Accessibility & Digital Inclusion Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy sets out Global Talent Pathway’s commitment to providing accessible and inclusive digital services across its platforms and workforce operations.

Its purpose is to:

  • support equitable access to Global Talent Pathway services,

  • meet applicable accessibility and non-discrimination obligations,

  • align with Australian Government digital accessibility expectations, and

  • ensure accessibility is addressed in a practical, risk-based manner.

2. Scope

This policy applies to:

  • Global Talent Pathway websites, portals, and digital platforms,

  • candidate-facing and employer-facing digital services,

  • digital communications and online content,

  • staff, contractors, and suppliers involved in digital design, development, or content creation.

This policy applies across all jurisdictions in which Global Talent Pathway operates.

3. Policy Statement

Global Talent Pathway is committed to taking reasonable and proportionate steps to ensure its digital services are accessible to people with disability and other access needs.

Accessibility is considered an ongoing process and is addressed in line with:

  • legal requirements,

  • technical feasibility,

  • user needs, and

  • risk-based prioritisation.

4. Accessibility Standards

Where reasonably practicable, Global Talent Pathway aims to align its public-facing digital services with:

  • Web Content Accessibility Guidelines (WCAG) 2.1, Level AA (or successor standards), and

  • relevant Australian Government Digital Service accessibility guidance.

Alignment is pursued on a best-efforts basis, recognising that:

  • legacy systems may require phased remediation,

  • third-party platforms may limit control, and

  • not all accessibility issues can be resolved immediately.

5. Digital Inclusion Principles

Global Talent Pathway’s approach to digital inclusion is guided by the following principles:

  • Equitable access: users should be able to access core services regardless of disability.

  • Usability: interfaces should be clear, understandable, and navigable.

  • Flexibility: alternative access methods should be considered where appropriate.

  • Continuous improvement: accessibility issues are identified and addressed over time.

6. Reasonable Adjustments and Alternatives

Where a user is unable to access a digital service due to accessibility barriers, Global Talent Pathway will consider reasonable alternative access arrangements, which may include:

  • alternative communication formats,

  • assisted completion of forms,

  • support via email or telephone.

Requests for adjustments are assessed on a case-by-case basis, taking into account:

  • the nature of the request,

  • the impact on the user,

  • technical and operational feasibility.

7. Third-Party Platforms and Content

Some Global Talent Pathway services rely on third-party platforms or tools.

Where third-party services are used:

  • Global Talent Pathway will take reasonable steps to consider accessibility in selection and configuration,

  • accessibility limitations outside Global Talent Pathway’s control will be documented where relevant.

This policy does not require Global Talent Pathway to guarantee accessibility of third-party systems beyond its reasonable influence.

8. Roles and Responsibilities

Governance and Compliance Function

  • Oversees this policy.

  • Monitors accessibility risks and complaints.

  • Coordinates periodic review.

Product, Technology, and Content Teams

  • Consider accessibility in design, development, and updates.

  • Apply accessibility standards where reasonably practicable.

Suppliers and Contractors

  • Are expected to comply with accessibility requirements relevant to their services.

  • Must not introduce unnecessary accessibility barriers.

9. Reporting Accessibility Issues

Accessibility issues, feedback, or requests for assistance may be reported through:

  • the Complaints & Disclosures Gateway, or

  • designated contact channels published on the platform.

Accessibility-related complaints are handled in accordance with the Complaints Policy.

10. Monitoring and Review

Accessibility is monitored through:

  • user feedback,

  • issue tracking,

  • periodic reviews of high-use services.

This policy and associated practices are reviewed annually or when material changes occur.

11. No Absolute Guarantee

Global Talent Pathway does not guarantee that all digital services will be fully accessible at all times.

This policy reflects a commitment to reasonable efforts, not strict liability or perfection.

12. Relationship to Other Policies

This policy operates alongside:

  • Privacy Policy,

  • Information Security Policy,

  • Complaints Policy,

  • Risk Management Framework,

  • Supplier Code of Conduct.

In the event of inconsistency, Tier 1 policies prevail.