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Accessibility Statement - hiToco

ACCESSIBILITY STATEMENT - HITOCO 

medigital GmbH is committed to making its mobile application accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. 

This accessibility statement applies to hiToco v2.1.7 released on 25th November 2025 

Compliance status 
The hiToco mobile application is partially compliant with the Web Content Accessibility Guidelines (WCAG) 2.2 AA. This means that some parts of the app do not fully meet the accessibility requirements. Details of the non-compliant elements are listed in Section (a) of this statement. medigital GmbH is working to improve accessibility in future updates. 

Non-accessible content 
The content listed below is non-accessible for the following reason(s): 

(A) NON-COMPLIANCE WITH THE ACCESSIBILITY REGULATIONS

The following content and functionalities within the hiToco mobile application do not yet fully meet the requirements of the Web Content Accessibility Guidelines (WCAG) 2.2 AA. These issues are within the organisation’s control and are planned for future remediation as part of continuous accessibility improvements. 

1. Orientation (WCAG 1.3.4 — AA)
The application currently supports only portrait orientation. Users cannot rotate the interface into landscape mode. This limitation may affect users who rely on fixed device positioning or larger landscape displays. 

2. Identify Input Purpose (WCAG 1.3.5 — AA)
Autofill and semantic identification of input fields (for example, name, email, telephone) are not consistently implemented. As a result, assistive technologies cannot always determine the intended purpose of input fields. 

3. Resize Text (WCAG 1.4.4 — AA)
Although text scaling is supported, it is currently capped at approximately 135%. WCAG requires support for up to 200% resizing without loss of content or functionality. 

4. Text Spacing (WCAG 1.4.12 — AA) 
The application does not fully guarantee correct content rendering when users adjust text spacing through system accessibility settings. Some interface elements may not fully adapt to increased spacing. 

5. No Keyboard Trap (WCAG 2.1.2 — A) 

In some cases, focus may become temporarily trapped within modal windows, switch components, or text input fields when using assistive technologies such as screen readers. This can limit navigation for keyboard-only or switch-access users. 

6. Character Key Shortcuts (WCAG 2.1.4 — A) 
A small number of gesture-based shortcuts (such as drag-to-reorder or long-press actions) cannot currently be disabled or remapped. This may present obstacles for users who have difficulty with fine motor gestures. 

7. Pause / Stop / Hide (WCAG 2.2.2 — A) 
While most time-based media can be paused, certain animations and loading indicators cannot be manually paused or stopped by the user. These elements are functional but still fall under WCAG requirements. 

8. Three Flashes or Below (WCAG 2.3.1 — A) 
The application is designed to avoid flashing content; however, certain video-based materials may contain brief flashes that cannot always be fully controlled. This may pose a risk to users sensitive to flashing stimuli. 

9. Language of Parts (WCAG 3.1.2 — AA) 
Where the application displays text in multiple languages, changes in language are not explicitly marked for assistive technologies. This can cause screen readers to misinterpret pronunciation. 

10. Error Identification (WCAG 3.3.1 — A) 
Although visual error messages are displayed, they are not consistently announced by screen readers. This may make it more difficult for users with visual impairments to understand input issues. 

11. Error Suggestion (WCAG 3.3.3 — AA) 
Suggestions or corrective prompts are available only during authentication. Other inputs do not provide automated guidance or recommendations, which is required when possible. 

12. Status Messages (WCAG 4.1.3 — AA) 
Status messages, such as confirmation banners or background processing updates, are not consistently announced by assistive technologies, which can hinder navigation for users relying on screen readers. 

(B) DISPROPORTIONATE BURDEN
Some accessibility issues cannot be fully resolved at this time because doing so would place a disproportionate burden on medigital GmbH, taking into account the size of the organisation, available resources, and the significant technical complexity involved. 

The following items fall under this exemption: 

1. Text Scaling Beyond 135% (WCAG 1.4.4 — Resize Text) 
Supporting text enlargement beyond 135% would require a fundamental redesign of the application layout, UI components, and screen flows. This represents a substantial development effort that is not currently feasible relative to the organisation’s resources. The app preserves readability up to 135%, which provides reasonable accessibility for the majority of users. 

2. Text Spacing Adjustments (WCAG 1.4.12 — Text Spacing) 
Ensuring full compatibility of user-adjusted text spacing across all Android and iOS devices, screen densities, and OS variations would require extensive re-engineering of UI components and retesting across hundreds of device configurations. Given the complexity and cost relative to the expected accessibility benefit, this is considered a disproportionate burden. 

3. Prevention of All Flashing Content (WCAG 2.3.1 — Three Flashes) 
While the application is designed to avoid flashing content, certain user-uploaded or third-party-generated medical video material may contain brief flashing that cannot be reliably controlled. Preventing or modifying such content is technically unfeasible without removing essential functionality. Therefore, this is considered a disproportionate burden. 

4. Full Remediation of Gesture-Based Shortcuts (WCAG 2.1.4 — Character Key Shortcuts) 
Some gesture-based interactions (e.g., drag-to-reorder, long-press activation) are part of the native operating system behaviour or essential UX patterns. Replacing or remapping these interactions would require considerable redevelopment effort and could negatively affect usability for the broader user base. This is therefore treated as a disproportionate burden. 

Where feasible, medigital GmbH will continue to monitor and improve accessibility in future development cycles 

(C) THE CONTENT IS NOT WITHIN THE SCOPE OF THE ACCESSIBILITY REGULATIONS 
Certain content and functionalities fall outside the scope of the accessibility regulations and are therefore not required to meet WCAG 2.2 AA standards. 

1. Authentication Time Limits (WCAG 2.2.1 — Timing Adjustable) 
The application’s authentication and session-timeout mechanisms are dictated by medical device security and regulatory requirements. These time limits cannot be extended or disabled without compromising safety and regulatory compliance. As such, they are exempt from accessibility requirements. 

2. Technical Loading Animations (WCAG 2.2.2 — Pause, Stop, Hide) 
Brief loading indicators are essential for conveying technical processing states and do not present meaningful content. Such animations are explicitly exempt under the accessibility regulations. 

3. Third-Party or User-Generated Content (e.g., medical videos) 
Some content displayed within the app, such as clinical videos or diagnostic media uploaded by customers or third-party systems, is not produced or controlled by medigital GmbH. As external content is outside the organisation’s control, it is exempt from WCAG compliance. 

4. Native System Components or Third-Party Modules 
Certain interface elements (e.g., camera modules, map views, OS-level UI behaviours) are provided by third-party platforms and cannot be modified by medigital GmbH. These components fall outside the regulatory scope. 

medigital GmbH will continue to provide accessible alternatives when possible and ensure all content under its direct control follows accessibility best practices. 

Preparation of this accessibility statement 
This accessibility statement was prepared on 1st December 2025. 

The accessibility of the hiToco mobile application was evaluated using a combination of: 

  • Internal self-assessment, including manual testing by medigital GmbH using VoiceOver, TalkBack, and system accessibility features. 

  • Automated accessibility checks, including contrast, labels, focus order, and structural validation. 

  • Functional testing on iOS and Android devices to assess compliance with WCAG 2.2 AA. 

  • Review of development documentation, user interface specifications, and testing records. 

This statement was last reviewed on 1st December 2025. 

The accuracy of the accessibility information in this statement is reviewed at least once per year or after significant app releases (e.g., feature additions, UI updates). 

If a substantial revision of the application takes place, the accessibility evaluation will be repeated, and the statement will be updated accordingly. 

FEEDBACK AND CONTACT INFORMATION 

If you experience any accessibility barriers while using the hiToco mobile application, or if you need information in a different format such as: 

  • Accessible PDF 

  • Large print 

  • Audio format 

  • Braille 

  • Easy Read 

  • Alternative structured text 

you can contact us using the details below: 

Accessibility Team – medigital GmbH 

Email: support@hitoco.co.uk 

We aim to respond to all accessibility-related requests as soon as possible and no later than within a reasonable timeframe. 

If you are requesting content that is excluded from the regulations or technically inaccessible due to third-party constraints, we will provide alternative formats whenever reasonably possible. 

ENFORCEMENT PROCEDURE 
The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. 

If you contact us with an accessibility-related concern and are not satisfied with our response, you can escalate the issue to: 

Equality Advisory and Support Service (EASS) 
Website: https://www.equalityadvisoryservice.com Telephone: 0808 800 0082 

UK-MGL-2026-2786-v1 Mar 2026