ict accessibility overview and strategy - o2 group · • integration of ict accessibility criteria...

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ICT Accessibility Overview and Strategy

Jeff Kline Program Director

Statewide ICT Accessibility Texas Dept. of Information Resources

[email protected]

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Accessibility is about all of us

People with Disabilities: Statistics

World Wide

(2016) USA(2015) Texas(2015)

Total Population 7.4 Billion 317 Million 27 Million

Disabled 1.1 Billion (15%) 40 Million (12.6%) 3.1 Million (11.6%)

However, disabilities are no longer confined to traditional People with Disabilities • Maturing population • Temporary disabilities • Nonnative language speakers & low literacy

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What is Information and Communications Technology (ICT) Accessibility?

ICT accessibility ensures that people with and without disabilities can 1. access the same information 2. perform the same tasks 3. receive the same services

• Benefits our maturing population that has changing abilities caused by aging.

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Understanding Disabilities

Blind users access software applications and the Web using a screen reader and the keyboard.

“Machine type. Edit. Model slash version. Edit. Help to select multiple options. Link. Operating system slash platform. Listbox. Not selected AIX. 1 of 30.”

Low vision users need sizable fonts and contrast settings.

Font size

Larger font size

Even larger font size

Contrast Poor

contrast

Contrast Good

contrast

Font size & contrast

Users with limited use of arms and hands need keyboard accessibility

features and alternative input methods.

Key Types OS Keyboard Accessibility Features

Mouse Keys Arrow keys control mouse pointer

Sticky Keys [Ctrl] then [F] activates [Ctrl-F] shortcut

Slow Keys Ignore short keystrokes

Repeat Keys Turn off keystroke repeat Adjust delay before repeat begins Adjust delay between repeats

Alternative input hardware devices

Joy Sticks Keyboards

Switches Mouth Sticks

Deaf users need alternatives for audio content (captioning); the

hard of hearing need the ability to increase volume.

Color-blind users need more than color differences.

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IT Accessibility Regulations

There are IT accessibility laws and regulations in • Various countries around the world • US federal procurement regulations (Section 508) • Many US states Most cite accessibility technical standards Texas statutes and rules

• Apply to all Texas state agencies and institutions of higher education – Texas Government Code 2054 Subchapter M – Texas Administrative Codes 1 TAC 206: State Websites , 1 TAC 213: Electronic & Information Resources

Federal Procurement • US Section 508 Refresh approved by USAB. WCAG2.0 AA will be its new technical standard (1H17) US Department of Justice • In progress but delays in issuing final rules on website accessibility (Title II and III

entities) however • Has already taken the position that websites are considered places of public

accommodations and therefore should be accessible • Has intervened in public and private sector lawsuits on behalf of plaintiffs

http://www.statutes.legis.state.tx.us/Docs/GV/htm/GV.2054.htm

http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=1&pt=10&ch=206

http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=4&ti=1&pt=10&ch=213

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37% Increase in Accessibility Complaints in 2016

Mar 25, 2016

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Scenario: Online Recruiting

Corporation X just completed the procurement and deployment

of a large new web application for recruiting new employees and

managing job candidates.

Software Company A developed the product. Both Company A

and Corporation X’s studies indicated that the new system

would offer significant advantages in cost savings, productivity,

and candidate quality over the previous, mostly manual

processes.

Then….

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A Few Example Areas of an Organization Where ICT Accessibility Impacts Can Occur

• Internet site and applications development • Intranet site and applications development • Procurement • Sales • Legal / civil rights • Executive management • Internal / external communications / PR • Department / class required IT • HR (employees) • Learning tools (hw/sw) • System admin user interfaces • Student services • Business controls / compliance office • Etc.

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Reasons for Low ICT Accessibility Adoption

Technical challenges • Continued investments in inaccessible legacy products and platforms • Technology gaps due to omission of accessibility criteria during the creation of

new, ICT technology

Organizational Challenges • Lack of awareness of accessibility and its technical standards • Accessibility deemed unnecessary or optional • Accessibility understood too late in project / program to be addressed • Lack of technical skills, tools, or training programs • No organizational policies or objectives related to IT accessibility • No one responsible or accountable for accessibility

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ICT Accessibility is a Complex Topic

Requires a holistic approach with organizations • Many moving parts = many challenges

– Technical – Organizational – Legal – Cultural

• Multi year initiative – Speed, scope, and success of strategy execution dependent on

organization • Skills and training • Tools and processes • Budget • Level of management commitment / support

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How do I make my organization’s ICT accessible?

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Take a strategic approach

Start with a good Accessibility Policy which includes: • Who is responsible for ICT Accessibility and how will it be governed • Integration of ICT accessibility criteria into key / relevant business

processes • Method(s) for addressing inaccessible ICT including

– a plan / date for compliance of the ICT – an alternate means of access until the ICT is accessible

• Approach for ensuring competence in ICT accessibility through staff training and vendor resources

• Establishment of accessibility goals and methods to track progress

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Prioritize what needs to done

High # of ICT users = higher impact / risk: • Public facing websites and web applications • Intranet sites and internal applications • Desktop applications

Evaluate your organization’s application portfolio • What ICT is not accessible? • What would it take to fix / replace inaccessible ICT?

Weave ICT Accessibility into your organizations culture • Integrate accessibility criteria into key business process • Make ICT accessibility awareness training a requirement

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An Accessibility Framework

Organizational Components

Gain top level “buy-in” and set

organization expectation levels

Ensure accessibility policies are

defined

Develop strategy and

implementation plans

Create an organizational

model

Assess business needs and make

accessibility investments

Implementation Components

Plan Strategically

Automate for productivity and

quality

Validate thoroughly, early,

and often

Grow awareness and provide education /

training

Measure and track progress

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IT Accessibility Implementation Framework Template

Plan Strategically

• Obtain initiative support of organization executive team • Develop long term organization goals • Integrate into or develop processes to ensure consistency over time • Select appropriate IT technologies / suppliers • Effectively manage the IT accessibility exception process • Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) • Charter a workgroup with representation from key areas of the organization

Automate for productivity and

quality

• Provide developers tools to facilitate and remediate accessibility compliance • Integrate accessibility into content management systems / processes • Utilize standardized accessible templates (CSS, etc) • Ensure browser neutral accessibility • Utilize enterprise level scan tools for issue identification / resolution

Validate thoroughly, early, and often

• Test internally developed pages and applications • Test externally hosted services • Test Published documents / information • Perform analysis of vendor VPATs and test vendor solutions to validate • Develop or integrate corrective actions process management / tools

Grow awareness and provide education /

training

• Evangelize accessibility throughout organization / IT supplier community • Build / maintain organization’s technical capacity with SME’s • Identify skill gaps, and resolve via and training staffing plans

Measure and track progress

• Develop goal appropriate metrics, and reporting tools / methods • Communicate and utilize results to drive initiative trajectory • Maintain processes and results for “audit readiness” posture

Organization Work Plan

Develop strategy and

implementation plans

Plan Strategically Obtain initiative support of organization executive team Develop long term organization goals Integrate into or develop processes to ensure consistency over time Select appropriate IT technologies / suppliers Effectively manage the IT accessibility exception process Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) Charter a workgroup with representation from key areas of the organization Automate for productivity and quality Provide developers tools to facilitate and remediate accessibility compliance Integrate accessibility into content management systems / processes Utilize standardized accessible templates (CSS, etc) Ensure browser neutral accessibility Utilize enterprise level scan tools for issue identification / resolution Validate thoroughly, early, and often Internally developed pages and applications Externally hosted services Published documents / information VPAT analysis and testing of supplier solutions Corrective actions process management / tools Grow awareness and provide education / training Evangelize accessibility throughout organization / IT supplier community Build / maintain organization’s technical capacity with SME’s Identify skill gaps, and resolve via and training staffing plans Measure and track progress Develop goal appropriate metrics, and reporting tools / methods Communicate and utilize results to drive initiative trajectory Maintain processes and results for “audit readiness” posture

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Accessibility Program Framework: 3rd level detail

Creation of action plans, project plans, work breakdown structures, etc.

• Obtain initiative support of organization executive team • Develop long term organization goals • Integrate into or develop processes to ensure consistency over time • Select appropriate IT technologies / suppliers • Effectively manage the IT accessibility exception process • Maintain flexibility to adapt to criteria changes (508 refresh, WCAG 2.0, etc) • Charter a workgroup with representation from key areas of the organization

Organization Work Plan

Framework Component Work plan detailed line items Priority Status Owner Team Start Date

Target Completion

Actual Completion Dependencies

Integrate into or develop processes to ensure consistency over time

Review and modify as needed current process(s) for accessibility integration H Not Started ICTAC ICT dev 10-Oct 11-Jan PM Contracts


Determine appropriate processes and process tools for ICT Accessibility H Green ICTAC

Exec management

/ IRM 15-Sep 10-Oct None


Analyze process(s) effectiveness. Are they being followed? H Green ICTAC

Exec management

/ IRM 10-Oct 10-Jan None


Integrate accessibility criteria and the exception process into development phases M Not Started ICTAC ICT dev 10-Oct 11-Jan PM Contracts


Develop guidelines for integrating Accessibility development / test into project schedules H Not Started ICTAC ICT dev 10-Oct 11-Jan PM Contracts


Develop work sizing guidelines for development and test planning H Not Started ICTAC ICT dev 10-Oct 11-Jan PM Contracts

Creation of action plans, project plans, work breakdown structures, etc. Extends to action plan development and work breakdown structures Plan strategically line item: Integrate into develop processes to ensure consistency over time Work items associated with the line item that can be prioritized and planned Review and modify as needed current process(s) for accessibility integration Determine appropriate processes and process tools for IT Accessibility Analyze process(s) effectiveness. Are they being followed? Integrate accessibility criteria and the exception process into development phases Develop guidelines for integrating Accessibility development / test into project schedules Develop work sizing guidelines for development and test planning

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Identify Skill Gaps and Build “Role Based” Accessibility Training Plans

Course Level Course Title All Staff Web Content Producers

Web & Application

Testers

Web Application Developers

Procurement Staff

Contract Writers

Contract Compliance

Project Managers

Fundamentals Introduction to Accessibility (Self) Required Required Required Required Required Required Required Required

Fundamentals Office Documents (Internal) Optional Required Optional Optional Required Required Optional Required

Fundamentals PDF (Internal) Required / Optional* Required Optional Optional Required /

Optional* Required / Optional*

Required / Optional*


Fundamentals HTML (Internal or External) Required Required Required

Fundamentals HTML Forms (Internal or External) Required Optional Required

Fundamentals Testing & Tools (Internal or External) Required Required Required

Fundamentals CSS (Internal or External) Optional Optional Required

Fundamentals Javascript (Internal or External) Optional Optional Required

Advanced Sharepoint / Dreamweaver (Internal or External)


Advanced ASP / ASP.Net (Internal or External)


Advanced Java / JSP (Internal or External)


Advanced Web 2.0 Technologies (Internal or External)


Specialized Accessibility Law, and its Impacts Required Required Required Required

Specialized Accessibility in Contract Solicitations Required Required Required Required

Specialized Understanding/validating Vendor IT accessibility Required Required Required Required

* As needed based on assignment.

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Plan

Strategically Form an Organizational Accessibility

Workgroup

An interdepartmental team representing stakeholder areas of the organization that require or may be affected by IT accessibility • Facilitates progress in IT accessibility across the organization • Identifies inhibitors and works to resolve them as a team • Sponsors or leads IT Accessibility workgroup and subgroup efforts • Reports progress and issues to senior leadership • Solicits support of management and others as needed

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Measure and Track Progress

Set Short and Long Term Accessibility Goals: Example

Web Content: Public Facing and General

Access Intranet

Web pages • Maintain less than 2.5% pages with accessibility errors

PDFs • Reduction of inaccessible PDF Documents by 25% within 1 yr • 10% additional reduction each subsequent year

Non-PDF documents • Reduction of inaccessible non-PDF Documents 50% within 1 yr • 10% additional reduction each subsequent year

Validation • Select and procure accessibility web scanning tool for internet / intranet pages • Begin monthly scans and remediation of errors

Internal / External

Applications

New internally developed or purchased applications • 75% to be accessible

Existing applications • 10% per year increase in compliance of existing applications

Training

Intro level accessibility training to staff • 90% staff within 1 yr; remaining 10% in following year

Accessible Office Documents training • 50% staff trained within 1 yr; 50% balance in following year

Web developer accessibility training • 100% developers trained within 1 yr

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The Procurement Dependency

• Vendor sourced IT products / services make up the majority of state IT

• Most products / services do not meet accessibility technical standards • There will be high dependency on procured IT for the foreseeable

future • All states, federal agencies, and the private sector experience this

problem

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Technical vs governance barriers

Improvements in technology and development tools make creating accessible IT easier then ever before BUT

– Technical challenges remain; however, improved resources and tools are helping

– Pushing technical specifications/standards has not been an adequate adoption driver

• Technical standards are execution criteria not governance criteria

– Gaps in organizational commitment and governance models for accessible IT are still major obstacles

• Nothing in today’s technical standards address governance

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Converging Accessibility Governance Model Examples

Type Source Policy Requirements

Skills &Training

Requirements

Reporting Requirements

Organizational, Process & Planning

Requirements

Directive

Office of Management and Budget

Strategic Plan for Improving Management of Section 508

9 9 9 9

Statute Province of Ontario Canada Accessibility for Ontarians with

Disabilities Act (AODA) 9 9 9 9

Litigation Settlement

US DoJ HR Block PeaPod

9 9 9 9

Litigation Settlement

US DoE Youngstown State University

University of Montana

9 9 9 9

Note also settlements in higher ed and other government entities.

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Policy Driven Adoption for Accessibility (PDAA)

NASCIO Workgroup Launched in 2013 to develop a common set of ICT accessibility criteria and supporting deliverables • Representation from 10 states and 1 federal agency

The integration of IT accessibility governance into organization policies in a way that enables them to drive themselves to

improve accessibility adoption.

• Makes IT accessibility difficult to ignore • Not prescriptive, tells what, not how • Governed through non-technical methods • Accelerates marketplace innovations

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Policy Driven Adoption for Accessibility (PDAA) - Core Criteria

Core Criteria

Policy Creation 1. Develop, implement, and maintain an ICT accessibility policy.

Organization 2. Establish and maintain an organizational structure that enables and facilitates progress in ICT accessibility.

Business Process 3. Integrate ICT accessibility criteria into key phases of development, procurement, acquisitions, and other relevant business processes.

Compliance Planning 4. Provide processes for addressing inaccessible ICT.

Training 5. Ensure the availability of relevant ICT accessibility skills within (or to) the organization.

Communication 6. Make information regarding ICT accessibility policy, plans, and progress available to customers.

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PDAA Maturity Model

Core Criteria Launch Integrate Optimize 1. Develop, implement, and maintain an ICT

accessibility policy.

Have an ICT accessibility policy.

Have appropriate plans in place to implement and maintain the policy.

Establish metrics and track progress towards achieving compliance to the policy.

2. Establish and maintain an organizational structure that enables and facilitates progress in ICT accessibility.

Develop an organization wide governance system.

Designate of one or more individuals responsible for implementation.

Implement reporting/decision mechanism and maintain records.

3.

Integrate ICT accessibility criteria into key phases of development, procurement, acquisitions, and other relevant business processes.

Identify candidate processes for criteria integration.

Implement process changes. Integrate fully into all key processes.

4. Provide processes for addressing inaccessible ICT.

Create plans that include dates for compliance of inaccessible ICT.

Provide alternate means of access until the ICT is accessible; implement corrective actions process for handling accessibility technical issues and defects

Maintain records of identified inaccessible ICT, corrective action, and tracking.

5. Ensure the availability of relevant ICT accessibility skills within (or to) the organization.

Define skills/job descriptions.

Identify existing resources that match up and address gaps.

Manage progress in acquiring skills and allocating qualified resources.

6. Make information regarding ICT accessibility policy, plans, and progress available to customers.

Make Launch level information available.

Make Integrate level information available.

Make Optimize level information available.

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Questions for Vendors and Organizations on ICT Accessibility

Policy / Culture

Offerings

Can you provide a copy of, or link to the organization’s ICT Accessibility Policy? Yes Yes

Can you provide information regarding the organizational structure of the organization’s ICT Accessibility Program? (where the function(s) is located within the organization, title of program head, centralized vs. distributed personnel, etc.)

Yes

Can you provide documentation on key business processes that have ICT accessibility integrated into them? (Examples: product development, procurement, HR, etc.) Yes

Can you provide documentation on the integration of ICT accessibility activities into your development processes? Yes Yes

Can you describe the skills and training resources that your organization uses (internal or third party) to develop and produce accessible ICT offerings Yes Yes

What development tools, test tools, and methods does your organization use to produce accessible ICT offerings and its associated documentation (VPATs, etc.)? Yes

Can you provide examples of typical test cases used to validate accessibility and how test results are documented? Yes

Does your organizations have corrective actions process(es) or system(s) for documenting, tracking, and resolving accessibility issues / defects? Yes Yes

Are there work arounds or alternate methods for ICT products that are not compliant with accessibility technical standards. (example: 24hour / 7day/week toll free phone support number): Yes Yes

Can you provide links to websites or other examples of ICT work that your organization has produced that meet accessibility technical standards such as US Section 508, or WCAG 2.0 AA Yes

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PDAA in Practice – Texas Government

Texas DIR initiated use of PDAA in August 2014 for applicable Cooperative Contracts Solicitations

Vendors required to complete the PDAA assessment

• Results not scored as part of contract award criteria

• Recorded and compared to later responses in:

– Subsequent solicitations – Contract renewals

Over 200 vendors have submitted assessments to date

– Some vendors have submitted to multiple solicitations

Mechanism in place to make results available at customer requests

Link to NASCIO Briefing Papers on PDAA Link to DIR PDAA site

http://nascio.org/pdaa

http://dir.texas.gov/View-Resources/Pages/Content.aspx?id=39#Procurement

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What Do I Do If Someone Files a Complaint under the ADA?

Consult you legal team • Determine if the complaint is valid

– Have accessibility evaluation performed on cited ICT (website, web application, etc.)

– If valid, develop a plan to remediate

• Take the complaint seriously

– In ICT accessibility, effort and progress may be helpful

• Demonstrate and communicate progress against a framework or maturity model such as PDAA

• If possible, articulate and communicate to plaintiff on progress and plans to remediate the offending ICT

• Provide an appropriate alternate method of access or an accommodation for use until the ICT is deemed accessible

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ICT Accessibility Reference Information

Techcheck – On Line Assessment Tool developed by the Partnership on Employment and Accessible Technology (PEAT) and sponsored by the Office of Disability Employment Policy (ODEP), U.S. Department of Labor

W3C – Web Accessibility Initiative - Planning and Implementing Web Accessibility

British standard BS-8878 Implementation Guide - by Hassell Inclusion - Accessibility business process integration

Strategic IT Accessibility: Enabling the Organization – Reference book on organizational accessibility enablement, strategy, and implementation

Digital Accessibility Maturity Model (DAMM) from SSB Bart Group - A Capability Maturity Model based framework to help digital accessibility programs measure ICT development against an objective yardstick

Accessibility Implementation Framework, Texas Department of Information Resources - A comprehensive framework and project plan to guide an organization’s IT accessibility program and initiatives

http://peatworks.org/techcheck/get-started

http://peatworks.org/

http://peatworks.org/

http://www.dol.gov/odep/

http://www.w3.org/WAI/

http://www.w3.org/WAI/managing.html

http://www.w3.org/WAI/managing.html

http://www.hassellinclusion.com/landing/book/

http://strategicaccessibility.com/

http://info.ssbbartgroup.com/WBN14-10-16DAMM_Compliance-Monitor_Follow-up-Gateway.html

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Thank You

Questions?

[email protected] 512.426.9779

mailto:[email protected]