Noting Paper 279 - Accessibility Improvement Plan

[CDR-CX-Stream]

Tuesday 6 December 2022: Report Published
The DSB, as an arm of Treasury, has engaged PwC's Indigenous Consulting and the Centre for Inclusive Design to provide an independent assessment of how the consumer experience data standards and related artefacts for the Consumer Data Right (CDR) are tracking against relevant accessibility and inclusivity benchmarks. This included a focus on the accessibility standards. Similar assessments are proposed to be undertaken in the future to help ensure the data standards and related artefacts remain fit for purpose.

The DSB considers it timely to undertake this assessment as the CDR expands to support new sectors and functionality, particularly in relation to action and payment initiation and the Government Response to the Final Report of the Inquiry into Future Directions for the Consumer Data Right.

The report can be accessed below in PDF and DOCX:
Accessibility Improvement Plan for the Data Standards Chair.pdf
Accessibility Improvement Plan for the Data Standards Chair.docx

This report outlines recommendations from the review and should not be read as representing the views of the DSB or the Data Standards Chair.

For ease of access, a summary of the report's recommendations can be found below (see pp.33-36 of the PDF version for more detail):

Recommendation 1: Whilst the CX Standards already mandate certain WCAG criterion, the Chair should consider more extensively incorporating WCAG into the Data Standards, the Data Standards artefacts themselves, and related products, to address their legislative obligations for Accessibility.

Recommendation 2: Given the current reliance upon a Design System which is not fit-for-purpose, the Chair addresses the divergence from the GOLD Design System.

Recommendation 3: The Chair commissions a scoping-study into the development of Usability and Inclusivity framework(s) with the intent of addressing their legislative obligations.

Recommendation 4: The Chair, or the DSB, joins W3C in order to support the future direction of these standards.

Recommendation 5: The DSB should maintain an Accessibility, Usability, and Inclusion capability in order to support appropriate Data Standards development, on behalf of the Chair.

Recommendation 6: The Chair refines the existing CX Accessibility Standards in order to simplify and strengthen them.

Recommendation 7: Review, prioritise and address issues of Transparency, Clarity and Understanding and Visibility in the Consent Flow.

Recommendation 6 represents the core part of an uplift to the accessibility standards. The report states that CDR participants are already required to make their online services accessible in accordance with the Disability Discrimination Act (DDA), which invokes a legal requirement for all information and services provided online to be usable and accessible to people with disabilities. The Australian Human Rights Commission’s (AHRC) guidance stipulates that any individual or organisation providing information or services online is subject to this requirement, and that WCAG2.0 be adopted for this purpose.

On this basis, the report recommends that the standards be revised to make CDR obligations consistent with these existing requirements by replacing the existing accessibility standards with a statement similar to:

All CDR participants MUST provide information and services that achieves two functional performance statements:
- Enable any person to locate identify, operate functions, and to access the information provided, regardless of physical, cognitive, or sensory abilities
- Maintain the privacy and security of any user at the same level regardless of the accessibility features of the content or service.

The DSB is particularly interested in feedback on this recommendation, including views on the presence and application of any equivalent non-CDR obligations, and how any such obligations are being met or considered by CDR participants.

The DSB also invites feedback on the priority and scope of the recommendations, and the timing of any subsequent uplifts to the accessibility standards.

The community is invited to provide feedback on the report's recommendations, ideally in this thread, or directly to contact@consumerdatastandards.gov.au. The DSB will develop a response to the recommendations, which will consider feedback provided by the community. The consultation will remain open indefinitely until this response is provided.