Accessible documents policy

Accessible documents at the Student Loans Company (SLC).

This policy explains how accessible the documents the Student Loans Company publishes on GOV.UK are. It covers PDFs and Microsoft Excel spreadsheets. It does not cover content published on GOV.UK as HTML: the main GOV.UK accessibility statement covers that.

Using our documents

Student Loans Company publishes documents in a range of formats, including:

  • PDF
  • Microsoft Excel spreadsheets
  • CSV (Comma-Separated Values)

We want as many people as possible to be able to use those documents. For example, when we produce a document we make sure to:

  • provide an HTML option where possible
  • tag headings and other parts of the document properly, so screen readers can understand the page structure
  • make sure we include alternative text alongside non-decorative images, so people who cannot see them understand what they’re there for
  • avoid using tables, except when we’re presenting data
  • write content that is easy to understand

How accessible our documents are

New documents we publish and documents you need to download or fill in to access one of the services we provide should be fully accessible. However, we know that some of our older documents (published before 23 September 2018) are not accessible. For example, some of them:

  • are not marked up in a way that allows screen reader users to understand them
  • are not tagged up properly - for example, they do not contain proper headings
  • are not written in plain English
  • contain images without a textual description
  • include complex tables

This mostly applies to our:

  • corporate reports
  • statistics
  • guidance

These types of documents are exempt from the regulations, so we do not currently have any plans to make them accessible. But if you need to access information in one of these document types, you can contact us and ask for an alternative format.

What to do if you cannot use one of our documents

If you need any of our letters, forms or guides sent to you in Braille or large print, email brailleandlargefonts@slc.co.uk with:

  • your address
  • your Customer Reference Number
  • what you need changing into Braille or large print
  • for large print, include the font size and the font type you need

If there are any other parts of our website which you cannot access, please let us know by contacting us at accessibility@slc.co.uk.

Reporting accessibility problems with one of our documents

We’re always looking to improve the accessibility of our documents. If you find any problems not listed on this page or you think we’re not meeting accessibility requirements, contact accessibility@slc.co.uk.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how the Student Loans Company respond to your complaint, contact the Equality Advisory and Support Service (EASS), or the Equality Commission for Northern Ireland (ECNI) if you live in Northern Ireland.

Technical information about the accessibility of our documents

The Student Loans Company is committed to making our documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. The documents the Student Loans Company publishes are partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances listed below.

Non-accessible content

The content listed below is non-accessible for the following reasons:

Non-compliance with the accessibility regulations

Success criterion 1.1.1: non-text content

Some of our documents have diagrams and/or tables. Some images do not have a text alternative, so the information in them is not available to people using a screen reader. This does not meet WCAG 2.1 success criterion 1.1.1 (non-text content). We plan to add text alternatives for all diagrams by September 2020. When we publish new documents we’ll make sure our use of diagrams meets accessibility standards.

Success criterion 1.3.1: info and relationships

Some of our documents do not identify headings, lists or data tables correctly. This means users using screen readers may not be able to follow the structure of a document, which in turn may affect their ability to access and understand the information. This does not meet WCAG 2.1 success criterion 1.3.1 (info and relationships).

We plan to ensure all our documents have a correct structure, so that they are accessible to users using assistive technologies, by September 2020.

Success criterion 1.3.2: meaningful sequence

Some of the content in documents may not read out in the correct order. This may make it difficult for screen reader users to interpret the information. This does not meet WCAG 2.1 success criterion 1.3.2 (meaningful sequence). We plan to ensure all our documents can be read out in the correct reading order, so that they are accessible to users using assistive technologies, by September 2020.

Success criterion 1.4.3: contrast (minimum)

Some of our documents may not display enough colour contrast between the foreground text and background. This may make it difficult for users who are colour blind, elderly users or users who have low vision to read see the content. This does not meet standard 1.3.2 (meaningful sequence).
We plan to ensure that we use the correct text/background colour combination and contrast ratio in our documents by September 2020.

Success criterion 1.4.5: images of text

Some of our documents contain images of text to convey information, rather than plain text. This means users either who have low vision or who use assistive technology may not be able to understand the image of text. This does not meet WCAG 2.1 success criterion 1.4.5 (images of text). We plan to ensure that none our documents use images of text to convey information only by September 2020.

Success criterion 1.4.10 (reflow).

Some of our documents do not display the content correctly or content may overlap when using Adobe Acrobat Reader. This may mean that users with low vision find it difficult to follow the order of the content in reflow mode. This does not meet WCAG 2.1 success criterion 1.4.10 (reflow). We plan to ensure that our documents display content in a single column by September 2020. This will mean that users will not have to scroll horizontally or vertically to view content when using reflow mode with Adobe Acrobat Reader.

Success criterion 1.4.11: non text contrast

Some of our documents do not meet the colour contrast ratio of at least 3:1. This can make it difficult for users with low vision or colourblindness to see non text items easily. This does not meet WCAG 2.1 success criterion 1.4.11 (non-text contrast). We plan to ensure that we use the correct contrast ratio in our documents by September 2020.

Success criterion 2.4.2: page titled

Some of our documents have incorrect or incomplete titles. This can cause confusion for people who use screen readers and make it hard for users to navigate and find the content they need. This does not meet WCAG 2.1 success criterion 2.4.2 (page titled). We plan to ensure that our documents have meaningful, complete and descriptive titles by September 2020.

Success criterion 2.4.3: focus order (in context)

Some of our documents may not follow a defined structure. This means users either using a text-only browser or using assistive technology may not be able to follow the content in the right order. This does not meet WCAG 2.1 success criterion 2.4.3 (focus order). We plan to ensure that our documents have a clearly defined structure, so that they are accessible to users using assistive technologies, by September 2020.

Some links in our documents do not contain context in the link text. This makes it hard for users using assistive technology to understand what the link is for, and where they would be directed to if clicked. This does not meet the WCAG 2.1 success criterion 2.4.4 (link purpose (in context)). We plan to give all our links context by September 2020 so that their purpose can be determined from the link text.

Success criterion 2.4.5: multiple ways

Some of our documents may not have clearly defined bookmarks. This can make it difficult for users who have low vision or who use assistive technology to navigate between pages. This does not meet the WCAG 2.1 success criterion 2.4.5 (multiple ways). We plan to add bookmarks to our documents by September 2020 to ensure that users with low vision or those using assistive technology can navigate different sections of the document quickly.

Success criterion 2.4.7: focus visible

Some of our documents do not display a visual indicator to show where the user is on a page. This means that users who are colour blind, elderly users, users with low vision or mobility impairments may find it difficult to see when focus moves from one element to another. This does not meet the WCAG 2.1 success criterion 2.4.7 (focus visible).

Content that’s not within the scope of the accessibility regulations

Some of our older documents don’t meet accessibility standards. For example, they:

  • do not contain alternative text for images – this does not meet WCAG 2.1 success criterion 1.1.1
  • use images of text, rather than plain text – this does not meet WCAG 2.1 success criterion 1.4.5

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services. For example, we do not plan to fix documents published before 23 September 2018 on the following page https://www.gov.uk/government/collections/slcs-corporate-and-business-plans.

Any new PDFs or Microsoft Excel spreadsheets we publish will meet accessibility standards.

How we tested our documents

We last tested a sample of our documents on November 2019. The test was carried out by Uservision. We tested:

  • PDF documents
  • Microsoft Excel documents

We decided to test these types of document as they are the main non-HTML formats published by the Student Loans Company.

What we’re doing to improve accessibility

The Student Loans Company is:

  • putting guidance and procedures in place to ensure that all new documents that we produce are accessible
  • working with our partners to help them create accessible documents
  • updating PDF templates to an accessible format
  • creating reports as HTML rather than PDF where possible
  • raising awareness across the organisation and encouraging the use of clear language in reports
  • testing publications with assistive technology software users

This page was prepared on 27 November 2019. It was last updated on 16 December 2019.