Disability : Information in Accessible Formats

The request was successful.

Dear NHS Digital,

Many disabled people continue to lose out as we exit the pandemic with huge healthcare backlogs. This request concerns provision of information in 'accessible formats.'
Disability only, as a 'protected characteristic' under s 20 of the Equality Act 2010 imposes the anticipatory duty of 'reasonable adjustments' on service providers. It matters that disabled people can access services, make informed decisions and participate in public consultations/ surveys ['engagement'] etc whether they can use the internet or not, and whether they fit the deaf/blind/learning difficulties /Braille/large print/audio/BSL stereotype or not.

The subjectivity of s 20 of the Equality Act 2010 has resulted in diverse efforts which variously clarify, confuse or limit what this means in practice for public service providers. These measures include the NHS Accessible Information Standard [AIS]; the Cabinet Office Service Standards and other NHS and government instructions, pledges and guidance including elements of the National Disability Strategy. Healthwatch England have just reported on AIS, finding widespread non-compliance.
Please disclose:
Do you have a consistent policy on providing information in accessible formats? If so, what is it?
How many 'pieces of information' [all types] for patients have you issued or commissioned in the last 3 years?
Of those, how many were offered online?
Of those, how many were also offered in alternative 'accessible' digital formats?
And how many were offered in accessible non-digital formats? [Some may well have been offered in both digital and non-digital accessible formats]
Which accessible formats were offered for people who are blind, deaf or have learning difficulties?
And which accessible formats were offered for people who have other disabilities causing communication needs [eg physical or cognitive]?
Depending on what statistics you hold centrally this could exceed time/cost limits, in which case please say what you can supply. Essentially i hope to discover the scale and how a] people covering the full range of disabilities and b] disabled people who cannot use the internet, are catered for.

Yours faithfully,

Dick Fowler

Dear NHS Digital,
i would appreciate a response to my FOI request.

Please advise

Yours faithfully,

Dick Fowler

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-638708-N2F8W 

Dear Dick,

Thank you for your email dated 29 March 2022 regarding your Freedom of
Information Request reference NIC-638708-N2F8W.
 
Please accept our sincere apologies for the delay in providing a response
to your request. We continue to consider your request and will be in touch
with our response as soon as possible.
 
Yours faithfully
Information Governance Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678
[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

 

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[3]https://digital.nhs.uk/about-nhs-digital...

[4]Privacy and cookies

 

 
 

show quoted sections

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-638708-N2F8W 

Dear Dick,

Thank you for your email and your patience whilst we responded to your
enquiry. Please see the below response we have received from the relevant
teams - 

"When publishing content on the NHS website ([1]https://www.nhs.uk), we
aim to make all our online content as accessible as possible.

• Almost everything is published in accessible HTML format, using
templates that are designed to be accessible and are tested with people
with a wide range of accessibility needs.

• Our teams follow the evidence-based guidance published in the NHS
digital service manual ([2]https://service-manual.nhs.uk) to help make
content as simple, usable, accessible and inclusive as possible. Content
is written in plain English, designed to meet accessibility standards
(WCAG 2.1 AA), tested with people with access needs and evaluated by
accessibility audits.

• We use different formats like images and video where appropriate. All
new videos added to the NHS website are to WCAG 2.1 AA standard. And we
have also made great progress in working through our legacy video content
to bring them up to AA standard. This includes the addition of captions
and transcripts to help users.

• The standards outlined in our service manual have been adopted across
the NHS to help make a wide range of digital information and services
usable and accessible for as many people as possible.

• The NHS website accessibility statement
([3]https://www.nhs.uk/accessibility-stateme... currently being
updated but reflects known issues on the website and we are committed to
fix the issues that we can.

• The recent COVID Pass letter service
([4]https://www.nhs.uk/conditions/coronaviru...
made available in a number of formats - an audio version, Braille or large
print. We can also provide information about the letter in several
languages. But we don't routinely do this with other content across the
website.

• We actively encourage teams who publish content on the NHS website to:

o Consider accessibility at the start of their project, and throughout
o Make it the whole team's responsibility
o Research with users with access needs
o Test on assistive technologies and where appropriate to get an
accessibility audit done to identify and remediate issues identified
o Make use of our own accessibility lab (based in our Leeds office) where
teams can test designs on a range of assistive technologies.

• Over the last two years, we have invested over £150,000 to carry out a
number of accessibility audits of our content on the NHS website, NHS App,
related services as well as public health campaigns.

• Over the last three years, we would estimate changes to 2,700 health
advice pages of content on the website (e.g. new content added such as the
COVID-19 content or changes to existing content including our routine
clinical reviews).

• Content we publish on the website is available for free via our APIs for
external organisations to re-use in alternative formats.

• We have redesigned how our pages appear when printed so they can be used
by people without internet access or who prefer hard copies of
information.

• We introduced a process in September 2020 to capture specific
accessibility enquiries via our service desk. Since that time, we have had
7 accessibility-related service desk tickets:

o Two of these tickets relate to content not being optimised to work for
screen readers – and have since been fixed.
o The remainder are more general enquiries by nature such as requesting
clearer accessibility information at a particular GP practice.
o We have not received any specific requests to provide content in
alternate formats such as braille, Easy Read, audio or large print. That
said, we do link to some Easy Read content about autism on the website
([5]https://www.nhs.uk/conditions/autism/eas...).

If we can be of any further assistance, please do not hesitate to get in
touch.

Kind Regards,

Contact Centre Team
NHS Digital
[6]www.digital.nhs.uk

0300 303 5678
[7][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

 

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[8]https://digital.nhs.uk/about-nhs-digital...

[9]Privacy and cookies

 

 
 

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Dear NHS Digital,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of NHS Digital's handling of my FOI request 'Disability : Information in Accessible Formats'.

You have replied only in terms of Accessible Websites and have not disclosed any other of the information requested [repeated below]. In particular you have said nothing about the scale of public information NHS Digital generate or commission nor what you provide for disabled people who cannot access the internet and so need traditional non-digital accessible formats. The latter is governed by an assortment of laws and policies.

''Please disclose:
Do you have a consistent policy on providing information in accessible formats? If so, what is it?
**How many 'pieces of information' [all types] for patients have you issued or commissioned in the last 3 years?
Of those, how many were offered online?
Of those, how many were also offered in alternative 'accessible' digital formats?
**And how many were offered in accessible non-digital formats? [Some may well have been offered in both digital and non-digital accessible formats]
**Which accessible formats were offered for people who are blind, deaf or have learning difficulties?
**And which accessible formats were offered for people who have other disabilities causing communication needs [eg physical or cognitive]?
Depending on what statistics you hold centrally this could exceed time/cost limits, in which case please say what you can supply. Essentially i hope to discover the scale and how a] people covering the full range of disabilities and b] disabled people who cannot use the internet, are catered for.''

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/d...

Yours faithfully,

Dick Fowler

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-647463-H1P0C 

Dear Dick Fowler,

We are writing to acknowledge that your request for information was
received by NHS Digital on 07/04/22 and is currently being considered.

If NHS Digital is able to provide you with the information you have
requested, then under the Freedom of Information (FOI) Act you are
entitled to receive it promptly and in any event no later than the 20th
working day following the date of receipt. However, we may need to contact
you to clarify your request. If this is required we aim to do this
promptly but no later than 7 days after receiving your initial request for
information.

The FOI Act provides a 'General right of access to information held by
public authorities'. However, it also defines a number of exemptions
which may prevent the release of some or all of the information you have
requested. Therefore, NHS Digital will assess your information request in
light of any relevant exemptions.

If exemptions do apply, then NHS Digital may decide not to release all, or
part, of the information you have requested. I shall inform you if this is
the case, and advise you of your rights of appeal.

If the information you request contains reference to a third party then
they may be consulted prior to a decision being taken as to whether to
release the information to you.

The response to your request will be sent to you by email, however if you
require your response in any other format, please contact us to discuss a
suitable format.

NHS Digital will not normally charge a fee to provide you with the
information you have requested, unless the cost of dealing with your
request is more than £450 as outlined in Section 12 of the FOI Act and
Section 3 of the The FOI and Data Protection (Appropriate Limit and Fees)
Regulations 2004. If it appears likely that your request will cost more,
then NHS Digital is able to refuse to supply the information.  As per our
obligations under Section 16 of the FOI Act, every effort will be made to
provide you with details of how you may be able to reframe your request in
order for us to complete the required work within the (£450 / 18 person
hours) cost limit.

If you have any queries or should you wish to make a complaint about the
manner in which your request is being processed then please do not
hesitate to contact us at [1][NHS Digital request email] in the first
instance. Any complaints will be investigated in accordance with NHS
Digital's complaints procedure.

Further information about your rights under the Freedom of Information
Act, is available from the Information Commissioner's Office, Wilmslow,
Cheshire and on the NHS Digital website.

Kind Regards,

Contact Centre Team
NHS Digital
[2]www.digital.nhs.uk

0300 303 5678
[3][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[4]https://digital.nhs.uk/about-nhs-digital...

[5]Privacy and cookies

 

 
 

show quoted sections

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-647463-H1P0C 

Dear Dick,

Thank you for your email.

Please accept our apologies, the response was sent to you prematurely. 

It was not a full response, and your FOI case is still open and being
worked on by our Information Governance team.

We will be in contact once we have a full response for your FOI from the
team.

If we can be of any further assistance, please do not hesitate to get in
touch.

Kind Regards,

Contact Centre Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678
[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

 

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[3]https://digital.nhs.uk/about-nhs-digital...

[4]Privacy and cookies

 

 
 

show quoted sections

Dear NHS Digital Enquiries (NHS DIGITAL),
Please advise the status of the rest of your reply. This is now nearly a month overdue.
I would be particularly interested to know if you are trying to show that you are not obliged to offer information in non-digital accessible formats and on what basis.

Yours sincerely,

Dick Fowler

NHS Digital Enquiries (NHS DIGITAL),

1 Attachment

 

Ref: NIC-638708-N2F8W 
 

Dear Dick Fowler,

Many thanks for your recent request to NHS Digital.

We have now received a partial reply to this from our colleagues in the
Information Governance team.

Please see the attached file(s).

Kind Regards,

Contact Centre Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678

[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

[3]Privacy and cookies

 

 

show quoted sections

NHS Digital Enquiries (NHS DIGITAL),

1 Attachment

 

Ref: NIC-638708-N2F8W 
 

Dear Dick Fowler,

Many thanks for your recent request to NHS Digital.

We have now received a reply to this from our colleagues in the
Information Governance team.

Please see the attached file(s).

Kind Regards,

Contact Centre Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678

[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

[3]Privacy and cookies

show quoted sections

NHS Digital Enquiries (NHS DIGITAL),

1 Attachment

 

Ref: NIC-638708-N2F8W 
 

Dear Dick Fowler,

Many thanks for your recent request to NHS Digital.

We have now received a reply to this from our colleagues in the
Information Governance team.

Please see the attached file(s).

Kind Regards,

Contact Centre Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678

[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

[3]Privacy and cookies

 

 

show quoted sections

Dear NHS Digital,
Ref: NIC-638708-N2F8W

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of NHS Digital's handling of my FOI request 'Disability : Information in Accessible Formats'.

This request for internal review concerns your last part reply dated 16 May 2022 and specifically information offered [or not] in non-digital 'accessible formats'. .

The problem my FOI request is trying to examine is how you reach those disabled people who 'harder to reach'. Those with limited digital skills and software etc; and those with none. i will be seeking advice on how accessible your websites are to those like me with limited digital skills and software etc really are.

I think that you are saying you have issued 2700 pieces of information in 'accessible' digital format and none in non digital format which is extraordinary. Surely you know about braille, large print, audio, BSL, email etc? Government guidance is https://www.gov.uk/government/publicatio...

As far as non-digital accessible formats, are concerned, you are correct. By 'offer' i do not mean 'on request' because this places the onus on the disabled person who probably does not know what you are doing or how to request an accessible format. Consider something complicated like GPDPR which has to be understood to make a decision on opting out or not.

By 'offer' i mean providing information in accessible non digital formats as an anticipatory duty under section 20 [6] of the Equality Act 2010 [and as a government public service provider you are not an 'Information Society Service Provider' exempt under section 25, i believe]; the NHS Accessible Information Standard [which you know about, there is an NHS Digital page about it]; plus various policies including the NHS Constitution and the National Disability Strategy [Social Model of Disability etc].

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/d...

Yours faithfully,

Dick Fowler

Dear NHS Digital Enquiries (NHS DIGITAL),
re NIC 638708 N2F8W final response.pdf

INTERNAL REVIEW

i am sorry there was a typo in my para 7

Regarding 'Information Society Service Providers', 'section 25' should have read 'Schedule 25' [of the Equality Act 2010]

Yours sincerely,

Dick Fowler

NHS Digital Enquiries (NHS DIGITAL),

1 Attachment

 

Ref: NIC-656553-X5W8N 
 

Dear Dick Fowler,

Many thanks for your recent request to NHS Digital.

We have now received a reply to this from our colleagues in the
Information Governance team.

Please see the attached file(s).

Kind Regards,

Contact Centre Team
NHS Digital
[1]www.digital.nhs.uk

0300 303 5678

[2][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

[3]Privacy and cookies

 

 

References

Visible links
1. http://www.digital.nhs.uk/
2. mailto:[NHS Digital request email]
3. https://digital.nhs.uk/about-nhs-digital...

Dear NHS Digital Enquiries (NHS DIGITAL),
NIC-656553-X5W8N
Thank you, my IR request 'jumped the gun.'
In terms of my original request please confirm or correct my understanding that of 2700 pieces of public information , none was offered in non-digital accessible formats.
Extract;
Do you have a consistent policy on providing information in accessible formats? If so, what is it?
How many 'pieces of information' [all types] for patients have you issued or commissioned in the last 3 years?
Of those, how many were offered online?
Of those, how many were also offered in alternative 'accessible' digital formats?
And how many were offered in accessible non-digital formats? [Some may well have been offered in both digital and non-digital accessible formats]
Which accessible formats were offered for people who are blind, deaf or have learning difficulties?
And which accessible formats were offered for people who have other disabilities causing communication needs [eg physical or cognitive]?

Yours sincerely,

Dick Fowler

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-661696-Q4C8H 

Dear Dick Fowler,

We are writing to acknowledge that your request for information was
received by NHS Digital on 22/6/2022 and is currently being considered.

If NHS Digital is able to provide you with the information you have
requested, then under the Freedom of Information (FOI) Act you are
entitled to receive it promptly and in any event no later than the 20th
working day following the date of receipt. However, we may need to contact
you to clarify your request. If this is required we aim to do this
promptly but no later than 7 days after receiving your initial request for
information.

The FOI Act provides a 'General right of access to information held by
public authorities'. However, it also defines a number of exemptions
which may prevent the release of some or all of the information you have
requested. Therefore, NHS Digital will assess your information request in
light of any relevant exemptions.

If exemptions do apply, then NHS Digital may decide not to release all, or
part, of the information you have requested. I shall inform you if this is
the case, and advise you of your rights of appeal.

If the information you request contains reference to a third party then
they may be consulted prior to a decision being taken as to whether to
release the information to you.

The response to your request will be sent to you by email, however if you
require your response in any other format, please contact us to discuss a
suitable format.

NHS Digital will not normally charge a fee to provide you with the
information you have requested, unless the cost of dealing with your
request is more than £450 as outlined in Section 12 of the FOI Act and
Section 3 of the The FOI and Data Protection (Appropriate Limit and Fees)
Regulations 2004. If it appears likely that your request will cost more,
then NHS Digital is able to refuse to supply the information.  As per our
obligations under Section 16 of the FOI Act, every effort will be made to
provide you with details of how you may be able to reframe your request in
order for us to complete the required work within the (£450 / 18 person
hours) cost limit.

If you have any queries or should you wish to make a complaint about the
manner in which your request is being processed then please do not
hesitate to contact us at [1][NHS Digital request email] in the first
instance. Any complaints will be investigated in accordance with NHS
Digital's complaints procedure.

Further information about your rights under the Freedom of Information
Act, is available from the Information Commissioner's Office, Wilmslow,
Cheshire and on the NHS Digital website.

Kind Regards,

Contact Centre Team
NHS Digital
[2]www.digital.nhs.uk

0300 303 5678
[3][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[4]https://digital.nhs.uk/about-nhs-digital...

[5]Privacy and cookies

 

 
 

show quoted sections

NHS Digital Enquiries (NHS DIGITAL),

Ref: NIC-661696-Q4C8H 

Dear Sir/Madam
 
Information Governance Query Ref: NIC-661696-Q4C8H
 
Thank you for your email dated 22 June 2022 in relation to your Freedom of
Information request reference NIC-638708-N2F8W, and NHS Digital’s
response.
 
You asked:
“In terms of my original request please confirm or correct my
understanding that of 2700 pieces of public information , none was
offered  in non-digital accessible formats.”

 
Your original request was for the following information:
 
“Disability accessible formats of Information
 
Do you have a consistent policy on providing information in accessible
formats? If so, what is it?
 
How many 'pieces of information' [all types] for patients have you issued
or commissioned in the last 3 years?
 
Of those, how many were offered online?
 
Of those, how many were also offered in alternative 'accessible' digital
formats?
And how many were offered in accessible non-digital formats? [Some may
well have been offered in both digital and non-digital accessible formats]
 
Which accessible formats were offered for people who are blind, deaf or 
have learning difficulties?
 
And which accessible formats were offered for people who have other
disabilities causing communication needs [eg physical or cognitive]?”
 
Your query of 22 June 2022 therefore relates to the second and third
questions from your original enquiry. We have set out NHS Digital’s
responses to those questions below. As we noted in our response of 26
April 2022, based your questions, we interpreted your request to relate to
the NHS website ([1]www.nhs.uk).
 
How many ‘pieces of information’ (all types) for patients have you issued
or commissioned in the last 3 years?
 
Over the last 3 years, we estimate that 2,700 changes to health advice
pages of content on the website have been made (e.g., new content added
such as the COVID-19 content or changes to existing content including our
routine clinical reviews).
 
Of those [pieces of information issued or commissioned in the last 3
years], how many were offered online?
 
All 2,700 changes to health advice pages of content on the website were
online.
 
As we understood your request to be about the NHS website ([2]www.nhs.uk),
our answer was about pieces of information on the website. By its nature,
all information on the website will be in a digital format. Therefore, to
answer your question of 22 June 2022 (“please confirm or correct my
understanding that of 2700 pieces of public information , none was
offered  in non-digital accessible formats”) we can confirm that none of
the aforementioned changes to web pages were offered in non-digital
formats. As was also outlined in our previous response, where patients
require information in an alternative format, we ask that they contact our
Contact Centre to let us know what their needs are. This allows us to be
responsive to people’s personal requirements.
 
We hope that this clarification is helpful.
 
Yours sincerely
 
Freedom of Information

Contact Centre Team
NHS Digital
[3]www.digital.nhs.uk

0300 303 5678
[4][NHS Digital request email]

7&8 Wellington Place | Leeds | LS1 4AP

 

You can find out more about our service, including our response times and
customer charter on the NHS Digital website:
[5]https://digital.nhs.uk/about-nhs-digital...

[6]Privacy and cookies

 

 
 

show quoted sections