Loyalty software: Welsh and accessibility duties in Cardiff

What to take away

Welsh-language disclosure expectations for Cardiff campaigns

Welsh Government bilingual disclosure expectations are not a single statute you can tick off. They come through the Welsh Language (Wales) Measure 2011, the Welsh Language Standards, and the procurement and grant conditions attached to Welsh Government funded work. If your loyalty scheme is commissioned by a Cardiff public body, those conditions usually flow down into your contract.

The Welsh Language Standards are made under regulations including the Welsh Language Standards (No. 1) Regulations 2015 and the Welsh Language Standards (No. 2) Regulations 2016. They apply to specified organisations, not every business in Cardiff. Check the organisation's compliance notice from the Welsh Language Commissioner for the standards and service-delivery obligations that cover the campaign.

In practice, that means a Cardiff loyalty scheme cannot treat Welsh as a translation afterthought. The Welsh Language Commissioner can investigate complaints about services that fail to offer Welsh. A member who receives a welcome email, a points statement or a referral invitation in English only has grounds to complain.

The disclosure itself covers what you do with member data, how points are valued, when they expire, and how referrals are tracked. If the English version says one thing and the Welsh says something looser, you have a problem on both fronts. Treat the two texts as equally authoritative and have a Welsh-speaking reviewer sign off the final copy.

This is where a disclosure policy without hiding the small print pays off. Write the Welsh and English versions side by side, at the same reading level, with the same caveats in the same order.

A useful discipline is to draft the Welsh first for any campaign aimed at Cardiff's Welsh-medium audiences. If a claim cannot be made clearly in Welsh, it is probably too vague in English too.

Bilingual consent wording in loyalty sign-up flows

Bilingual consent wording is the part most Cardiff campaigns get wrong. Any consent has to be given freely and must be specific, informed and clear. A single tick box that says "I agree to the terms" in English does not meet that bar for a Welsh-speaking member.

Under UK GDPR and the Data Protection Act 2018, you need separate consents for separate purposes: joining the scheme, receiving marketing, and being contacted about referrals. Each needs a Welsh and an English version, and the member must be able to read either one before ticking.

The Information Commissioner's Office sets out what individuals can ask of you once they are members, including access, correction and erasure. Welsh-speaking members can make those requests in Welsh, and you should be able to answer in Welsh. The ICO's Individual rights - guidance and resources | ICO is the reference point here.

Design the flow so the language toggle sits above the consent text, not below it. A toggle at the foot of the page is easy to miss on a phone. Cardiff members on mobile are a large share of any public-facing scheme.

Store the language of consent alongside the consent record. If a complaint arrives two years later, you want to show which version the member actually saw. That single field also tells your team which language to use for future contact.

Examples of loyalty and referral platforms include LoyaltyLion, Yotpo Loyalty & Referrals and Smile.io. Where you use one, map the Welsh copy, consent records, referral journey and accessible landing page across the platform and connected email or web components; verify the actual configuration rather than assuming the platform name guarantees compliance.

Designing products that protect privacy | ICO is worth applying at this stage. Decide what member data the scheme genuinely needs, collect that, and set the retention period before the first sign-up, not after the first audit.

WCAG-aligned accessibility for loyalty and referral flows

WCAG-aligned accessibility means meeting the Web Content Accessibility Guidelines at level AA. For public-sector bodies in scope, the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 apply to their websites and mobile apps and require an accessibility statement. The Regulations point to EN 301 549, which incorporates WCAG 2.1 AA criteria; WCAG 2.2 AA is a useful current design target, not the version named in the Regulations. For a loyalty or referral flow, assess the app, web sign-up, emails and points statements against the applicable duties.

Common failures in Cardiff schemes include colour contrast on points balances, referral links that only work with a mouse, and PDF statements with no tagged headings. Each of these blocks a member from earning or spending points, which is a service failure, not a cosmetic one.

Here is a practical checklist for a Cardiff loyalty or referral flow:

Accessible referral flows matter because referrals are where members invite others. If the share step is unusable with a screen reader, the scheme quietly loses the members most likely to need support.

Where rules and ethics matter is in the overlap between accessibility and fairness. A referral bonus that only works for app users excludes members who rely on the website. Design the reward so it lands the same way whichever route the member uses.

Equality duties shaping audience targeting

The Equality Act 2010 sets out protected characteristics that shape how you may target and exclude audiences. Age, disability, race and religion or belief are the ones that come up most often in loyalty segmentation. You can target a Cardiff audience by interest or behaviour, but you cannot build a scheme that routinely shuts out a protected group.

The full text sits in the Equality Act 2010. The Equality and Human Rights Commission (EHRC) is Great Britain's equality regulator; it publishes guidance and has powers to enforce the Act.

That has a direct effect on segmentation. If your model scores members on app engagement and you have not made the app accessible, the model is filtering by disability. The same applies to language: scoring Welsh speakers lower because they engage in Welsh is indirect discrimination.

Cultural identity data from the Cultural identity - Office for National Statistics is useful for sizing and segmenting Welsh audiences without guessing. It gives you population-level context, not individual profiling. Use it to check that your Cardiff sample reflects the city, then keep the profiling decisions at the campaign level.

Targeting also has a consent dimension. Sensitive characteristics need a lawful basis and, in most cases, explicit consent. If you want to send Welsh-language campaigns to members who prefer Welsh, ask them, and record the answer as a preference rather than an inferred trait.

Document the reasoning. A short note explaining why a segment was chosen, what data supported it and who approved it will do more for you in a challenge than any amount of retrospective justification. That is also where team roles need clear data: someone owns the segment definition, someone owns the legal basis, and someone owns the creative.

Testing campaigns with Cardiff members

Cardiff campaign testing should happen with real members before the campaign goes live, not with staff on a fast connection. Recruit a panel that includes first-language Welsh speakers, older members, and people who use screen readers or voice control.

A worked example shows how this plays out. A Cardiff public-sector loyalty scheme plans a referral push for its recycling rewards. The English copy is ready, the Welsh is machine translated, and the referral link works on desktop.

In the test, a Welsh-speaking reviewer flags the machine-translated copy for replacement, while a mobile check confirms the desktop-only referral link cannot be used on a phone. The team replaces it with a mobile-accessible route and has the Welsh wording reviewed by a human translator. Before launch, it retests sign-up, sharing and redemption with keyboard and screen-reader users.

That cycle takes a fortnight and gives the team time to correct the Welsh copy and referral route before launch. It reduces the risk of a language complaint to the Welsh Language Commissioner or an accessibility complaint, and gives the funder evidence of testing and fixes.

Keep a short test log for each campaign: who tested, on what device, in which language, and what changed. Over a year, that log becomes the most useful document your team holds.

Common questions