Developing an Accessibility Policy

David Banes

Mada Center January 2011

Why Develop a Policy for Accessibility?

• Policy development establishes expectations for accessibility. For accessibility for people with disabilities to be a consistent reality, an organization has to establish that accessibility will be required and expected. Treating accessibility as an afterthought, or an add-on, ensures that people with disabilities will have to struggle to get equal treatment.

• Policy development fosters cost savings on an organizational level. Planning for accessibility can help to save time and money in the course development process. While accessibility training and retrofitting will cost more up-front, such efforts should result in long-term savings as developers become more skilled in creating accessible content.

• Policy development helps protect against costly litigation. As of this writing, there are no effective standards for accessibility in distance learning or information technology access. However, organizations could face future litigation seeking to enforce their rights under the UN Convention. An organization with a policy in place for accessibility in this area will be much more likely to be able to defend themselves against such litigation than an organization without such a policy.

• Policy development helps confirm organizational commitments to accessibility. Most organizations have a strong commitment to inclusion and diversity which includes people with disabilities. Drafting and implementing a strong policy regarding electronic accessibility reinforces that commitment and helps to ensure that the campus will continue to be a welcoming environment for all people.

Business Case

• Websites and technologies must address the needs of people throughout the country. An accessible website can provide access to information on a far wider scale than previously possible. Social incentives for accessibility include: – Disabled people have easier access to printed, audio or visual

material.– Citizens can access services and information, regardless of experience

or ability.– Everyone will find the website easier to use, improving their ability to

successfully complete goals online.– People using all kinds of devices, from the oldest to the newest, will be

able to use the website, helping to reduce the impact of the digital divide.

– Greater interaction between citizens and government is possible with a user friendly, accessible website.

Business Case

• A user friendly and accessible website can help reduce costs both directly and indirectly. Accessibility is often viewed as an expensive afterthought, but it can provide many cost benefits. The key is to build in accessibility from the outset, making inclusive design a priority throughout the development lifecycle of the website. Financial incentives for inclusive design include:

– Accessible web pages tend to be lighter (physically smaller) which reduces bandwidth costs and improves page response times - leading to an improved customer experience.

– Increasingly, people will be able to access services and information online, representing a reduction in costs needed for ancillary resources such as call centres.

– Ongoing maintenance and hosting costs can be significantly reduced.– Providing one website that supports multiple audiences is more

efficient than running multiple websites for multiple audiences.

Business Case

• Technical concerns vary. According to capability, needs of a small NGO will be different to those of a central government body. However, improving technical performance and delivering reliable digital services is important across the board. Technical incentives for inclusive design include: – Following recognised standards and guidelines for

accessibility can help ensure that future technologies will have access.

– Compatibility with more technologies such as mobile.– Access to a wide range of assistive technologies.– Improved levels of traffic may be driven to the site through

Search Engine Optimisation (SEO).

Developing an Accessibility Policy

• For organizations that do not have a policy in place, there may be a tendency to spend a great deal of time developing a new policy. However, there is little need to "reinvent the wheel" in policy development. Many organizations have already developed policies which cover information technology accessibility, and others have developed policies that are specific to the distance learning environment. Following the best parts of these practices can be beneficial in developing a new policy.

Document Sections

PurposePolicy StatementScopeCompliance RequirementsProcurementTesting and ValidationMonitoringDesignated IndividualsComplaint ProcessContact InformationAdoption & Implementation

Accessibility statement

• An accessibility statement is a statement of intention. At its most simple, an accessibility statement will provide an open commitment to accessibility. An example of a simple accessibility statement would be:

[Organisation name] is committed to ensuring that this website (or other forms of technology) is accessible to the widest possible range of people. If you have any questions or suggestions regarding the accessibility of this, or if you have difficulty using any part of it, please contact us.

• An accessibility statement should contain the following parts: – A clear statement that demonstrates the organisation's commitment to accessibility.– Information about any areas of the system that do not yet conform to the overall accessibility

targets.– Contact details for people wishing to report problems.– A link to the accessibility policy.

• Accessibility statements should assume that the user has little or no knowledge of design issues and should therefore limit the use of technical jargon (e.g. levels of conformance to accessibility standards).

Accessibility Statement

• An accessibility policy must: – demonstrate disability awareness;– explain how disabled users are to be involved in the development of the website;– state the level of conformance to be upheld; and– plan how the level of accessibility will be maintained over time.

• The process for maintaining accessibility shall always include: – a description of the target user population;– the core tasks that users should be able to carry out;– an analysis of user needs;– the steps taken to meet those needs; and– an evaluation of how successful the site or system is in meeting those needs.

• If there are areas of the website or system which pose potential problems for users with particular impairments, an accessibility policy should contain: – how the potential accessibility issues are to be addressed;– how long it is likely to take to repair;– how the service can be accessed by alternative means; and– who to contact if there is a specific problem.

Policy

ScopeThe Scope section should identify the entities (e.g., departments, authorities, universities, contractors, grantees, etc.) that are required to comply with the policy. In the scope, you also need to identify the service and programmatic reach of the policy. For instance, does the policy require that all technologies conform to the accessibility policy and standards?

Key factors to consider when addressing the scope of applicability are: • Who is issuing the policy?• What entities fall under the authority of the issuing entity?• Are they bound by the policies and standards that are issued?

You may want to cite any statutory authority, executive order, etc., under which the policy is issued.

Care should be taken to use consistent terms to identify required entities. You also should consider including the terms in the Terms & Definitions section of the policy.

Compliance

The Compliance Requirements section should address the specifications for compliance with the policy, including the timeframe for implementation of the policy and standards for new websites and technologies as well as for remediation of existing ones.

Guidelines and StandardsWebsites and online applications,

Public access terminals, such as ATMs, information kiosks, ticket vending machines, Information displays, and card readers,

Telecommunication devices and services, such as desktop telephones, mobile phones and Interactive Voice Response services,

Application software,

Smart cards and related media.

Procurement

What is a disability compliant IT solution?

• Answer 1: No idea– How do you measure?

– How do you test for it?

– Does an IT supplier understand it?

• Answer 2: Everything– All IT solutions are compliant with needs until…

– They create disadvantage for someone with a disability which is then not addressed and…

– That person successfully complains.

What’s a better question to ask?

• Is your IT solution accessible to people with disabilities?

Specific and open

• What accessibility

standards does your IT solution meet?

Too ambiguous

Vendors - Don’t take their word for it

• Has their solution been tested by people with disabilities?

• How will they involve disabled people in the development of the solution?

• Do they have reference sites?

• Will they let you test the solution yourself?

A recipe for success

4 simple questions

Do not purchase Ok to purchase

Doesit meet recognised

standards?

Doesit pass your

testing?

Willthey commit to

compliance?

Is there anacceptable interim

position?

Yes No

No

No

YesYes

NoYes

Do not purchase Ok to purchase

Doesit meet recognised

standards?

Doesit pass your

testing?

Willthey commit to

compliance?

Is there anacceptable interim

position?

Yes No

No

No

YesYes

NoYes

Testing and Validation• Requirements for the testing and validation of accessibility should consider some of the known issues and

best practices that are related to evaluating accessibility.

• Known issues and recommended practices include: Automated and semi-automated testing tools can provide valuable information about your product in an efficient manner. Both automated and manual reviews, however, are necessary to ensure a comprehensive evaluation.

• Many automated evaluation tools are available on the market; each tool has different strengths and weaknesses. An array of testing tools should be evaluated to determine which tool most effectively meets your identified needs and requirements.

• Manually evaluating your entire system or site may not be possible. A manual evaluation should be completed on a subset by individuals experienced with the applicable standards or guidelines.

• User testing is critical. Testing by persons who use, but are not reliant on assistive technology as their normal means to access the web or technology, can result in unreliable results. A percentage of evaluations should be completed by individuals with different types of disabilities, including those who are experienced in using different assistive technologies.

• If individual entities are responsible for developing and implementing testing and validation protocol, it could result in inconsistent practices and reporting. Consider devising a documented testing protocol to ensure consistent and comparative evaluations across all entities responsible for testing and validation.

Monitoring

• In the Monitoring section, you should describe the monitoring that will take place to determine implementation and compliance with the policy and standards.

Co-ordination, Complaints and Contact

In the Designated Individuals section you should identify an individual or an entity as the contact point for questions or complaints about implementation and/or compliance with the access policy and standards.

The Complaint section should address the complaint provisions that are in place including the information that is required for a complaint, the process that is used to file a complaint, and the actions or events that will occur once a complaint is received.

In the Contact Information section of the policy, you should specify whether covered entities need to identify a person or entity that is responsible for answering questions and handling problems with the website or system.

Is this person different from the person or entity to whom formal complaints can be submitted ?

Adoption and ImplementationThis discussion is provided to explore strategies and activities that should be considered to support the adoption and implementation of your accessibility policy and standards.

It is not designed to be part of the policy document, but as a means to help you think about what needs to be done to promote and support successful implementation.

First, you should consider your communications strategy.How will you inform stakeholders of the policy and standards?

Will staff have the knowledge, skills, and tools to ensure compliance? If not, what strategies need to be put in place to meet those needs?

Does training need to be provided? What level and what type of training is needed?

Adoption and ImplmentationIs awareness training needed at all levels (executives, developers, content developers, contractors, etc.) to understand why accessibility is a necessary consideration and why the you have adopted an accessibility policy? Who needs skill development training?

How will training be provided? For instance, will it be separate and distinct from other information technology training, or do you want/need to consider developing and offering customized training curricula to ensure that accessibility is considered within the general context of web development training? Will both strategies be necessary?

Multiple training approaches should be considered: face-to-face training, CD-based training, and web-based training (interactive and/or one-way).

Devise methodologies, tools, and strategies to determine needs for initial and ongoing training. For example, you may need to survey developers, consider user complaints, and review results of any monitoring processes.

Adoption and ImplementationIs there an economy of scale to consider when making enterprise-wide buys of development and testing tools, training tools, or other offerings?

Review existing authoring tools, evaluation tools, and user agents (browsers, media players, etc.) for accessibility support.

Refer to the W3C's Selecting and Using Authoring Tools for Web Accessibility for some guidance on considerations for authoring tools.

Do you need to consider the design and implementation of efforts to determine the impact of the policy?

Do you need to establish a plan or timeframe to review the policy and standards to ensure that it is consistent with other IT policy development and that it reflects the most up-to-date web and platform development practices and tools?

Evaluating the Accessibility Policy

• Whether an organization is developing a new policy, or reviewing an existing policy, it is still important to evaluate the policy to ensure that it meets the needs of the organization and the people.

• Checking the effectiveness of the policy is key to providing equal access for all people.

• The AccessIT project has identified the following characteristics of information technology accessibility policies.

Evaluating the Policy

• What groups of people with disabilities are covered? Effective policies cover all people with disabilities. Some policies, however, cover only people who are blind or have low vision. While the majority of issues regarding accessibility deal with people who are blind or who have low vision, other groups -- such as people with mobility disabilities, people who are deaf or hard of hearing, or people with photosensitive epilepsy -- should be considered in policy development. Additionally, more and more people with learning disabilities are beginning to use screen readers and other pieces of assistive technology originally developed for people who are blind -- and may encounter similar barriers. An effective policy should be as inclusive as possible, and apply on a cross-disability basis.

• What types of technology are covered? One weakness of many policies is that the policies incorporate only web accessibility Initiative standards. However, these "first generation" standards do not cover the "second generation“ content frequently found -- such as PDF files, PowerPoint presentations, and other non-HTML elements. Policies should be written to cover many different types of information technology products and services -- not just HTML pages on websites. Additionally, an effective policy should cover the procurement of information technology.

• Which entities are covered? Some existing policies only cover one department. Some have a policy that covers a library system but not the curriculum. Some have policies regarding website design, but not regarding communications tools accessibility. Having one policy for an entire organisationhelps to promote uniformity and raises expectations for access.

Evaluating The Policy

• How is compliance measured?• Implementing and enforcing the policy is just as important as developing the policy in the first

place. Who is responsible for evaluating information technology? What penalties are there for failure to comply with the policy? How are complaints and grievances handled?

• How will the policy be disseminated? How will staff know about the policy? Is it publicly posted? Is training available?

• What if the technology changes? Will the policy continue to apply to new and emerging technologies? Or will the policy need to be assessed periodically as assistive technology and information technology products become more sophisticated?

• Does the policy meet the needs of all people? Might some people still experience barriers even after the policy has been fully implemented? What procedures are in place for people to request additional accommodations? Have people with disabilities and representative organizations been included in the policy development process?

• Asking questions such as these helps to clarify the policy and insure that it meets the stated goal of achieving accessibility for people with disabilities.

Sources

• COI - Delivering Inclusive Websites• W3C - Developing Organizational Policies on Web

Accessibility• MLA – Delivering your access policies and plans• HSE – Website Accessibility Policy• CATEA - Developing Effective Policies for Information

Technology Accessibility for people with Disabilities• G3ICT - Introduction to developing policy• JISC - Accessible e-Learning in Higher Education• NDA - Universal Design guidelines and standards for ICT• ITTATC - Access Policy & Standards Construction Tool