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Disproportionate Burden Assessment


This assessment applies to two sections of our website that hold PDF documents produced between September 23rd, 2018 and September 28th, 2023: our board meetings and key documents pages and the Freedom of Information Act (FOIA) section.


Out of scope

The accessibility regulations do not require us to fix PDFs or other documents published before September 23rd2018 if they are not essential to providing our services. We do not plan to fix any PDFs or other documents published before September 23rd, 2018 for example board and committee papers, health board policies and procedure documentation or statutory documentation such as annual reports.  However, we will endeavour to make any new PDFs or Word documents accessible wherever possible.

We occasionally publish PDFs which contain ‘transcripts/scanned manuscripts or handwritten notes’ for example in FOIA requests - these are outside of scope and will not be fixed.



Recreating those PDFs that are in scope into Word documents would make recent and past information and statistics more accessible.



We have conducted an objective assessment of the resources required to convert those PDFs that are in scope into accessible Word documents and examined that in the context of the resources available and the number of users who may benefit.

Our assessment found:

  • Since January 2022 alone more than 1,000 PDF documents have been uploaded as board papers and in response to FOIA Requests. There are an average of 55 health board meetings each year, which require up to 50 PDFs to be uploaded to the website.
  • Since April 2019 approximately 4,584 PDF documents have been uploaded as FOIA responses. There are on average around 550+ FOIA requests each year, which require approximately 1000+ PDFs to be uploaded to the website.
  • To remove each PDF identified above from the website, convert it into a Word document and re-upload it would prove an unsustainable additional burden on teams in terms of human resource, time and cost.
  • This is based on current experience of uploading documents, the size of corporate governance and FOIA teams and the impact on the health board budget of employing agency staff to back fill while team members are taken away from their current role for significant periods of time to do the conversion work.
  • In the context of the wider website and based on Google Analytics, we can see that only a small number of users access the pages that contain links to the PDFs.
  • We are unable to give statistics on the numbers of page views or users of the PDFs themselves due to the limitations of Google Analytics.


Other factors
  • We will provide accessible versions on request. To request accessible copies of board and committee papers and other key documents email    To request accessible copies of responses to Freedom of Information Act requests email
  • We will upload board and committee papers, other key documents and responses to FOI requests in Word format from September 28th 2023.


  • Based on the assessment we have carried out we consider converting documents which are of limited interest and which, in many cases, no longer represent the current position to be a poor use of limited staff time and represent a disproportionate burden on the organisation in terms of cost.



Preparation of this assessment

This assessment was prepared in September 2023.



Rydym yn croesawu gohebiaeth a galwadau ffôn yn y Gymraeg neu'r Saesneg. Atebir gohebiaeth Gymraeg yn y Gymraeg, ac ni fydd hyn yn arwain at oedi. Mae’r dudalen hon ar gael yn Gymraeg drwy bwyso’r botwm ar y dde ar frig y dudalen.

We welcome correspondence and telephone calls in Welsh or English. Welsh language correspondence will be replied to in Welsh, and this will not lead to a delay. This page is available in Welsh by clicking ‘Cymraeg’ at the top right of this page.