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Disproportionate burden

This section of the statement identifies issues that we are aware of but are not able to fix at present. For each issue identified, we've undertaken an assessment of the extent of the issue, and deemed that the cost of fixing these issues is a disproportionate burden.

PDFs and other documents

As with all local authorities, we publish many documents each year that are created both within our council and provided by third parties.

As of 31 March 2025, 1033 PDF documents have been uploaded to the websites covered in this accessibility statement on or after 23 September 2018.

Of the 640 documents our automated scanning tools have identified published on our main www website 517 do not meet the required accessibility standard. Most of these documents are to be found on pages further into our site and would have likely received very few views which will not adversely impact users with disabilities.

Further documents have been uploaded to our various web portals.

Our experience had identified that PDF accessibility checking tools are inconsistent in identifying accessibility issues affecting PDF and source documents. For example, Microsoft Word's accessibility checker can identify text contrast issues that cannot be identified using the Adobe Acrobat PDF accessibility checker.

Cost of fixing PDF documents

Without reviewing the documents individually, we are unable to calculate exactly how long it would take to fix these issues. This is because each document varies in length and complexity, along with the number and type of issues that are present. Some documents may also require reproducing if we no longer have access to the original source document(s).

Based upon past experiences of fixing accessibility issues within existing documents, we estimate that it would take approximately three hours to apply the necessary changes to fix each document in scope to meet current accessibility requirements.

Using this figure, one employee would be able to update an average of three documents per working day which would be the equivalent of allocating 100% of a full-time staff member for 246 days.

Assessment of cost and benefit

  • we believe that the cost of fixing all documents would be a disproportionate burden on our organisation
  • we don't believe the cost of time and effort that would be required to update each of these PDFs to be appropriate and/or justified
  • we believe that this time would be better invested in fixing outstanding accessibility issues present across the website which would be of greater benefit to our customers
  • we believe that we should first prioritise fixing issues that are present within the most popular documents used by our customers

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