Introduction
French Decree No. 2019-768 of July 24, 2019 relating to the accessibility to disabled persons of online public communication services,1 published on July 25, 2019, sets out the accessibility obligations applicable to the websites of all French entities with revenues above €250 million.
Accessibility in du Crédit Mutuel Alliance Fédérale’s digital strategy
We make digital accessibility a core concern when developing and providing websites or mobile applications to our customers and our internal personnel, this being a core element of du Crédit Mutuel Alliance Fédérale’s policy on the integration of disabled persons.
Structures dedicated to accessibility
A dedicated accessibility unit has been set up at the group's IT subsidiary, Euro-Information.
The team works on several aspects of accessibility:
- ensuring that the processes required to take accessibility into account are established, implemented and maintained;
- reporting to management on accessibility levels and any areas for improvement;
- promoting awareness of accessibility requirements;
- managing internal and external compliance checks;
- providing assistance with all problems related to accessibility;
- acting as the first point of contact for matters relating to digital accessibility.
In addition, each du Crédit Mutuel Alliance Fédérale entity responsible for its own content will in the future have its own assigned accessibility officer to oversee these tasks.
Training and awareness-raising
E-learning modules will be offered to raise awareness among all developers, authors, webmasters, project owners, organizers, UX Designers, etc.
Training modules will be offered by the training department based on profile, and will be included in the ongoing training catalog.
Basic training on accessibility will be offered to all developers.
More advanced training will be offered to the developers of components and thick-client applications and to accessibility officers.
Accessibility requirement concerning external software
As far as possible, we insist that all external solutions are made accessible before being integrated into our application system.
User support
We advise all users who encounter an accessibility problem to report it via the contact details on the website.
All problems reported are systematically dealt with as soon as possible by the internal error management system.
Compliance work
Accessibility within projects
As a result of the measures to raise awareness and by dint of a gradual increase in expertise, digital accessibility will become a factor that is incorporated into projects right from the beginning.
Information and learning resources will be made available to everyone involved in this matter:
- an internally developed tool for checking that certain criteria outlined by the RGAA (French government guidelines on improving accessibility) are complied with;
- at least one screen reader available for testing web pages;
- a specialized support unit.
The majority of our website and intranet site developers work with an internal framework.
The existing components of this framework will be reviewed with a view to complying with accessibility requirements; new components will automatically incorporate accessibility rules.
The templates (elements other than the main content) of the websites are managed by the same team which will receive specific training on accessibility. This team also manages all of du Crédit Mutuel Alliance Fédérale’s graphics standards and thus takes charge of several accessibility criteria.
Internal tools are used to generate certain web content or Word and PDF documents. They will be examined with a view to generating accessibility elements.
Audits
Throughout the year, rapid assessments of the accessibility of future applications or updates will be conducted on request, or systematically for major applications.
These assessments will be carried out by in-house accessibility experts. They will cover a limited number of the RGAA version 4 criteria, selected on the basis of their relevance to the context of the application and criticality of the requirement.
The largest and most important websites of the du Crédit Mutuel Alliance Fédérale entities in France will be audited by an external body in order to establish a compliance level. Where possible, the other sites will be audited by an in-house expert. If this is not possible, an external body will be used.
The frequency of these audits will range between once a year and once every three years.
Corrective measures
All nonconformities detected during the audits or rapid assessments will be classified as critical, major or minor, depending on their severity level. As far as possible, critical nonconformities will be treated as a priority, as will those identified as quick and easy to correct.
A team responsible for correction will be set up for each one. Standardized correction requests will be created for this purpose.
Annual action plans
Compliance work and digital accessibility activities are set out in annual action plans.
| Actions | Provisional date of implementation |
|---|---|
Publish official pages
|
3/24/2021 |
| Make documentation on accessibility available (community)
Input information on the subject into a database Provide advice on coding, writing Provide technical memos, etc. |
Q1 2021 |
|
Organize an accessibility audit Research and select an external auditor Carry out the audit on the website and related mobile application. |
Q1-2021 |
| Raise awareness of accessibility among all parties (community) Disseminate the awareness e-learning module to all affected parties. |
Q2 2021 |
| Correct nonconformities Assign nonconformities to the appropriate teams Correct nonconformities that are classified as critical and those that are identified as quick and easy to correct. |
Q2-2021 |
| Carry out a follow-up audit To check that the areas flagged during the first audit have been corrected. |
Q3-2021 |
| Indicate the compliance level on the website Modify the site template so that this information can be added. |
Q3-2021 |
| Update the tools that generate web content (community) To ensure that the content created is accessible. |
Q4 2021 |
| Implement accessibility training Training for experts on website assessment Advanced developer training Basic level training for the majority of developers Training for content writers |
Ongoing |
| Action | Provisional date of implementation |
|---|---|
Update official pages
|
Q1-2022 |
| Update the tools that generate web content (community) To ensure that the content created is accessible. |
T2 2022 |
| Make documentation on accessibility available (community) Input information on the subject into a database Provide advice on coding, writing Provide technical memos, etc. |
Ongoing |
| Raise awareness of accessibility among all parties (community) Disseminate the awareness e-learning module to all affected parties. |
En continu |
| Implement accessibility training Training for experts on website assessment Advanced developer training Basic level training for the majority of developers Training for content writers |
Ongoing |
| Monitor publication of the implementing decree for international application (community) To support our foreign subsidiaries. |
Ongoing |
Action overview
| Action | Provisional date | Completion date |
|---|---|---|
Create a model of official pages (community)
|
Q2 2020 | September 2020 |
| Provide information on Decree No. 2019-768 of July 24, 2019 on digital accessibility (community) Present the impacts and obligations of the decree to a certain number of key people who will disseminate the information. |
T2 2020 | June 2020 |
| Make documentation on accessibility available (community) Input information on the subject into a database Provide advice on coding, writing Provide technical memos, etc. |
From May 2020 Then ongoing |
Ongoing |
| Raise awareness of accessibility among all (community) Research/create and implement an e-learning module. Disseminate the awareness e-learning module to all affected parties. |
From Q4 2020 Then ongoing |
Postponed until 2021 |
| Make accessibility training available (community) Research training for different profiles (website assessment experts, developers of components, mobile applications and thick-client applications, standard developers) or create training courses. Enhance the ongoing training catalog. |
Q3 2020 | Q1 2021 |
| Action | Completion date | Provisional date |
|---|---|---|
|
Draw up a framework memorandum (community) Prepare a document presenting the action to be carried out and the impacts of this law |
Q4 2019 | January 2020 |
| Draw up a list of Crédit Mutuel Alliance Fédérale’s French entities concerned by the legislation (community) Determine which of Crédit Mutuel Alliance Fédérale’s French entities with a website and mobile application have revenues above €250 million. |
Q4 2019 | Defer until 2020 |