directive, in 2016. EU Member States are and equal access for persons with now obliged to ensure that all public-sector disabilities. bodies’ websites and mobile applications are accessible by 23 September 2020. These rights are clearly set by the United Nation Convention on the Rights of National parliaments have a decisive and Persons with Disabilities (CRPD). representative role in modern democracy. The Convention, ratified by the European The importance of having fully accessible Union and all its Members States, obliges websites is clear: it is not only a legal State Parties to take appropriate measures obligation, it is essential to assure that to ensure full and effective participation persons with disabilities enjoy their right to and inclusion of persons with disabilities participation in public and political life. in society. Article 9 sets accessibility As this report reveals, Member States have a requirements for State Parties, such as long way to go before they can demonstrate guaranteeing persons with disabilities full compliance with the CRPD and the Web access, on equal basis with others, Accessibility Directive. It is disappointing to to information and communications see such low standards of accessibility of technologies and systems, including Member States’ parliaments’ websites. We the Internet. Article 21 highlights States’ are hopeful that the findings will encourage responsibility to ensure that persons Member States to swiftly meet the with disabilities can exercise their right requirements set by the Web Accessibility to freedom of expression and opinion, Directive. including the freedom to seek, receive and impart information and ideas on an equal The lack of accessible information on the basis with others and through all forms websites of national parliaments seriously of communication of their choice. Both hinders the possibility of persons with obligations set out by Articles 9 and 21 are disabilities to fully and effectively exercise preconditions for effective participation their political rights. We call on Member of persons with disabilities in political and States to assure national parliament public life, which is again something States websites’ are fully accessible for persons must ensure according to Article 29 of the with disabilities. Convention. Yannis Vardakastanis, President European Disability Forum

Page 4 // Page 4 // Executive Summary

The right to political participation, to vote, and to access democratic information is a fundamental right for all citizens, as outlined in Article 29 of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD).

Despite this designation millions of people in Europe with disabilities are deprived of exercising this right. According to the European Disability Forum “Persons with disabilities are deprived from their right to cast an informed ballot due to many accessibility hurdles: hard to understand information; lack of subtitles; printed materials with a small font or not in braille, etc.”

In this whitepaper, digital accessibility of the 28 European Member State parliament websites, as well as the overarching European Parliament website, www.europarl.europa.eu, will be assessed against the Web Content Accessibility Guidelines (WCAG) 2.1. WCAG 2.1 covers a wide range of recommendations for making web content more accessible.

Siteimprove’s Digital Presence Optimization (DPO) software is the scoring system used to calculate and classify website accessibility. This system, known as the Accessibility Digital Certainty Index®, uses a weighted score with a scale of 1-100. The scoring key utilized by the Accessibility DCI is as follows:

Website Classification Corresponding Score Range Very Poor 0-50 Poor 51-70 Average 71-80 Good 81-90 Very Good 91-96 World Class 97-100

An overview of the most common issues is identified in this report, as well as brief recommendations on how website accessibility can be improved.

Page 5 // Methodology

For this whitepaper the parliament websites of all 28 European Member States, as defined by the European Union as of 15 November 2018, were selected. The European Parliament website was also included. Utilizing Siteimprove’s software, the first 500 pages of each parliament website, starting with the homepage, was crawled. There were exceptions for France, Spain, and Slovenia. For France 495 pages were crawled, for Spain 492, and for Slovenia 497 pages. These exceptions were the result of the French, Spanish, and Slovenian websites not having 500 pages. Each website was assessed based on the national country language version of the website. In total, 29 websites and 14,484 pages were crawled.

Country Parliament URL Austria https://www.parlament.gv.at/ Belgium http://www.senaat.be/www/?MIval=/index_senate&LANG=nl Bulgaria http://www.parliament.bg/bg Croatia http://www.sabor.hr/hr Cyprus http://www.parliament.cy/el/home Czech Republic http://www.psp.cz/sqw/hp.sqw Denmark https://www.ft.dk/ England https://www.parliament.uk/ Estonia https://www.riigikogu.ee/ European Parliament http://europarl.europa.eu/portal/en Finland https://www.eduskunta.fi/fi/Sivut/default.aspx France https://www.senat.fr/ Germany https://www.bundestag.de/ Greece https://www.hellenicparliament.gr/ Hungary http://www.parlament.hu/ Ireland https://www.oireachtas.ie/ Italy https://www.senato.it/home Latvia http://www.saeima.lv/lv Lithuania http://www.lrs.lt/ Luxembourg https://gouvernement.lu/lb.html Malta https://parlament.mt/mt/ Netherlands https://www.staten-generaal.nl/ Poland http://www.sejm.gov.pl/ Portugal http://www.parlamento.pt/ Romania http://www.cdep.ro/pls/dic/site.home?idl=1 Slovakia https://www.nrsr.sk/web/?sid=home Slovenia http://www.dz-rs.si/wps/portal/Home Spain http://www.senado.es/web/index.html Sweden http://www.riksdagen.se/sv/

Page 6 // An Introduction to Web Accessibility

What is web accessibility? Which accessibility standards should

Web accessibility refers to the inclusive I use? practice of making websites usable by people WCAG 2.1 defines how to make web content of all abilities and disabilities. When sites are more accessible to people with disabilities. correctly designed, developed, and edited, The guidelines are internationally recognized all users get equal access to information and and are used as a best practice worldwide. functionality. WCAG has 12 guidelines organized under 4 Who is affected? principles: There are many different disabilities affecting Perceivable people using the web. Web content can be perceived by the user’s Visual brain regardless of the senses they can use. Blindness, color blindness, and low-vision Operable caused by various eye conditions Web content can be accessed and navigated Motor regardless of the user’s devices. Various forms of paralysis caused by injury, Understandable congenital conditions, and tremors Web content can be understood as easily Auditory as possible through simple language and contextual information. Difficulty hearing, deafness, and hearing impairments Robust Cognitive Web content can be accessed regardless of the user’s operating system, browser, and browser Conditions that affect the brain’s memory, version. attention, or ability to interpret information

The WCAG 2.1 works with three different conformance levels: A (minimum conformance level) AA (medium conformance level) AAA (highest conformance level)

Page 7 // The Accessibility DCI Score Results

Country Accessibility DCI Score Corresponding Classification Austria 56.7 Poor Belgium 64.6 Poor Bulgaria 60.4 Poor Croatia 58.7 Poor Cyprus 61.6 Poor Czech Republic 62.4 Poor Denmark 81 Good England 61.6 Poor Estonia 60.5 Poor European Parliament 55.8 Poor Finland 58.4 Poor France 60.2 Poor Germany 63.6 Poor Greece 72.7 Average Hungary 59.0 Poor Ireland 62.7 Poor Italy 61.9 Poor Latvia 61.5 Poor Lithuania 57.4 Poor Luxembourg 61.0 Poor Malta 64.2 Poor Netherlands 84.4 Good Poland 62.9 Poor Portugal 62.9 Poor Romania 58.7 Poor Slovakia 62.3 Poor Slovenia 59.2 Poor Spain 61.6 Poor Sweden 63.6 Poor

Page 8 // Key Takeaways From the Findings

89.66% of websites provide a POOR accessibility experience.

3.45% of websites provide an AVERAGE accessibility experience.

6.89% of websites provide a GOOD accessibility experience.

Each Parliament URL had on average 65 PDF files with accessibility problems

Only 3 of the 29 websites score above the industry average for accessibility of 66.3.

EU Member States Parliament

Website Accessibility Findings World class: 97-100 58.4 Very good: 91-96 Good: 81-90 FinlFinlaandnd 63.6 Average: 71-80 Poor: 51-70

SwedenSweddenn 60.5 NorwNorwaayy Very poor: 0-50 No data EstEstotoniaoniniai 61.561.5 62.7 61.1 Denmark LatviaLaL tviaa

LithuaniaLiLithuannia 5757..44 Irreelelandd 84.84.4 588 62..99 UnitUniteedd KingdomKKingdoKin m 64.64.6 NetherlNethehheeerlaandnd 633..66 BelorussiaBelorussia PolPolaandnd Europeanean BelgiumBelgiumu 61.0 58 55.8 GermanGeermananyy Parliamentment 62..33 LuxLuxembourembourrgg CzCzech Republicpublic 58 UkrUkkraineaine 56.6.7 Slovakia

60.60.2 59.59.22 59.0 Moldoddoovvaa AustAustriariia 58.58.77 SwitzSwitzerlerlanandd HungaryHuunggaryy RRoomaniamania FranceFrance Croatiaoaatttia 6161..66 ItalItaly 62.9 61.9 SerbiaSeS rbiarrbiaa 60.4

SpSpaipainn KoKoossooovvvoo BulgariaBuBulgaria PortugalPortutugaal MonMontetenegnegrneegroro

Albanibanbanin a

72.7 Greeceeec

61.6

64.2 CypruCyprus

MalMalta

Page 9 // Investigation: Common Accessibility Issues Identified

Page 10 // Inaccessible PDF Files

Ensuring that PDF files on a website are accessible for everyone is important for every organization. PDF documents are a popular file format and users rely on their content for information and links to additional sources. Unfortunately, a routine custom of making documents accessible is often overlooked.

One example discovered during the crawls was an inaccessible PDF which wasn’t tagged and didn’t contain any bookmarks. The document, entitled the ‘House of Commons Service Diversity and Inclusion Scheme,’ outlined its aim as “Equality, diversity and inclusion help make the House of Commons Service respected, effective, efficient, and assist in ensuring that Members, staff and the public are well informed about what we do”.

Despite the good sentiments contained in the document, the lack of tagging means that for a user with a screen reader no information is tagged to distinguish text types such as headings, paragraphs, lists, and tables. The lack of bookmarks means a screen reader user has to read through the entire document to find what they need, rather than jumping to the information they want from headings bookmarked in the table of contents.

Page 11 // The following are some of the most important accessibility aspects to check in PDF files:

Language Tables For screen readers and other assistive When data tables are used, it is important technologies to correctly read a document, to tag their structure. At a minimum, define there should be an overall designation of the all column and row headings. Keep table language in which the document is written. structure as simple as possible; avoid merging Furthermore, if lines or blocks of text within rows and columns as it complicates navigation the document change language, that text for assistive technology users. should be tagged separately. Reading Order Title Assistive technologies rely on logical reading At minimum, documents should include basic sequences to present content to users. information like a title. It is also a good idea to During a document’s creation, it is extremely provide the name of the author, a description, important to ensure there is a sensible reading and a few relevant keywords. order.

Tagging Text Bookmarks All text in a document should be tagged. The easiest and most accessible way to Whether it’s paragraph text, a heading, a list, organize a table of contents is to provide or similar it should be labeled as such. Doing bookmarks based on document headings. This so not only makes a visual distinction between habit gives users the ability to navigate the various text types, but also clarifies the site for PDF using bookmarked headings rather than all users by providing the correct tagging for reading through the entire document to find assistive technologies to use. what they need.

Images Exporting An image can have different purposes There are a variety of ways to create PDFs from depending on how it is used in the document. different editing programs. The document’s Many images are purely decorative, which accessibility functions vary greatly depending should be conveyed with alternative text. It is on the way it is exported, converted, or saved. important to define those images as “artifact”. Other images that have a function or convey Security Settings important information require clear but Lock settings on documents make it more concise descriptions as the “alt” text. difficult, or ultimately impossible, for assistive technologies to extract content and render it to the user. Make sure the final document is not locked, allowing it to be accessed by screen readers and more. Locking a PDF is not the same as password protecting it.

Page 12 // Images That Aren’t Correctly Tagged

When images are added to a web page, it is important to consider that some users cannot see images and others may have images turned off in their browser. Therefore, images need a text alternative. In most content management systems (CMS) the label is referred to as “alternative text” or “alt text.” The text you write here is not visually displayed on the page but is embedded into the code and accessed by screen readers.

Images without alternative text were found to be a common problem across the board for most of the websites assessed. This issue was most often found on pages that displayed information about politicians such as parliament members. Often the biography pages included an image of the person. However, in many cases these images had no “alternative text.”

The following are some of the most important accessibility aspects to consider when adding images:

The code for alternative text (alt="") must be present for all images. However, if the image is decorative, the alt text field can be left empty. If the image conveys information that a person not know without seeing the image, then descriptive information should be written as the alternative text.

If the image links somewhere, it is important to use the alternative text to describe where the link leads to or what happens when the user clicks on the image.

Be careful using images with text in them or text that’s been saved or presented as an image. The alternative text for these ‘images’ should communicate the same information as the text in the image. No screen reader technology can read images of text. They cannot highlight that text within an image and read it aloud. Images of text also tend to pixelate and become blurry upon magnification making them difficult to read for people with other visual or cognitive impairments. For many dyslexic web users, their type of assistive technology requires the user to manually highlight the text on a page that they would like to be read aloud.

Page 13 // Links Identified Only by Color

Approximately every one in twelve men, and one in 200 women, globally are affected by color blindness which is also known as color vision deficiency. This designation is the decreased ability to see color or the difference of colors. It can make everyday tasks such as choosing the right pen or adhering to traffic lights more challenging. Likewise, hyperlinks that are only identified by color causes issues. This issue was identified across most of the surveyed websites.

When links are only identified by color it makes it difficult for people to distinguish between the body of text and the link. In an example found on one of the European Parliament’s (Europarl’s) webpages concerning the 2019 European elections, four links were identifiable only by a blue font color which makes them difficult to identify as links.

How to fix this: Links that are only identified by color need additional visual cues. When users point to the link with their mouse or move keyboard focus to the link alternative cues could be to underline the link or to make it bold. If links in blocks of text are identified only by color, then the color contrast ratio between the link text and the surrounding text needs to be at least 3:1.

Page 14 // Generic Link Text

Another commonly identified accessibility issue across parliament websites was the use of generic link texts like ‘Read more’, ‘Here’, ‘PDF’, and ‘Click here’. These link texts tell the user nothing about what content they will see if they click on the link nor does it provide the destination page that the link points to. It’s important that link texts make sense when they are read out of context especially for those utilizing a screen reader. The reason is that the software often culls the various links on a page into one list for ease of navigation when tabbing around a site. Therefore, it’s best that the link text doesn’t simply read ‘Click here’ 10 times in a row—or at all.

How to Fix Generic Link Text: In general, instead of writing ‘Read more’ it is preferable to explain what the visitor will be reading more about. So instead of just ‘Read more’ it would be preferable to write ‘Read more about the press tool kit’.

Page 15 // Inaccessible Forms

Forms are a common part of websites and are ideal for signing up subscribers to a newsletter, asking a question, getting registrations for membership, and so forth. When designed with accessibility in mind they are useful and usable by all. However, forms are often neglected when it comes to accessibility. This neglect was found to be the case on several of the parliament websites. Forms should be a pressing issue with high priority as they often function as the primary means for website users to contact an organization.

When a contact form is inaccessible, there is a potential for excluding 15% of website visitors.

In an example found on Europarl’s website the form on ‘Sending your question to the European Parliament’ was inaccessible due to the ‘Send’ button being improperly formatted in the html code. In this case, ‘Send’ visually looks like a button but is actually just a link. Proper code is needed to make it a button. Visitors using a keyboard and reliant on the tab key to shift between form fields will miss the ‘Send’ button because it will not actually be recognized as a submission button. Those using a screen reader will also not be able to detect the ‘Send’ button. Both cases make it impossible to move beyond this page and submit a question. Instead the user is stuck eternally looping around the page.

Page 16 // Conclusion

The battle for equality, justice, and fairness changes over time but remains a cornerstone of our society. Just as integrity topics around segregation, “fake news”, and the rise of the #metoo movement, evolve, so do principles around digital accessibility. The quickness with which issues come and go in our consciousness means that it’s easy to claim victory when in fact an issue still exists, or in some cases evolves. The Disability Rights Movement is certainly a point in case.

Over the last couple of decades, the movement has made great leaps in promoting the rights of people with disabilities. Evidence is seen through employment legislation and mandatory building modifications to name a few. Yet one area that remains underprioritized is the digital world. Over 1 billion people, or one in seven people globally, experience disability. Many are heavily reliant on the internet in their day-to-day life.

The role and relationship between the internet and democracy is also essential, as the rise of digitalization means that more and more information is only available online. When an important informational site such as a parliament website is inaccessible a significant amount of the voting population are unable to access essential information that they are democratically entitled to.

It is the hope that with the publication of this whitepaper EU member states will consider prioritizing and improving the web accessibility of all their sites.

Page 17 // Glossary of Terms

UN CRPD Article 29 - Participation in Political and Public Life States Parties shall guarantee to persons with disabilities political rights and the opportunity to enjoy them on an equal basis with others, and shall undertake to:

(a) Ensure that persons with disabilities can effectively and fully participate in political and public life on an equal basis with others, directly or through freely chosen representatives, including the right and opportunity for persons with disabilities to vote and be elected, inter alia, by: (i) Ensuring that voting procedures, facilities and materials are appropriate, accessible and easy to understand and use; (ii) Protecting the right of persons with disabilities to vote by secret ballot in elections and public referendums without intimidation, and to stand for elections, to effectively hold office and perform all public functions at all levels of government, facilitating the use of assistive and new technologies where appropriate; (iii) Guaranteeing the free expression of the will of persons with disabilities as electors and to this end, where necessary, at their request, allowing assistance in voting by a person of their own choice;

(b) Promote actively an environment in which persons with disabilities can effectively and fully participate in the conduct of public affairs, without discrimination and on an equal basis with others, and encourage their participation in public affairs, including: (i) Participation in non-governmental organizations and associations concerned with the public and political life of the country, and in the activities and administration of political parties; (ii) Forming and joining organizations of persons with disabilities to represent persons with disabilities at international, national, regional and local levels.

Page 18 // WCAG 2.1 Guidelines Following these guidelines will make content more accessible to a wider range of people with disabilities, including accommodations for blindness and low vision, deafness and hearing loss, limited movement, speech disabilities, photosensitivity, and combinations of these, and some accommodation for learning disabilities and cognitive limitations; but will not address every user need for people with these disabilities. These guidelines address accessibility of web content on desktops, laptops, tablets, and mobile devices. Following these guidelines will also often make Web content more usable to users in general.

Digital Presence Optimization (DPO) software DPO software allows users to monitor, improve, and optimize all aspects of their website. DPO software provides marketers with eye-opening insights that empower them and their team to create higher quality content, drive better traffic, measure digital performance, and work towards regulatory compliance—all from one place.

Accessibility DCI Score The DCI Accessibility score is a measure of how well a website tests against web accessibility standards that have been set out in the Web Content Accessibility Guidelines (WCAG 2.1). A website’s Accessibility Score is determined by the number of success criteria a site fulfills under the three WCAG conformance levels (A, AA, AAA).

Page Level Page level refers to the level of a page relative to the site’s index URL. The index URL is the URL where the crawler starts to scan the website. It is referred to as on Page level 1. The index URL is normally but not always the homepage of a website.

Web Accessibility Web accessibility refers to the inclusive practice of making websites usable by people of all abilities and disabilities. When sites are correctly designed, developed, and edited, all users can have equal access to information and functionality.

Page 19 // The Accessibility DCI Score Point System Explanation

To generate a balanced Accessibility score, Siteimprove has designed an algorithm that ranks the accessibility issues found against the Web Content Accessibility Guidelines (WCAG), which are part of Siteimprove’s automated Accessibility checks. Siteimprove’s automated checks cover a subset of the WCAG 2.1. success criteria spanning across all functional requirements as outlined in the EN 301 549.

It makes a distinction between errors and warnings to distinguish between WCAG success criteria and best practices: Errors: automatically determined failures to meet success criteria in WCAG Warnings: automatically determined failures to meet best practices in WCAG Besides these two categories, the algorithm also assesses the WCAG A, AA, and AAA levels.

Here is a table showing the WCAG levels, the compliance requirements and their priority:

WCAG Level Compliant when Priority

All ‘A level’ issues have been fixed and best A Highest priority: Minimal Accessibility practices have been applied sitewide.

All ‘A level + AA level’ issues have been fixed High priority: The preferred standard of AA and best practices have been applied site- Accessibility wide.

All ‘A level + AA level + AAA level’ issues have Medium priority: Highest standard of Acces- AAA been fixed and best practices have been sibility applied sitewide.

With the categories and levels combined, the algorithm weighs the issues that occur on the website and reflects these using points, which in turn generates the Accessibility score.

Page 20 // How are the issues being weighted? Here is a table showing how the points are distributed:

WCAG Level issue Category Weight

Errors 0.81 A Warnings 0.25

Errors 0.53 AA Warnings 0.18

Errors 0.33 AAA Warnings 0.07

The algorithm also allocates extra points based on the page level and WCAG A, AA, and AAA level: Pages at level 1 (i.e. the homepage) with multiple Level A/AA errors Pages at level 2 with multiple Level A/AA errors Pages at level 3 with multiple Level A/AA errors

Here is a table showing the extra points that are allocated based on the page level and WCAG level issue:

Page Level WCAG Level issue Weight

Page Level 1 A/AA errors 3.0 / divided among the number of pages

Page Level 2 A/AA errors 6.0 / divided among the number of pages

Page Level 3 A/AA errors 21.0 / divided among the number of pages

To secure a good score, it’s important to ensure the home page and internal links leading from the homepage to level 2 and 3 pages have a low number of errors.

Page 21 // About the Authors

Who is Siteimprove? We’re a people-centric software company driven by the desire to simplify website management and make the internet a better place. Siteimprove was founded in 2003 in Copenhagen, Denmark, and has since expanded into thirteen offices around the world (with more in the works): Amsterdam, Berlin, London, Minneapolis, Oslo, Paris, Singapore, Stockholm, Sydney, Tokyo, Toronto, Vienna, and Zurich. With over 500 employees working in numerous markets, we pride ourselves on having a truly global, yet truly local approach.

Siteimprove’s global CSR strategy and vision is to positively contribute to the area of digital accessibility, with a specific emphasis on making the web better for individuals of all abilities and disabilities.

Learn more about Siteimprove’s work with web accessibility: https://siteimprove.com/en/accessibility/what-is-accessibility/

Who is EDF? The European Disability Forum is an independent NGO that defends the interests of 80 million Europeans with disabilities. We are a unique platform which brings together representative organisation of persons with disabilities from across Europe. We are run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.

Learn more about EDF and their work: http://www.edf-feph.org/

Page 22 //