HMRC (Her Majesty's Revenue and Customs) is the UK government department that collects direct and indirect taxes and pays benefits to individuals. This means that most adults are users of its services and this also means that it needs to provide equality of service to every adult in the UK. In particular it means that its IT Services should be accessible to people with disabilities.

HMRC has been aware of this requirement for a long time but was keen to review the situation and recommend improvements in the systems used and the processes involved in commissioning and developing new systems.

The latest stage in this process is the publishing of ‘HM Revenue and Customs, IT Accessibility Policy, Draft Equality Impact Assessment for Consultation’. To quote from the HMRC announcement ‘We wish to consult both externally and internally with both representative bodies for disability groups and individuals to ensure that our approach meets their needs and to receive feedback on how our approach may be improved.’

I bring this to my readers' attention for two reasons:

• They may wish to send feedback as an individual or as a representative of an effected organisation (the closing date is 31 December 2007).
• It is a good example of the processes and documentation related to an accessibility assessment. The structure could be used as a template for an assessment in any organisation.

Having recommended it to my readers I feel it is incumbent upon me to add my own comments and criticism of the document:

• It is a thorough and well thought out document, it clearly describes the good and the not so good implementation of accessibility in HMRC.
• The twelve golden rules at the end are a helpful checklist that will help to avoid many accessibility problems.
• The document itself is published as an accessible PDF and includes a set of bookmarks for the chapter headings. Creating it in this format shows HMRC is thinking about accessibility at all levels. Having said that I would suggest some the following improvements:
  • Removal of redundant bookmarks (in some case two bookmarks point to the same place).
  • Add bookmarks for the level two headings (those starting n.m). By doing this the bookmarks give a very clear overview of the document and its structure (helping both understanding and navigation).
  • I assume the document was originally created in Word. It would help if the headings and sub-headings used styles as then the numbering would be correct (there are several errors in the numbering which certainly confused me; for example, there are three sections numbered 2.2).
• The Golden Rules section is very useful but I think it needs to be preceded by some more general definition of principles from which the Rules could flow, see my article Web Content Accessibility Guidelines 2.0 latest draft. I think the WCAG 2.0 principles: perceivable, operable, understandable and robust (POUR) would be a very useful addition to this document.
• The communication plan should be extended in two ways:
  • An accessibility statement (based on the accessibility policy) should be easily available to all users of the systems, as a way to communicate with the users what they can expect. See my article Accessibility Statement - What it should include.
  • A simple way to provide feedback should be included on every page of every system, with a specific category of accessibility.
• Finally a bit of pedantry, i.e. and e.g. are not interchangeable and have been used in the wrong way in several places in the document.

Overall this is an extremely useful document and shows that HMRC are taking the issue very seriously. It would be great to see other public bodies going through a similar process.