Digital Transition Manager (DTM) in schools and the accessibility statement: example of DTU communication and statement

The accessibility statement can and should be considered the tool through which the public administrations, and also our schools, publish the accessibility status of each website and mobile application they own. And it is clear that all schools now have one, and in many cases these educational institutions gain great visibility and implementation of the organization.

Schools prepare the declaration and then publish it exclusively using the online application available on the National Government website at the link Compliance with the accessibility declaration form is guaranteed solely by completing the online form from AGID.

Activities required before completing the declaration

As is known, art. 17 of the Legislative Decree of 7 March 2005, No. 82, “Digital Administration Code” (hereinafter “CAD”), last amended by Legislative Decrees No. 179 of 2016 and No. 217 of 2017, stipulates that the public administrations “guarantee the implementation of the strategic lines for the reorganization and digitalization of the administration defined by the government” and also that “they attribute to a superior management office the implementation of the strategic lines for their reorganization and digitalization”. The rule therefore stipulated that among the activities necessary before completing the declaration, there should be the appointment of the head of the digital transition (FTU). Then also having indicated on the PA index (IPA) the email from the RTD of one’s administration; without this e-mail published on IPA, it is not possible to access the application and therefore it is not possible to send the statement (in the case of schools, the institution’s e-mail address will be taken into account as indicated on IndexPA ).

However, the Ministry of Education has with its own Note-MI of prot. 2260 of 05-12-2019, it was stated that “In light of the relationship behind art. 17 of the DAC and with particular reference to the provisions in subsection 1-septies of the same on the possibility of exercising the RTD functions in an associated form, the administration – also after discussions with AGID – has found it appropriate that the Digital Transition of MIUR also plays this role for schools and educational institutions. The Directorate General for Contracts, Procurement and Information Systems and Statistics is already dealing with, among other things, the planning and implementation of strategic lines for digitization of the Administration and School Processes This solution is therefore aimed at improving the technological development interventions already undertaken by the administration in line with MIUR’s role as the enabling entity for the digital transformation path of the education sector.

The numbers and organizational functions already planned and operational in the schools (e.g. digital animators; digital innovation team, etc.) will also work in synergy with the centralized coordination of the RTD for a participatory implementation of MIUR’s strategic guidelines. Taking into account the above, schools and educational institutions that may have appointed an FTU are encouraged to adapt to what is indicated in this note and accurately cancel the agreements made, recognizing the FTU for MIUR as the sole responsible for digital transition” .

FTU’s coordination tasks

Art. 17 of the DAC precisely regulates the figure of the “Digital Transition Manager”, who is assigned important coordination and impulse tasks for the restructuring of services, such as in particular:

  1. strategic coordination of the development of information, telecommunications and telephone systems to ensure compliance with common technical and organizational standards;
  2. managing and coordinating the development of both internal and external services provided by the administration’s telecommunications and voice information systems;
  3. guidance, planning, coordination and monitoring of IT security in relation to data, systems and infrastructures also in relation to the public connection system in accordance with the technical rules mentioned in Article 51, subsection
  4. disabled people’s access to IT tools and the promotion of accessibility also when implementing the provisions of Act No. 4;
  5. periodic analysis of the relationship between the organization of the administration and the use of information and communication technologies in order to improve user satisfaction and the quality of services, as well as to reduce the time and costs of administrative actions;
  6. cooperation in revising the reorganization of the administration for the purposes mentioned in letter e);
  7. managing, coordinating and monitoring the planned planning for the development and management of telecommunications and voice information systems;
  8. planning and coordination of relevant initiatives with a view to a more efficient delivery of online services to citizens and businesses through the tools for application collaboration between public administrations, including the preparation and implementation of service agreements between administrations on the creation and sharing of cooperative information systems;
  9. promotion of initiatives regarding the implementation of the directives given by the President of the Council of Ministers or by the Minister of Innovation and Technologies;
  10. planning and coordination of the process of dissemination, within the administration, of e-mail systems, IT protocol, digital signature or qualified electronic signature and IT mandate, and of the rules on accessibility and usability.

An example of an RTD appointment

The article presents an excellent model for the “Appointment of RTD” developed by Head of School Lucia Barbieri at the head of the Comprehensive Institute of Borgo Virgilio (MN). The same, as already in the introduction to the previous section, refers to the ministerial note on appointing the Director General of the Directorate General for Contracts, Procurement and for Information Systems and Statistics for MIUR as responsible for the transition to the digital mode of operation, who is entrusted with the resulting reorganization processes, directed towards the creation of a digital and open administration, of easy-to-use and quality services, through greater efficiency and cost-effectiveness.

Accessibility check of websites and mobile applications

The schools’ task is also to “carry out accessibility checks of websites and mobile applications by adopting the methods, the evaluation criteria and the technical checks of compliance with the accessibility requirements according to EU directive 2016/2102. AGID makes, to facilitate the work of the PAs, available to the administrations a tool “Accessibility Self-Assessment Model”, Annex 2 of the guidelines for accessibility of IT tools, useful to determine the state of conformity of the website and/or application mobile, the outcome of which can be: Compliant, partially compliant or non- compatible”.

Provide and make a “feedback mechanism” available

The legislation also stipulates that educational institutions must necessarily equip themselves and provide a “Feedback Mechanism”, which the PA must indicate in the accessibility statement, to allow users to report cases of inaccessibility.

How do you fill out the declaration of availability? What needs to be done?

The administration continues to complete the declaration of accessibility at At the first access, it is necessary to request the credentials. Elements that all schools eventually have at their disposal. The statement consists of two macro sections.

The first section

The first section presents the content of the EU implementing decision 2018/1523:

  • Compliance status
  • Content statement, sections and functions are not available in case of partial or complete non-compliance
  • Indication of the feedback mechanism and contact details of the administration
  • Implementation procedure (Digital Ombudsman).

Second section

The second section instead consists of:

  • Information on the website or mobile application
  • Administration information.

Link must appear in the footer of the website

Once the declaration is completed, the PA will receive an email with a link to be displayed in the footer of the website or in the specific section of the store related to mobile apps.

The timing

No later than 23 September each year, all schools must review and, if necessary, update the content of the accessibility statement. Each availability statement is valid for one year from September 24 of the current year to September 23 of the following year.

Administrative default by the schools

Failure to publish the “availability declaration” is an expression of a breach of the law with the responsibility set out in art. 9 of Act No. 4/2004.

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