Council Advertising Network and Accessibility

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Consent Management Platform (CMP)

The CMP is powered by one of the top 5 CMP providers Quantcast. It has been designed to conform to the ICO specifications and regulations. Unfortunately the ICO and also the government failed to specify that CMPS had to meet a specific level of accessibility so because of this the CMPs fall into the third party category so something that is supplied by a third party supplier and you have no control over the building of it. That said our supplier has made a lot of changes to the system, you can navigate through the original pop up so you can select links, and action any of the buttons including accept. The main pop up box again is navigable via keyboard. You are correct the close ‘X’ is not keyboard selectable and we will mention this to Quantcast to look at but the user can close the pop up by choosing the save/exit button. 

There is an issue with keyboard selection of the privacy button in the bottom right hand corner which has been fed back to Quantcast.

With regards the advertising, advertising forms part of the third party supplier rules as councils/government have no control over the build of this technology/service so it is exempt from any accessibility assessment. To ensure adverts meet colour contrast regulations and if animated do not flicker or loop a range of automated and manual checks used by the delivery platform and CAN. Any adverts specifically created by CAN on behalf of the council or by the council itself are checked by CAN to ensure they meet guidelines. 

Issue and description

Where the issue was found


WCAG 2.1.1 Keyboard


Users should be able to use a keyboard to access all content and functionality of a web page. This means the page can be used by people with no vision as well as people who use alternative keyboards or input devices that act as a keyboard.




•       Privacy value is not accessible using the keyboard as Accept and other options cannot be selected

•       Smart testing pop up box is not accessible and cannot be closed using the keyboard. remove

This refers to the consent pop up
We have tested the initial pop up and the other main pop up if a user wants to make more choices and all the elements can be tabbed through via the keyboard There is an issue with the ‘X’ on the main pop up which has been highlighted with the supplier but the box can be closed by using the save button.

WCAG 2.4.7 Focus visible


A visible focus helps users know which element has keyboard focus and where they are on the page.


When an element gets focus there should be a visible border around it. Highlighting the element that has keyboard focus or is hovered over can provide information like whether the element is interactive or the scope of that element.


Operating systems have a native indication of focus, which is available in many browsers. The default display of the focus indicator is not always highly visible and may even be difficult to see especially on coloured backgrounds.

This is on all webpages


•       Focus is not clear on privacy settings button in the right hand bottom corner

This is a known issue and is currently being investigated by the supplier

WCAG 2.4.1 Bypass Blocks, 4.1.2 Name, Role, Value

A frame title describes the content of the frame. Screen readers can understand this and help users move through frame elements quickly by using an option to select a list of titles for all frames on the page.


A descriptive, meaningful and unique title allows users to find the frame they need. Ensure all frame and iframe elements have useful <title> attribute values.

Home, Report



•       This refers to Element location
#google_ads_iframe_\/31781941\/can_haltonbc_0 and Element location

To solve this issue, you need to fix the following:
Element's title attribute is not unique

Due to how the advertising is constructed and delivered we have no control over the frame title nor can we add in a title to the delivery. This is one of the issues that is recognised and one of the reasons why advertising is classed as third party.

WCAG 2.4.4 Link Purpose (In Context), 4.1.2 Name, Role, Value

All link names should be accessible by a screen reader and be descriptive enough to tell a user where that link will take them. Common issues include:


•      the inner link text not being visible

•      duplicate link labels

•      the link not being focusable


All links should receive focus and link text should not be hidden as this will stop a screen reader from relaying the link information



Home, Contact, Bins and Recycling, Report


•       This refers to the coronavirus image

The iBar is old technology and therefore does not fully meet the guidelines but is still classed as third party. The ibar is primarily for councils own use so we can pause the delivery of this if you do not wish to use the iBar in its current form.