Internet Accessibility Policy

Introduction

Most organizations will benefit from a formal agency wide Section 508 Internet Policy. Effective policies have three important components. They:

1. Establish and define roles and responsibilities
2. Identify technical and functional requirements
3. Identify tools and resources available to responsible parties and stakeholders.

Best Practice Guidelines

Roles

There are at least three roles to define and assign responsibilities. Some organizations may require additional segmentation but most will fit within these three categories:

• The Section 508 Coordinators Office
  • Office or group responsible for Section 508 compliance or oversight
• Agency Webmasters
  • Web administrators or content managers posting content and ensuring multiple agency web requirements are being met before content is posted on the Internet
• Agency Content Owners
  • Parties that submit content the Webmasters including electronic documents, videos, web application projects, pod casts, etc.

This Best Practice outlines a delegation between the Webmaster and Content Owner, but also recognizes that additional delegation opportunities exist depending on an organizations structure. When identifying roles, allow for additional delegation, but clearly identify who the ultimate responsible parties are.
 

Responsibilities

The Section 508 Coordinator's Office

• Maintain Agency Minimum Technical Requirements for Web Accessibility
  • These can be Section 508 standards or agency interpretation of the 508 standards
  • Agencies may choose to break these requirements out separately for different types of content (i.e. HTML, electronic documents, video, etc.)
• Evaluate and approve all Agency Web Templates for Web Accessibility
  • This is vital toward achieving greater efficiency and uniformed testing of repetitive content
• Evaluaute and approve all Accessibility Testing Tools and Testing Procedures/Guidance
  • Having everyone use the same tools and procedure, and testers all working from the same testing guidelines, will produce a uniformed result and metrics

The Agency Webmasters

• Responsible for Section 508 compliance of the Web content they post to the Internet.
• Require written certification from the Content Owners for non-HTML content, or HTML content they have not inspected themselves (i.e. web application that was tested by the application development team)
• Responsible for remediating identified accessibility issues for the web content they manage

Content Owners

• Responsible for certifying the content they submit for posting is Section 508 compliant
• Responsible for remediating accessibility issues for the web content they author
• Responsible for seeking internal/external assistance for authoring and/or testing content

Identify Requirements

Many agencies will choose to point to the Section 508 standards without any interpretation or alteration. Others may choose to apply agency specific requirement. Either way, segmenting requirements by content type has proven to be much more effective than just pointing to the Section 508 requirements as a whole. Each of the categories can then identify only those requirements associated with that specific content type, and although there is significant technological convergence underway, often authors and developers are more easily identified by content type.

Avoid embedding technical or functional requirements into the policy to ensure a flexible and sustainable policy. Executive approval of this type of policy will likely be time consuming and difficult, so build a policy that allows for evolving technical standards by making them external to the policy. The following categories should address most agency Internet content:

• Web Pages and Web Applications
• Adobe PDF Documents and Forms
• Microsoft Word
• Microsoft Power Point
• Microsoft Excel
• Video
• Audio
• Flash
• Live and Recorded Web Events

Identify Tools and Resources

The effectiveness of an agency Web policy is dependent on the guidance and resources available to responsible parties and stakeholders. The Web policy should point stakeholders and responsible parties to targeted guidance and assistance.

A list of resources in the web policy is highly dependent on many factors:

• Agency organizational structure
• Distribution and hierarchy of Webmasters and Content Owners
• Section 508 Office approach to managing compliance (policy oriented, services oriented, terms of service oriented, etc.)
• Breadth and depth of internal Section 508 resources and/or willingness to point to outside resources
• Section 508 testing/vetting policies and procedures in place
• Level of accessibility awareness and expertise distributed throughout the agency
• Training programs in place and their effectiveness

A web policy should not compel all responsible parties to become accessibility experts, and therefore, pointing to targeted resources is important. A list of standards, although useful to understanding accessibility, is not effective in helping developers create accessible content. Best practice libraries with specific code example, electronic document accessible authoring guides, and hands on training, whether from within an agency or outside of the agency, are integral to a successful Web policy.

Here is a list of some example resources the policy may want to point readers to:

1. Best Practices Library for HTML components
2. Closed captioning guidance, services, or assistance
3. Testing tool guidance, training, procedural guides, and assistance
4. Electronic document authoring guidance, training, and remediation services
5. A list of vetted and/or approved browser embedded multi-media players
6. Browser embedded interactive or time based content guidance (Java, Flash, etc.)
7. List of vendor consultants and task order contracts available to the agency
8. Forums, email lists (listserv) , wikis, and social media sites that may be useful
9. Training courses (online and instructor lead)

Benefits and Justification

• The size and scale of Internet content is too large for a Section 508 Office to assume on its own, so delegating authority and responsibility is more efficient and less costly.
• Defining roles and assigning responsibilities addresses agency legal obligations and compels responsible parties to be proactive in planning, development, and validation of web content.
• Remediating accessibility issues, especially for web applications, is expensive and time consuming causing considerable cost overruns and project delays.
• Agency Internet sites are highly visible and increasingly the primary touch point for the public, businesses, and other government agencies, so exposure to legal and financial risks are high.
• The Section 508 standards are currently being refreshed, and a policy that points to external requirements will adapt well to new and evolving standards.

Monitoring and Metrics

There may be other policies necessary to ensure success with this best practice, and performance monitoring of agency web content is chief among them. Automated web testing tools can handle a lot of the HTML content, but since the policy covers much more than what automated web testing tools can monitor, processes and procedures for monitoring these content types should be included in monitoring practices. Other performance metrics should be combined with automated testing tool results. For instance, if individual development groups or the Section 508 office have separate testing procedures for web applications, those results should be combined if the automated tools do not monitor those systems. Electronic documents that are tested and/or remediated should be included in reporting metrics, and agencies should develop ways to measure the percentage of captioned videos, the number of transcripts for podcasts, etc.