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 CIC Market Solutions'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 CIC Market Solutions'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 CIC Market Solutions 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 CIC Market Solutions'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 CIC Market Solutions 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.

2021 action plan
Actions Provisional date of implementation
Publish official pages
  • Support and accessibility
  • Accessibility statement
  • Multi-year plan
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
2022 action plan
Action Provisional date of implementation
Update official pages
  • Multi-year plan
  • Accessibility statement
  • Multi-year plan
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

2020 action plan
Action Provisional date Completion date
Create a model of official pages (community)
  • Support and accessibility
  • Accessibility statement
  • Multi-year plan
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.
Q2 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
2019 action plan
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 CIC Market Solutions French entities concerned by the legislation (community)
Determine which of CIC Market Solutions French entities with a website and mobile application have revenues above €250 million.
Q4 2019 Defer until 2020