Cookie Policy  

Information about our use of cookies

Why we do not use a cookie banner

You may have noticed that this website does not display a cookie banner. That is not an oversight. It is a deliberate decision.

As accessibility specialists, we have tested many websites with people with disabilities. Our experience of cookie banners and consent management platforms has frequently been poor.

We have encountered cookie banners that keyboard users cannot operate properly, controls that make it difficult or impossible to reject individual cookies, interfaces that create significant barriers for screen reader users, and implementations that can make the underlying website extremely difficult or sometimes impossible to use.

For someone without a disability, a badly designed cookie banner may be an irritation. For a disabled person, it can become a barrier to accessing the website at all.

We do not believe that is acceptable.

Our approach: minimise cookies rather than create another barrier

Instead of adding a cookie consent interface simply because it has become commonplace, our approach is to minimise the cookies and similar technologies used by our website in the first place.

Where a technology can be avoided, we would rather avoid it than require somebody to negotiate another layer of controls before they can use the website.

This reflects a fundamental principle behind everything we do at Access by Design: people with disabilities should not have to overcome additional barriers to access information or services online.

UK rules governing cookies and similar technologies sit primarily within the Privacy and Electronic Communications Regulations, alongside UK GDPR. There are circumstances in which cookies and similar technologies can be used without consent, including technologies that are strictly necessary for a service and, subject to particular requirements, certain technologies used for statistical purposes or to remember appearance and functionality preferences.

Where consent is legally required for a particular technology, simply continuing to browse a website is not sufficient consent.

Our approach is therefore not to assume that every website needs a conventional cookie banner. We look first at what technologies the website actually uses, whether they are necessary, whether an exemption applies and whether there is a less intrusive and more accessible way of achieving the same purpose.

Accessibility and privacy should work together

We are particularly concerned by the assumption that compliance in one area should be achieved by creating a barrier in another.

Websites in the UK have obligations relating to privacy and electronic communications, but they also operate within a legal framework protecting disabled people's access to goods and services, including the Equality Act 2010. Businesses providing relevant services within the European Union may additionally have obligations under the European Accessibility Act.

We do not believe privacy and accessibility should be competing objectives.

A privacy control that a disabled person cannot operate is not meaningful control.

Our position is therefore simple: we will not knowingly introduce an inaccessible cookie consent mechanism onto a website in the name of compliance. Where consent is required, the mechanism used to obtain that consent should itself be accessible.

Our experience has shaped our policy

In earlier years, websites commonly displayed a simple cookie notice explaining that cookies were being used. Cookie regulation and regulatory guidance have developed considerably since then, particularly around the standard of consent required for non-essential cookies.

At the same time, cookie consent systems have become substantially more complex.

Our accessibility testing has shown us the unintended consequences of that complexity. This is why we have deliberately chosen a different approach: minimise unnecessary tracking, be transparent about the technologies we use and avoid placing unnecessary barriers between people and content.

It is the same approach we recommend to our clients.

Controlling cookies and analytics yourself

Modern browsers provide controls that allow you to manage cookies and other stored website data. Depending on your browser, you can usually block or delete cookies, restrict third-party cookies and control how websites store information on your device.

Google also provides a Google Analytics Opt-out Browser Add-on. Once installed, this prevents Google Analytics from using information about your visits to websites that use Google Analytics. This gives you a way to opt out of Google Analytics across websites, rather than having to make the same choice separately on every website you visit.

Please be aware that the Google Analytics Opt-out Browser Add-on only applies to Google Analytics. It does not prevent websites or other analytics services from collecting information in other ways.

You can also use the privacy and cookie controls built into your browser to exercise greater control over what information websites are permitted to store.

Please be aware that blocking cookies that are technically necessary for a particular service may prevent some website functionality from working correctly.

Putting disabled people first

Accessibility is not something we add after a website has been built. It influences the decisions we make about the technologies we use in the first place.

That includes cookies.

If the choice is between adding unnecessary tracking and another layer of controls for visitors to navigate, or designing the website so that neither is necessary, we choose the simpler and more accessible website.