Introduction

Decree No. 2019-768 of 24 July 2019 on accessibility of online public communication services to persons with disabilities, published on 25 July 2019, sets out the obligations regarding accessibility of websites, intranet and mobile applications of all French entities in the COFIDIS group whose turnover exceeds the millions of euros 250.

Accessibility in the Cofidis digital strategy

Digital accessibility is at the heart of the concerns related to the development and availability of websites or mobile applications to both our customers and our internal staff, thus participating in COFIDIS' policy in favor of the integration of people with disabilities.

Facilities dedicated to accessibility

This position is expressed by the setting up of an accessibility reference center in the group's it system subsidiary, Euro-information.

This team works on several fronts; it :

  • Ensure processes necessary to address accessibility are established, implemented and maintained
  • Reports to management on the level of accessibility and any need for improvement
  • Ensure awareness of accessibility requirements is promoted
  • Manages compliance controls (internal or external)
  • Provides support for accessibility issues
  • Is the single point of entry on digital accessibility topics.

In addition, each COFIDIS entity managing its own content will eventually have an accessibility referent responsible for the same tasks, limited to its entity.

Training and awareness

E-learning modules will be offered to raise awareness among all developers, editors, webmasters, project owner, organizers, UX Designers, etc.

Depending on the profiles, training modules will be offered by the training service and will be included in the continuing education catalog.

Basic accessibility training will be offered to all developers.

More advanced training will be offered to developers of components, heavy client applications and accessibility referents.

External Software Accessibility Requirement

We will require that, wherever possible, any external solution be accessible for integration into our application fleet.

User Support

Any user who encounters an accessibility problem should report it via the site's contact means.

An internal anomaly management system allows for the timely and systematic consideration of any identified problem.

INTERNET, INTRANET AND MOBILE APPLICATION COMPLIANCE WORK

Accessibility within projects

Through awareness-raising measures on digital accessibility and progressively as skills are developed, this will be taken into account from the start of a project.

Knowledge and learning resources will be made available to all actors on the subject :

  • documentation available from a portal dedicated to digital accessibility on the Intranet of COFIDIS entities
  • an internally developed tool to verify that a number of GAIR criteria are met
  • at least one screen reader available for testing web pages
  • a dedicated support cell

Most of the developers of our websites and intranet work with an internal framework.

The latter shall make available components which shall be reviewed in order to meet accessibility requirements; new components automatically incorporate accessibility rules.

The templates (parts apart from the main content) of the websites are managed by a single team that will be trained particularly in accessibility. This team also manages all COFIDIS chart charters, thus supporting several accessibility criteria.

Internal tools are used to generate certain web content or documents in Word, PDF format. They will be studied to generate accessible elements.

Audits

Throughout the year, rapid assessments of the accessibility of future applications or update will be carried out on demand, or systematically for major applications.

These checks will be carried out by internal accessibility experts. These assessments will focus on a reduced number of GAIR Version 4 criteria, selected for relevance based on the context of the application and the blocking level of the requirement.

The main or significant sites of the French COFIDIS entities will be audited by an outside body in order to establish a level of compliance.

Other sites will be audited by an internal expert if possible; if not, an external body will be used.

The pace of these audits will vary from 1 time per year to 1 time every 3 years.

Corrective measures

All non-conformities identified by the audit or quick check will be classified according to their severity level: blocker, major, minor.

Where possible, blocking data will be treated as a matter of priority as well as those identified as quick and easy to correct.

For each, a team responsible for its correction will be identified. Standard correction requests will be created.

Annual action plans

Compliance work and digital accessibility actions are planned annually in action plans.

Action Plan 2022

Actions Estimated implementation dates
Current Website
Correct non-conformances. Continuous
Update the official page(s). Q1 2022
Miscellaneous Actions
Train site evaluation experts, developers, content writers. Continuous
Community action
Update web content generation tools to make content created accessible. Q4 2021

Raise awareness of accessibility among all stakeholders.

Disseminate the awareness-raising e-learning module to all relevant stakeholders.

Continuous

Review components.

Cross-cutting review of the accessibility of components used by developers; for non-audit components

Current 2021

Audit mobile apps (iOS and Android)

2022

Action Plan 2021

Actions Estimated implementation dates
Current Website
Perform a site accessibility audit. Q1 2021
Correct non-conformances. Current 2021
Perform a cross-audit of the accessibility of the site. Q4 2021
Mention the site's compliance level. Q1 2021
Community action
Update web content generation tools to make content created accessible. Q4 2021

Raise awareness of accessibility among all stakeholders.

Disseminate the awareness-raising e-learning module to all relevant stakeholders.

Continuous

Review components.

Cross-cutting review of the accessibility of components used by developers; for non-audit components

Current 2021

Action Plan 2020

Actions Estimated implementation dates

Create a template for official pages

  • Help and Accessibility
  • Accessibility Statement
  • Multiannual outline
Q3 2020

Inform on decree n°2019-768 of 24 July 2019 on digital accessibility

Present the impacts and obligations of the Digital Accessibility Order to a number of key individuals who will disseminate the information.

S2 2020
Make Accessibility Documentation Available From May 2020
Continuous
Actions Estimated implementation dates

To feed a knowledge base on the subject.

Provide technical memos, ...

Training in accessibility.

Train site assessment experts.

Train developers at an advanced level.

Provide basic knowledge for the majority of developers.

Train content writers.

From Q4 2020
Then Continuous

Publish official pages

  • Help and Accessibility
  • Multiannual outline
  • Accessibility Statement
October 2020

Organize an accessibility audit.

Find and select an external auditor.

Q4 2020