Web Accessibility : What Your Campus Needs to Know

Web Accessibility : What Your Campus Needs to Know

Diane Kubarek, Tracy Mitrano, Cyndi Rowland, Sharon Trerise

Overview of Laws Overview of Laws Affecting Web Affecting Web AccessibilityAccessibility

Cyndi Rowland, Ph.D.

WebAIM, Utah State University

A Little about myself . . .

Cyndi Rowland, Ph. D.Associate Director-CPD

National Center on Disability & National Center on Disability & Access to EducationAccess to Education

WebAIM WebAIM (Web Accessibility In Mind)(Web Accessibility In Mind)

Utah State UniversityUtah State University

• Although an accessibility expert, I am NOT a lawyer. If you seek Although an accessibility expert, I am NOT a lawyer. If you seek legal advice, please contact institutional counsel or an attorneylegal advice, please contact institutional counsel or an attorney

SUMMARYSUMMARY

• Rehabilitation Act (Sec 504 & 508)• ADA of 1990

– see 28 C.F.R. Part 35– Dept of Justice ruling (9/9/96): ADA accessibility

requirements apply to Internet web pages (10 NDLR 240)

• Telecommunications Act (see Sec 255)• Responses from U.S. Dept of Ed, OCR (see

docket numbers 09-95-2206; 09-97-2002)

• NIMAS (in IDEA)

Review• Rehabilitation ActRehabilitation Act

– Section 504 (all federally funded programs)

– Section 508 (federal agencies)

Section 504 of the Rehabilitation Act

“ no otherwise qualified individual with a disability in the United States… shall, solely by reason of his disability, be

excluded from the participation in, be denied the benefits of, or be subjected to

discrimination under any program or activity receiving federal financial

assistance. . .” (29 U.S.C. Section 794)

Review

• Rehabilitation Act–Section 504 (all federally funded

programs)• Affirmative obligation to plan in

advance • Courts knocking down post-hoc

accommodations

• Reactive, rather than proactive, model

• Native access can be achieved in many cases, yet the model reinforces “accommodation”

• Mindset of many is to go to DSO or SpEd and they’ll do it. They may not have the expertise or see the big picture.

504 Model for working with students may not fit Web

Section 508

Section 508 of the Rehabilitation Act of 1997 provides the legislative language for accessible electronic information technology, including the Internet

Took effect: June 21, 2001

Review• Rehabilitation Act

– Section 508 (federal agencies)• All the buzz years ago, lost it’s luster• Interpreted NOT to apply to states with Tech Act

monies• Used to define floor of access (16 standards) • Emerging in federal RFP’s and contracts, emerging

as procurement language • VPAT’s continue to be problematic• Monitoring is poor, (benign neglect?)• “Access” still means different things (e.g., FAFSA)

– ADA of 1990 • Civil Rights Legislation• Word “Internet” not in ADA • Employment discrimination• Title II: effective communication• Title III: place of public accommodation • Sample court cases

– MARTA, Southwest, Utah DOJ – CSU Fullerton, UC Berkeley, Cappella College– Target

• Current draft of ADAAG guidelines do not include any mention of electronic information (other than ATM’s and Kiosks)

Review

ADA may help us think about electronic access

• Right to access entire building– Rights to independence– Back doors problematic

• Could not go around ADA by “renting” inaccessible buildings• Remodel “springs” law into place

– Legacy pages

• Written transition plan necessary • Regulations began to inform professions (e.g., architects,

engineers, building inspectors)

• Telecommunications ActTelecommunications Act (see Sec 255)– Applies to hardware, – Excludes the Internet – What will happen to telecom as VoIP takes a place in the market?

• IDEAIDEA– NIMAS / NIMAC– Could this foot in the door creep to NCLB? (AYP could help)

• Higher Ed ActHigher Ed Act– Don’t get your hopes up

• Miscellaneous legislationMiscellaneous legislation that may assist in making the case– Air Carrier Act– HAVA

Review

• StatesStates– 17 with laws that cover Web– 8 with policies– Most using 508 or hybrid– Vendors nightmare– Many do not include education

• EducationEducation– Lots of models & good work being done

• Postsecondary policies all over (See WebAIM)• K-12 (e.g., Texas, Oklahoma, Kentucky, CoSN)

Review

Don’t forget international accessibility laws

Globalization realities in distance education

(a.k.a. The world is flat)

Questions or comments?

Policy, Process, and Policy, Process, and History of Web History of Web

Accessibility at CornellAccessibility at Cornell

Tracy Mitrano

Director of IT Policy and Computer Policy and Law Programs

Big “P” and Little “p” Policy

• Big “P” policy involves external issues, such as national security, electronic surveillance laws, digital copyright or disability law.– Rehabilitation Act – Americans with Disability Act– How many tax dollars should be spent on

people with disabilities?

• Graphic representation of Laurence Lessig’s foundational concept of the principle influences on the Internet, as described in his book, Code, published in 1999. This graph is offered with the suggestion that institutional policy is similarly influenced by market, social norms, technology, and the law.

MarketMarket

ArchitectureArchitecture

Norms Norms

LawLaw

Policy Policy

The four major influences on institutional policy

Big “P” and Little “p” Policy

• Little “p” policy is institutional policy.– Preservation and protection of institutional

interests and assets -- including reputation!• “Any person, any study”

• Cornell Model• Centralized University Policy Office

– http://www.policy.cornell.edu/

• Famous “policy on policies!”– http://www.policy.cornell.edu/vol4_1.cfm

Take Aways about Institutional Policy

• Policy is integral part of the culture and traditions of each individual institution.

• Matters less who or how institutional policy is developed than that some process exists…

• Process breaks down into three parts– Initial high level send off with guidance– Middle level review and/or stakeholders– Executive sign off

Cornell’s Policy Process• This process boils down to three steps: an introductory step, where a

responsible office brings a policy concept to the Executive Policy Review Group, which represents the highest level of the University administration. This group reviews the policy as a concept, offers direction where needed, and either approves or denies the responsible office to go forward to draft and vet a policy throughout the University community. The second step is review by the Policy Advisory Group, which represents mid-level administrators whose principle role is to determine optimal implementation, and therefore the focus is largely on procedures. The Policy Advisory Group is not allowed to reject the policy as a concept, and only in extreme situations could they reject the policy for failure of appropriate implementation. Given their role in reviewing all University policy, PAG also assists in harmonizing policies into the University policy library. The third and final step is review by the EPRG to assure that the policy meets their original expectations, has been reviewed by the PAG and all other relevant stakeholders, and is in final draft form in order for the University policy office

to promulgate it to the entire University.

References

• Information Technology Framework– http://www.cit.cornell.edu/oit/policy/framework-chart.html

This diagram illustrates the development of IT policy in the period from 2002 projected into 2007. It breaks down the original responsible use policy, promulgated in 1995, and one of the first IT policies at the University level in the country, into discrete digestible full-text policies. The left-hand side of the diagram represents, in the main, security policies, and the right hand side, privacy policies, augmented by other IT issues to be resolved at the University level through policy, such as domain name conventions and Web accessibility.

• Impact Statement for University Policy 5.11, Accessibility of Cornell Web Sites– http://www.cit.cornell.edu/policy/drafts/WAis.pdf

Defining Scope for Cornell’s Proposed Policy on Web

AccessibilityDiane Kubarek

Director, Office of Web Communications

dmk2@cornell.edu

Cornell’s scope definition(to-date)

• New definitions categorize Cornell Web sites• Most (not all) official sites must be compliant,

eventually• Unofficial sites are encouraged to comply• Some sites have as long as 5 years to come into

compliance (mitigation of impact)• There will be a process for undue burden

exemption requests

“Sticky Wickets”

• Which standard?

• How do we define the University Web space? (Scope step 1)

• How do we define priorities within that Web space? (Scope step 2)

Which standard: Why Section 508?

• 508 is less “fluid” (W3C is under active revision)

• Tools exist to assess 508 compliance (hybrids imply tools require more interpretation)

• Future legal actions more likely to be based on 508 than W3C or hybrids

Defining the Web space: basic definitions (see Impact

Statement • Defining a site (p.2)

• Categorizing sites as “official” (pp.2-3) or “unofficial” (p.5)

• Capturing all the major types of sites

• Deciding on appropriate exemptions (p.3)

Defining the Web space: sites for special consideration

• Course sites• Archival sites• Student organizations• Student project sites (class assignments)• Sites about individuals - personal, professional• Affiliated organizations - e.g. alumni classes &

clubs• Testing or staging sites• “Live” sites (e.g. Webcasts)

Defining the Web space: sites for special consideration

• Sites developed to experiment with new technologies

• Sites you host for the “general good” – WWW Virtual Library catalog sites– Professional organizations or associations– Mirror sites

• “Dot Orgs”, “Dot Coms”, and other official sites outside of your domain name space, or hosted externally

Defining priorities: hard questions

• Internal vs. external

• Retrofit vs. redesign (from this day forward)

• Password protected vs. not

• Is traffic volume a consideration?

• What’s realistic at your institution?

• All reflected in implementation schedule

Defining priorities: policy questions answered

by your culture• How will exemption requests be reviewed?• In your policy process, who bears the burden of

enforcement?• Can you influence purchasing decisions?• Can you promote skill elevation in job

descriptions during Web developer hires?• How will you define success?• How will you monitor success?

Current Cornell challenges

• Research sites (collaboration, data-gathering)• Faculty issues, especially course sites• Central administrative systems• Purchasing requirements, vendor relationship• Open source projects• Enforcement and consequences• Accessibility alongside accommodation• Implementation timeline not complete

Web accessibility = usability

• All audiences benefit

• Content easier to access with portable devices

• Content easier to re-use

• Content better organized

• Simpler links, digestible chunks

• Download times reduced

Web Accessibility Policy Implementation

Sharon Trerise

smt34@cornell.edu

Project: Evaluate accessibility of CC websites• Diagram depicting relationship between 4

evaluation methods including– Automated 508 evaluation– Manual 508 evaluation– Simulated user evaluation– Actual user evaluation

• Automated and manual 508 evaluation procedures are page-based evaluations

• Simulated user evaluation and actual user evaluations are process-based

• All methods evaluate both accessibility and, to some degree, usability

• Overall <5% of all pages evaluated complied with all Section 508 criteria

• Notable results:– 35% of images lacked meaningful alt text– 100% of data tables lacked headers– 100% of frames lacked titles– 87% of use of scripts was not accessible– 91% of forms objects were not labeled– 97% of pages lacked skip navigation links

Graph of Section 508 Manual Evaluation

Results

508 Manual Check Results(% of all relevant sets of pages n=150)

100

97

91

100

87

4

100

100

1

4

35

4

5

20

2

42

3

5

8

80

96

97

96

23

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

p) Timed Response (n=1)

o) Skip Nav Links (n=136)

n) Forms (n=78)

m) Scripts - Link to accessible version (n=11)

l) Scripts -- Asst. Tech Equivalent (n=60)

k) Text-Only (n=5)

j) Flickering (n=137)

i) Frames (n=4)

h) Logical Level Headers (n=0)

g) Data table Headers (n=6)

f) Client-side image maps provided (n=0)

e) Image maps: Redundant Links (n=0)

d) CSS (n=132)

c) Color (n=142)

b) Multimedia (n=0)

a) Images (n=136)

Checkpoint (# pages included)

No Implimentation - significant barrier Partial Implimentation Full Implimentation

NA

NA

NA

NA

Guidelines governing web design

Sample = 701 Community Colleges

Requirements regarding web accessibility

• Guidelines governing web design– 71% of colleges have guidelines for web design– 28% either don't have guidelines or don't know

• Requirements regarding web accessibility– 50% reported having web accessibility requirements

– 29% do not have web accessibility requirements– 49% either don't have requirements or don't know if they do

• Of the 29% who do not have web access. requirements,

– 30% plan to implement them in next year– 36% do not plan to implement in next ye

• POINT: A surprising 50% of colleges have some sort of web accessibility policy or statement of intent.

• Sample=701 Community Colleges

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

# Responses

Yes No Don't know No Response

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

# Responses

Yes No Don't know No Response

Survey*: 50% of institutions with

Web Accessibility Requirements

Website Evaluations**: <5% Web Pages met

Section 508 Web Accessibility Standards

*N = 701 community colleges**N = 150 web pages from 30 community college websites

What do the web accessibility requirements cover?

• Of the 50% who have web accessibility requirements,– 84% of policies cover student services pages– 66% of policies cover individual department/ faculty pages– 75% cover online course content including distance

learning courses– 82% cover ALL college web pages

• POINT: More directly under control of central administration (webmaster), more likely to be covered by web policy; as opposed to under control of departments or individual faculty

Dept /

Faculty

Distance

Learning

Student

Services

ALL

0 20 40 60 80 100

%

Barriers to implementation

Costs & Staffing

Lack of technical support

Lack of knowledge /

training

Lack of awareness

Attitude; Disregard

Lack of support

from administrati

on

Lack of Faculty

Involvement

• Costs• Staffing• Training• Technical support• Awareness• Attitude• Administrative support• Faculty Involvement

WebAIM*8-Step Implementation Model

1. Gather baseline information2. Gain top level support3. Organize a web accessibility committee4. Define a standard5. Create an implementation plan6. Provide training and technical support7. Monitor conformance8. Remain flexible through the changes

*www.webaim.org

The worst thing that

could happen is a policy

that sits on the shelf

• Legally vulnerable

• Not showing a good faith effort

Every institution is different

Your starting point:• Size of website• Number & job roles of

designers & contributors

• Administrative structure & support

• Attitudes

Will affect:• Sequence of events• Timeline• Who gets involved• ???

So you have a policy…

What’s Next?

Step 5: Implementation Plan

• Establish timelines

• Set priorities

• Delegate responsibilities

• Monitor progress

• Document!!!• Example: http://www.wact.missouristate.edu/plan.htm

During Implementation…

Example

Step 6: Training & Technical SupportTraining

• Short term: – Awareness of the need– Understanding of the User Perspective*– Design techniques – Know your audience

• Different skill levels • Different needs (faculty, staff, web designers, students)

• Long term– Incorporate accessibility into existing training

programs*www.webaim.org

Step 6: Training & Technical Support

• Training: Questions– In-house or outsource– Live or online; Delivery format– Frequency– Target audiences– Topics– Updating

Step 6: Training & Technical Support

• Technical Support– Add to job responsibilities of existing staff

(performance evaluation criteria)• Web designers, technical support specialists,

web managers, instructional designers

– Services (in-house, contract)• Video captioning, transcription• Compliance testing / user testing

– Listserv

Step 7: Monitor Conformance

• Compliance testing procedures & frequency– Automated– Manual– User testing

• Let everyone know about your commitment to accessibility– Add statement to your home page– Provide avenue for user to report accessibility

barriers

Step 7: Monitor Conformance

• Plan for sustainability– Include in job description of webmaster, CIO or

hire accessibility consultant– Schedule yearly checks of all web content &

distribute reportsBe sure accessibility criteria is included in all

procurement contracts– Establish relationship with Disability Services

OfficeAim for Systemic Change

Step 8: Remain flexible

Changes in:• standards• personnel• technologies

May necessitate:• new training• new leadership• revised

implementation plan

LEADERSHIP

The most obvious person may not be the best person

• Passionate• Understands disability

issues• Leadership qualities