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Website accessibility disproportionate burden

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Dear City of Wolverhampton College,

I am contacting you with regard to your website accessibility statement:

In the statement you claim disproportionate burden under Part 2 Section 7 of the Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018: https://www.legislation.gov.uk/uksi/2018....

As required by Part 2 Section 7 (2) of the regulations mentioned above, you were required to conduct an assessment of impacting factors before making the disproportionate burden claim. Information on the types of evidence expected in the assessment can be found in the latest monitoring report produced by GDS: https://www.gov.uk/government/publicatio....

I have noticed that your disproportionate burden claim happens to match word for word that which is provided in the example accessibility statement by the monitoring body: https://www.gov.uk/government/publicatio.... In particular the following:

Interactive tools and transactions
Some of our interactive forms are difficult to navigate using a keyboard. For example, because some form controls are missing a ‘label’ tag.

Our forms are built and hosted through third party software and ‘skinned’ to look like our website.

Given that you made a claim in the accessibility statement dated 10 June 2020, please can you provide me with all documentary evidence that meets monitoring expectations which supports your disproportionate burden claim and shows that you have not just copy/pasted the example into a legal claim without completing your legal due diligence.

Kind regards,


Mail College Direct, City of Wolverhampton College

[Ticket#2022090710000661] Your Recent Enquiry
Dear -,

Thank you for contacting us.

We will respond to your enquiry as soon as possible.

If you need to contact us please quote your Reference number: 2022090710000661


Kind regards

City of Wolverhampton College
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Elizabeth Ball, City of Wolverhampton College

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Dear Chris

I apologise that the Freedom of Information request that you sent in July
2022 was overlooked by our system and not sent over to me until December.

We are however able to respond to your request as per the attached.

Yours sincerely

Elizabeth Ball

Head of Governance  


From: Chris Malry >
To: FOI requests at City of Wolverhampton College <[1][City of Wolverhampton College request email]>
Subject: Freedom of Information request - Website accessibility
disproportionate burden
Date: 09/07/2022 11:40:21

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We don't know whether the most recent response to this request contains information or not – if you are Chris Malry please sign in and let everyone know.