It's a 26 page document of common sense and technical best practice wrapped up in politically correct bureaucratese and threats about legal imperatives. It isn't available on the internet ("distribution will be via e-mail and uncontrolled").
The document begins by setting accessibility in the context of HMRC's "Diversity and Equality Policy", the aims of which are enumerated.
- Recognise that barriers may still exist in society and in the workplace that would hinder the progress of particular groups and to act positively to ensure that these are eliminated from all HMRC policies and processes.The tone is set.
- Use the knowledge and skills of our diverse workforce to increase compliance and customer satisfaction and better understand the customers’ needs and viewpoint.One of the most galling things about HMRC is their insistence on calling their victims 'customers'.
Customers are people who freely choose to exchange something they have for something they want. Taxpayers are people who are forced to surrender a portion of their earnings, under pain of imprisonment.
- Employ a diverse workforce that represents the community we serve, helping us to develop our policies and practices in ways that are appropriate to different customer groups.If HMRC were a real business, with real customers, they would be driven to hire the best people for the job. Any 'diversity' that arose would be incidental, and incompetents would be underrepresented.
It is a strange sort of 'service' that HMRC do for 'the community', but if we are to be robbed, we should at least demand to be robbed as efficiently as possible.
Employing a workforce that "represents the community" should not come into it.
- Value our people as individuals who have a unique contribution to make to HMRC’s success. Use our differences in positive ways to promote an inclusive environment for our employees and customers.If HRMC truly valued people as individuals, they wouldn't lump them into "particular groups" and obsess about 'barriers' and 'inclusion'. They would award jobs and promotions based on merit and merit alone.
- Be the public sector’s employer of choice, attracting and retaining the best from the widest pool of talent and developing our people to the level of their potential and inclination.The public sector's employer of choice! Such ambition!
- Eliminate any unjustifiable discrimination against anyone for any reason, including race, ethnic origin, religion, nationality, sex, sexual orientation, working pattern, marital status, gender reassignment, disability or age. In Northern Ireland, to eliminate any unfair discrimination because of political opinion.At this point you may be wondering what race, ethnic origin, religion, nationality, sex, sexual orientation, marital status, and gender reassignment have to do with IT Accessibility Standards.
You may also be wondering why discrimination based on "political opinion" is acceptable in England, Scotland, and Wales.
As for "working pattern", your guess is as good as mine. Of all the possible variations between individuals, this is the one that should most uncontroversially be open for discrimination by employers. Want to work from home? Want to work 2 days a week? Want to work from 6 to 2 or from 4 to midnight? Want to work only on those days that you're feeling physically and mentally tip-top? Fine: go out and find an employer who values your services enough to accommodate your working preferences. But if you can't find such an employer, or if your current employer proves "inflexible", don't cry discrimination! Nobody has a right to a job, much less a right to a job on their own terms.
-Monitor and evaluate our progress to ensure we are meeting our targets and legal responsibilities.We can only speculate about what these targets may be.
On page 6, we are introduced to the The Disability Discrimination Act:
According to the Act, a disabled person is generally someone with a physical or mental impairment, which has a substantial adverse effect on his or her ability to carry out normal daily activities over a long period. It also covers people who have had such a disability in the past.It is so natural for us to pity disabled people, to regard them as victims in need of protection, and unfortunates in need of support, that most people will read those two paragraphs without flinching. Even highly principled libertarians, who in other circumstances are quick to condemn "positive discrimination", stay strangely silent. I must truly be a cold-hearted bastard, because I find this staggering.
The DDA makes it illegal for employers and service providers to treat disabled people less favourably than they would treat people without impairment, for a reason related to their disability, when recruiting or employing individuals, or offering or providing goods, facilities or services, or (from December 2006) delivering public functions.
Here we have recognition of "a substantial adverse effect on his or her ability to carry out normal daily activities" coupled with a prohibition on "less favourable" treatment. It is one of the most baldly unmeritocratic statements I've ever seen.
Life is unfair. People are different. Some are "more able" than others.
The best we can hope for is that we will be judged not based on our race, ethnic origin, religion, nationality, sex, sexual orientation, marital status, gender reassignment, political opinion, or age, but instead on our ability. If I am intelligent, pragmatic, sociable, healthy, and industrious, I should be free to enjoy the fruits of my labour, and no-one should begrudge it. If I am stupid, distractible, antisocial, sick, or lazy, my ability to deliver value is impaired, and nobody should suggest that I deserve remuneration beyond my contribution.
If I can work, but only for 5 hours a day, I shouldn't expect to be paid for 7.5. If I can produce something useful, but slower than my colleagues, I shouldn't expect to be paid the same. If I can do a job, but only with the aid of special equipment, I shouldn't expect my employer to bear this cost. If I have special talents, which compensate for my disabilities, I will find employment without recourse to legal imperatives.
The requirements placed by the DDA on "service providers" are equally abhorrent. A shopkeeper should decide for himself whether to make his shop wheelchair accessible, according to his own economic calculations and personal sense of moral duty. Authors of software and websites should decide for themselves how much to cater for people with visual impairments, and those unable to operate a mouse. Accessibility may not cost the world, but nor is it free. I have no right to your products and services, any more than I have a right to demand from you a job.
But in Britain today, if your particular physical or mental impairment has a government-approved label, you are entitled to special treatment. A swollen public sector confuses charity with public service. An army of bureaucrats produce guidelines on what constitutes "reasonable" discrimination and "reasonable" steps towards accommodation. An army of lawyers will help you fight for your rights, and they're happy to settle out of court. It is wrong.
Yes, there is such a thing as compassion, but it is incompatible with compulsion.