NHS Dumfries & Galloway

Disproportionate burden statement

Disproportionate burden assessment 

NHS Dumfries and Galloway is committed to meeting its legal obligations set out in The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (“No. 2 Regulations”). 

However, we have limited resources to check our website and associated documents for accessibility issues.   

As per the Number 2 Regulations: Interpretation, we have decided it would be a disproportionate burden to pay for the services of an external auditor to perform a detailed check on our entire collection of websites. 

We do not believe the benefits of paying for an external check of our site would justify the impact on our organisation. 

How we do accessibility checks 

We’ve decided to use a combination of methods for our organisation, as set out in the GOV.UK guidance on deciding how to check your websites and in compliance with the No. 2 Regulations.  

Detailed checks 

We’re doing a detailed accessibility check for the NHS Dumfries and Galloway website, nhsdg.co.uk. 

The process for doing a detailed check includes: 

We believe it is reasonable to carry out a detailed check in the manner above.  

Our accessibility statement covers problems we found and our plans to fix them.  

Disproportionate burden 

Checking the website 

We have assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to pay an auditor to do an additional detailed check on our website.  

Between July and September 2023, we responded to the results of the initial audit by conducting extensive accessibility-improvement work on nhsdg.co.uk in line with our ongoing commitment to make our web estate as accessible as we can. The failures in accessibility of the web pages (as opposed to hosted documents) identified by the initial audit were site-wide, and therefore amenable to site-wide correction by changing details of the site templates. Additional fixes applied to hosted documents are discussed below. 

Fixes to the website included WCAG 2.1.1 Keyboard;  2.4.7 (Focus Visible); 1.4.10 Reflow; 1.4.5 (Images of Text), 2.2.2 (Pause, Stop, Hide); 1.4.3 (Contrast, Minimum), 2.4.4 (Link Purpose), 4.1.2 (Name, Role, Value), and 2.4.1 (Bypass Blocks) . This involved a coordinated programme of work by our external CMS provider and our communications team.  

Based on this, manually auditing every page on our main site would, in our belief, constitute a disproportionate burden. 

Fixing documents  

The audit identified a need to amend published documents for accessibility, with fixes including WCAG 1.4.3 (Contrast), 3.1.1 (Language of Page), 1.3.1 (Info and Relationships: Tables) and 1.1.1. (Non-text content). 

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. 

Having carried out a detailed check of nhsdg.co.uk, we’ve also assessed that it would be a disproportionate burden within the meaning of the No. 2 Regulations to fix all documents published on nhsdg.co.uk since 23 September 2018.  

As of 1 August 2023, 578 documents (PDF, Word, Excel, PowerPoint) have been uploaded to our website since its inception. Of these documents: 

  • 563 are in PDF format, of which 506 have been published since 23 September 2018 
  • 15 are Word documents, of which 12 have been published since 23 September 2018 

Most of these documents have never been viewed by humans, so they are not negatively impacting users with disabilities or impairments. For this reason, we don’t believe the cost of time, effort and resource to fix all the documents is justified.  

Instead, we have focussed on fixing only those PDFs that have been viewed by humans between 1 September 2022 and 1 August 2023. Our external contractor has informed us that 103 separate PDFs were accessed during this period, and of these 24 were accessed by humans – the rest were accessed by bots, for example crawlers indexing the documents for search engines. 

In the case of papers presented to the Integration Joint Board, we have chosen, at the Board’s request, not to add any new material that was not present when the papers were originally presented and approved by the Board. This includes alternative text attached to images, as recommended under WCAG 1.1.1. 

In future, we will ensure that new documents uploaded to the website are accessible where they are required for essential services or used by people with disabilities.  

Estimated costs  

Paying for detailed audits  

We have assessed that it could cost between £6,500 and £39,000 for an external expert to do a detailed check (and later re-audit) on our website. 

These costs are based on estimates from GOV.UK’s guidance on deciding how to check your website and getting an accessibility audit. This includes: 

  • A third-party day rate of £1,300 
  • About 5 to 20 days to audit a large website 

Cost of fixing documents  

It’s difficult to know how long it would take to make every document accessible without first reviewing each one. An informal estimate with an external contractor produced an estimate of US$7-9 per page to make all PDF documents accessible – this would lead to an estimated total cost of $20,000-$30,000 (£16,000-£24,000) for the entire corpus, depending on estimated average document length. Making PDF documents accessible ourselves took from 30 minutes and 8 hours per document, depending on length and complexity. Further to this, some documents will require approval of accessibility changes from the original authors, where alternative text is used to describe graphs and other visual elements. For this reason it was decided to limit accessibility work to those documents accessed in the last 12 months.   

Assessment of costs and benefits 

We believe that: 

  • The costs of paying for detailed checks and fixing all documents on nhsdg.co.uk would be a disproportionate burden on our organisation 
  • The benefit to users of paying for detailed checks and assigning staff or external contractors to fix all documents on nhsdg.co.uk (taking into account the low level of usage for most documents) would not be justified and would impose a disproportionate burden on NHS Dumfries and Galloway. 

In reaching this decision, we have considered the following: 

Our organisation’s size and resources 

NHS Dumfries and Galloway Council is a local health board managing increasing front-line service demands set against limited budgets and a significant budget deficit. 

During 2020-2021 the coronavirus (Covid-19) pandemic placed considerable additional pressure on our resources, and, in common with other health boards, we are still facing a backlog of long waiting lists for treatment.  

The nature of our organisation 

We do provide services aimed at people with a disability, but these are generally included on our main website, nhsdg.co.uk. We do not have a separate website covering these services. 

The estimated costs and benefits for our organisation: in relation to the estimated benefits for people with disabilities, taking into account the frequency and duration of use of the independent websites 

We believe the potential of paying up to £39,000 on audits (before we have done anything to fix the issues identified) is unreasonable.  

We believe that: 

  • Maintaining statutory and essential front-line services should be prioritised over paying for independent website audits 
  • It would be reasonable within the meaning of the No. 2 Regulations for our services to carry out basic checks of their independent websites and use any available budget to fix the main issues found on their sites 

Our services will be assisted in their basic checks by: 

  • Accessibility monitoring software (Adobe Pro) 
  • Guidance from the external web design agency 

Our communications team is leading the check of nhsdg.co.uk. However, this is a small team with many other responsibilities and therefore lacks the capacity to carry out a full manual check of every page on our site. 

How much users with a disability would benefit from making things accessible 

Our users would benefit from us making our website and online documents accessible, providing inclusive access to our documents and, hence, easier access to health care. 

However, we do not believe that for most of our websites the extra improvements that could be gained from paying for a detailed check would justify the cost over doing a basic check internally. And fixing thousands of documents that no one views or downloads is not a good use of resource. 

We also believe that users will benefit most from us focussing our available resources on fixing the most used documents on nhsdg.co.uk (under way), continuing to fix any outstanding accessibility issues as outlined in our accessibility statement, and ensuring that newly created documents are accessible. 


Where possible, we can provide accessible formats of any documents on request. In addition, if you spot an accessibility improvement on nhsdg.co.uk or want to chat to us about our ongoing work to improve the accessibility of our website, please contact dgcommunications@nhs.scot 

Last update 

This statement was prepared on 30 August 2023 and published on 25 October 2023