Web Accessibility Working Group

Transcription

1 Web Accessibility Working Group Revision History Maintained by: Eva Grabinski Last updated by: Jonathan Woodcock, Karen Jack Last updated on: March 13, 2013 Revision copies at: accessibility Table of Contents Revision History... 1 Recommendations... 3 Abbreviations... 4 Members of Working Group... 4 Objectives of Working Group... 5 Accountability... 5 Legislation... 5 Accessibility for Ontarians with Disability Act (AODA)... 5 Related Legislation... 6 University s Position... 6 Scope... 6 Websites that Fall Under the AODA Legislation... 6 Outside of Scope... 6 Internal or Intranet Sites... 6 Software or Web Based Applications... 6 Benefits Beyond Legal Compliance... 7 Website Content and the AODA Legislation... 7 Examples of Website Content... 7 Written Content... 7 Web Graphics... 7 Documents... 7 Interactive Content... 8 Archival Documents on Publicly Facing University Websites... 8 Website Design and Development and the AODA Legislation... 8 Internal Communications... 9 Audiences... 9 Channels... 9 Processes... 9 Internal Review of Websites for Compliance with Accessibility Legislation

2 Description... 9 Recommendation Legal Notification of Non Compliance with Website Accessibility Legislation Description Recommendation Procuring Web Services and Technologies for Publicly Facing University Websites Description Recommendation Website Accessibility Training for Existing and New Website Maintainers Description Recommendation Training and Support Resources Internal Resources Central Location Listing Resources Training Courses Through Skills for the Electronic Workplace (SEW) Technologies that Support Web Accessibility Templates for Accessible Documents Client Service Support External Resources Peer Institutions Staffing Risk Assessment Technical Risks University Websites Inconsistently Implemented Limited Tools for Generating Accessible Web Alternatives for Publications/Documents Financial Risks Budget for Recruiting / Hiring Internal Experts in Web Accessibility Budget for Professional Development of Internal Experts in Web Accessibility Budget for Procuring External Expertise in Web Accessibility Operational Risks Communicating AODA Website Requirements Given Organizational Size and Structure Not Specifying AODA Requirements in Procurement of Web Services Procuring Web Services from Vendors With Inadequate AODA Knowledge Implementing a Website Accessibility Training Program for All Website Maintainers Geographic Risks Compliance of International Websites with AODA Requirements Time Risks Migration Schedule for Moving Publicly Facing University Websites Into WCMS Scheduling of Updates to Publicly Facing University Websites Not In WCMS Training and Support Staff in Place with Web Accessibility Expertise Before Deadline Training Maintainers of Publicly Facing University Websites Before Deadline Unavailability of External Experts on Web Accessibility Around Deadline Human Resource Risks Limited External Web Services Providers with AODA Web Accessibility Expertise Lack Website Accessibility Training and Support Plan Developer and Coordinator Inadequate Number of Internal Web Accessibility Experts for Campus Wide Support Gaps in Web Accessibility Expertise in Particular Areas

3 Legal Risks Website Content in WCMS Websites Compliance with AODA Requirements Internal Process for Checking Accessibility of Publicly Facing University Websites Notification or Fine from Provincial Government for Non Compliance Independent Legal Notification of Non Compliance of Website(s) Assuming Legal Risk for Deliverables from Web Services Providers Political Risks Resistance to Changes Needed to Meet AODA Website Requirements Leadership Championing of Need to Meet AODA Website Requirements Recommendations 1. Draft a University Policy to address compliance with legislated web accessibility requirements: draft a University Policy that addresses governance for compliance with the AODA legislated requirements for Ontario University websites. 2. Draft and implement a web accessibility training and support plan for University website maintainers: draft and implement a training and support plan for the University s approximately website maintainers (including training plans and schedules, required courses, required templates/tools, and a client service support model). 3. Develop and hire staff with expertise in web accessibility to provide University wide support for meeting legislated web accessibility requirements: develop and hire staff with expertise in web accessibility to provide training and support (including courses and hands on help) to the University s approximately website maintainers. 4. Procure services in web accessibility where required to support meeting legislated web accessibility requirements: define areas where external expertise in web accessibility is required (e.g., training, audits, testing, conversion of documents to accessible formats) and procure required services. 5. Draft and implement a University wide communications plan on legislated web accessibility requirements and related support: draft and implement a University wide communications plan to inform areas about web accessibility, the Accessibility for Ontarians with Disabilities Act (AODA) legislated requirements, and related information (e.g., available training and support). 6. Specify and implement procurement requirements for external providers of web services to meet legislated web accessibility requirements: specify and implement a procurement process requiring service providers that create or maintain University websites (including website content such as text, graphics and videos) to deliver deliverables that comply with AODA legislated website requirements. 7. Define and implement a website accessibility audit process: define and implement an audit process for checking the compliance of University websites with AODA legislated website requirements, and provide client service support 3

4 to areas that need to update their websites for AODA compliance based on audit findings. 8. Draft recommendations for archival content on University websites within the context of legislated web accessibility requirements: draft recommendations for the publishing of archival content that predates January 1, 2012 and resides on publicly facing uwaterloo websites accounting for AODA legislated website requirements. 9. Contact peer institutions to learn about their website accessibility plans and resources: contact peer institutions in Ontario to learn about their staffing models, training courses, budgets and templates/tools to support their website maintainers in complying with AODA legislated website requirements. Abbreviations Abbreviation Description AODA Accessibility for Ontarians with Disabilities Act CECA Co operative Education and Career Action COU Council of Ontario Universities CPA Communications and Public Affairs CTSC Computing Technology and Services Committee FACCUS FACulty Computing User Support Group FEDs Federation of Students IST Information Systems and Technology SEW Skills for the Electronic Workplace program SMC Social Media Committee STAC Student Technologies Advisory Committee TBD To be determined UCIST University Committee on Information Systems and Technology uwaterloo University of Waterloo WAC Web Advisory Committee W3C The World Wide Web Consortium WCAG 2.0 Web Content Accessibility Guidelines 2.0 WCMS Web Content Management System Members of Working Group Eva Grabinski (CPA, chair) Karen Jack (Secretariat) Liam Morland (IST, web technologies accessibility) Rose Padacz (AccessAbility Services) Laura Pfanner (IST, enterprise software applications and procurement) Susan Shifflett (AccessAbility Services) Andrea Sweet (CPA, web graphics accessibility) Lisa Tomaltly (IST, web documents accessibility) 4

5 Heather Wey (IST, web training and support specialist) Jonathan Woodcock (CPA, web content accessibility) Objectives of Working Group With AODA website accessibility legislation coming into effect, many website maintainers at uwaterloo have questions about website accessibility requirements: what the requirements are; how to meet the requirements; training and support available; university governance on website accessibility. The goal of this working group is to identify and address gaps in information, training and support required for uwaterloo website maintainers pertaining to the AODA website accessibility legislation. Accountability The working group is accountable to: Web Advisory Committee (WAC) Web Steering Committee University administration leading AODA compliance at uwaterloo Legislation Accessibility for Ontarians with Disability Act (AODA) The Accessibility for Ontarians with Disabilities Act (2005) (AODA) aims to make Ontario barrier free, allowing everyone, regardless of disability, to be able to participate fully in society. This includes the ability to browse and use websites. Under the Act, the requirements relating to websites are in the Integrated Accessibility Standards, Ontario Regulation 191/11, Section 14. The requirements are defined in terms of the W3C s Web Content Accessibility Guidelines (WCAG) 2.0. WCAG 2.0 specifies a number of guidelines (such as having alt text for images), which contribute to making an accessible website. There are three levels to WCAG 2.0: Level A, Level AA, and Level AAA. Each level builds upon the previous one. Level A provides a basic level of accessibility, but using the website may still be cumbersome for users. Level AA provides a highly accessible web experience. Level AAA provides maximum accessibility, but it is widely acknowledged that compliance at this level may not be possible or feasible for many websites. The legal requirements that apply to uwaterloo are summarized as follows: 5

6 By January 1, 2014, websites created or significantly refreshed after January 1, 2012 must conform to WCAG 2.0 Level A. By January 1, 2021, all websites must conform to WCAG 2.0 Level AA (with two exceptions relating to captions and audio descriptions for video). January 1, 2012 is a key date: anything created or significantly refreshed on or after that date must be made to follow WCAG 2.0 Level A. Some existing sites will have to be revised to meet this requirement. Related Legislation Canadian Charter of Rights and Freedoms: lois.justice.gc.ca/eng/const/page 15.html Ontario Human Rights Code: human rights code University s Position uwaterloo Accessibility Plan: services/policy/university waterloo accessibilityplan Scope Websites that Fall Under the AODA Legislation The AODA legislation applies to all websites controlled, directly, or indirectly through a contractual relationship, by uwaterloo that are accessible to the public. Compliance with the legislation is required by all publicly facing uwaterloocontrolled websites. The legislation applies to the code, templates and content (text, graphics, videos) of publicly facing uwaterloo websites. Examples of websites that the AODA legislation applies to include: faculty, department, school, research, support unit, and university college websites. Outside of Scope Internal or Intranet Sites Websites that are internal (i.e., password protected internal sites or intranets) used to privately and securely share University information fall outside of the scope of this document. However, other law covers accommodation for employees and students with disabilities who require access to content on internal sites or intranets. Questions about providing accessible content for internal sites or intranets can be directed to AccessAbility Services ( Software or Web Based Applications Today, many software applications are web based or produce web content. Any publicly facing web pages or web content generated by these applications can fall 6

7 under the AODA legislation. Consideration to AODA legislation must be given by uwaterloo in the purchasing and development of software or web based applications. Procurement and development of software or web based applications fall outside of the scope of this document. Questions about AODA and software or web based applications can be directed to Information Systems and Technology ( Benefits Beyond Legal Compliance As an educational institution competing for student enrollment our websites are key communications and marketing tools. To maximize our audience reach, we need search engine optimization and websites that are accessible and usable by the largest number of visitors possible keeping in mind not only those with disabilities but those limited by their environment, bandwidth, or mobile device. A website featuring consistent design with clear and logical navigation; simple language with text that is easy to scan; understandable links; good color contrast; text descriptions of essential visual elements; and transcripts or captions for audio, video, and multimedia content improves the experience of all users. Visitors achieve their goals efficiently and this positive experience with our websites translates into a positive impression of the University. Website Content and the AODA Legislation Examples of Website Content This section provides examples of website content that falls under the AODA legislation. If there is this kind of content on a uwaterloo website, then it needs to be accessible (including but not limited to): Written Content Colour (text and background) Headers Links Lists Tables Text Web Graphics Colours in graphics Images of text Informational graphics (e.g., pie charts) Moving or flickering graphics or effects Documents Excel 7

8 PDF PowerPoint Word Interactive Content Audio files Forms Image maps Plug ins (e.g., Flash) Videos Archival Documents on Publicly Facing University Websites Legal opinion on the status of archival material on publicly facing uwaterloo websites is required. Archival information would include old publications, old meeting minutes, old academic calendars, old theses, and the like. For example, several University websites have a large number of research papers going back decades. Most of these research papers are PDFs that are scans of paper documents. Electronic files of these research papers no longer exist and thus accessible PDFs cannot be easily created. Section 14 of the Integrated Accessibility Standards states that all websites and content on those websites must be accessible by January 1, Making all of the University s scanned PDFs accessible for January 1, 2014 is not feasible. To comply with legislative requirements, is the only option to remove these scanned PDFs from public access? Doing so clearly makes the information much less available. Is it a reasonable interpretation of the legislation that current information on websites must be accessible and archival information from before January 1, 2012 can be left as is? Archival information dated prior to January 1, 2012 could be indicated as being made accessible on demand. Of course, on demand is not a substitute for something being accessible from the start, but is preferable than the information being completely unavailable. Website Design and Development and the AODA Legislation Website design and development impact on the accessibility of websites. As such, website designs (e.g., templates) and website development (e.g., code) are affected by the AODA legislation. Website design and development must be implemented such that AODA legislative requirements for websites are met and supported. Attention must be paid to the following in website design and development (including but not limited to): HTML, CSS, JavaScript, frames, plug ins. 8

9 Internal Communications This section addresses internal communications about the legislation as it pertains to uwaterloo websites, and internal communications about training and support available to help areas at the University comply with the legislation. Audiences Students employed by uwaterloo (coop, work study, part time, casual, research assistants, teaching assistants, etc.) Faculty members Staff members Anyone working on behalf of uwaterloo or as an agent of uwaterloo who creates or maintains a uwaterloo website Channels Communications Council Computing Technology and Services Committee (CTSC) Cooperative Education and Career Action (CECA) Daily Bulletin (uwaterloo.ca/bulletin) Executive Council Faculty Computing User Support Group (FACCUS) Federation of Students (Feds) Graduate Students Association Faculty Association IST Friday Morning Seminar Leadership Forum Social Media Committee (SMC) Student Technology Advisory Committee (STAC) Undergraduate Marketing Roundtable University Committee on Information Systems and Technology (UCIST) WatITis Conference Web Advisory Committee (WAC) Web Maintainers E Mailing List Web Resources Website (uwaterloo.ca/web resources) Processes Internal Review of Websites for Compliance with Accessibility Legislation Description Random audits of publicly facing uwaterloo websites to test for compliance with AODA legislative requirements are proposed to help areas and the University in general comply with the legislation. Staff with expertise in website accessibility will be required to conduct the audits. While website accessibility testing tools are available to assist with audits, the tools alone are insufficient to assess compliance: 9

10 human review of website code, design and content are required. Importantly, training and support need to be available to areas that are audited and are required to make corrections to their websites to meet AODA legislated website requirements. Recommendation Specify and implement an audit process for checking the compliance of University websites with AODA legislated website requirements. Legal Notification of Non Compliance with Website Accessibility Legislation Description Members of the University community may receive notice from outside parties claiming that a website does not meet legislated accessibility requirements. Recommendation Anyone who receives notice that a website does not meet legislated accessibility requirements should not respond to it and instead should redirect the notice to the Secretariat ( us) for response. Procuring Web Services and Technologies for Publicly Facing University Websites Description External service providers that create or maintain University websites must deliver code, design, and content (e.g., text and graphics) that comply with AODA website accessibility legislated requirements. Incorporating legislated website accessibility requirements into contracts for website development, website design, and website content creation is required. This needs to be part of the procurement processes managed by Procurement and Contact Services. As well, since many contracts for website services are not managed by Procurement and Contract Services, areas must be informed of this requirement in procuring contracted website creation and maintenance services. Recommendation Writing accessibility requirements into RFPs and contracts for website design, web development, and/or web content provision (e.g., text, graphics, videos). Website Accessibility Training for Existing and New Website Maintainers Description Students The University regularly hires students (coop, work study, part time, casual, research assistants, teaching assistants, etc.) to work on web applications, web technologies, and web content. Training of these students is required to help ensure that the work done by these students complies with website accessibility legislated requirements. 10

11 Staff It is estimated that approximately university staff members create and maintain University websites, including website content and web technologies. Training current and future staff in website accessibility is required to help ensure that the University s websites meet website accessibility legislated requirements. Faculty Many faculty members have publicly facing uwaterloo websites. Training of these faculty members is required to help ensure that their websites comply with website accessibility legislated requirements. Recommendation Draft and implement a website accessibility training and support plan for the university s website maintainers. Training and Support Resources Internal Resources Central Location Listing Resources Web Resources Website: resources/ Training Courses Through Skills for the Electronic Workplace (SEW) Training courses are an effective way to help University website maintainers learn about AODA website accessibility requirements. Given the very high number of University website maintainers (approximately 2000+), it is recommended that more than one staff member be available to deliver a particular training course so that backups for training courses always exist. The table immediately below lists courses identified that would be of benefit to University website maintainers; additional courses may be identified over time. Course Offered Staffing Resources Accessible Website Design and Development Yes Internal (1) Creating Accessible Audio Files No TBD Creating Accessible Numerical Content No Internal (1) Creating Accessible PDFs from PowerPoint No TBD Creating Accessible PDFs from Word Yes Internal (1) Creating Accessible Tables for Websites No Internal (1) Creating Accessible Web Graphics Yes Internal (1) Producing Accessible Videos No TBD Testing Your Website for Accessibility No TBD Writing Accessible Web Content Yes Internal (1) 11

12 Technologies that Support Web Accessibility Central uwaterloo Web Content Management System (WCMS) The WCMS is a huge boon for accessibility. It takes care of much of the work of creating a website and ensuring that the website is accessible. The WCMS generates the navigation menus and other webpage parts that appear on more than one webpage, and it does this in a way that is accessible. Content maintainers need only be concerned about making their own website content accessible. The WCMS helps with this by providing prompts, tools and tips within the editing interface to assist content maintainers, who also have training available to them via the uwaterloo SEW program. For example, the WCMS requires that content maintainers provide a text alternative for every image, thus benefiting users with particular visual impairments. The WCMS allows content maintainers to easily create web forms in an accessible way. Content maintainers can define fields to be filled in or questions to be asked. They can define the validation rules, such as mandatory fields or the format of a number. The WCMS takes care of generating the HTML code, which displays the form in the web browser in an accessible way. The tools available in the WCMS allow for the creation of accessible equivalents for existing PDF files that are not accessible. Content maintainers can create an HTML version of a document, upload the PDF file to the WCMS, and link to the PDF file from the HMTL page. Forms that currently exist on paper or as PDF files can be recreated in the WCMS as web forms, replacing the inaccessible form with one that is accessible. Templates for Accessible Documents The availability of accessible templates for various types of documents regularly produced as part of University operations can assist areas with the creation of accessible documents. Importantly, any documents placed on uwaterloo publicly facing websites must comply with AODA legislated requirements. Compliance with AODA legislated requirements for documents can be achieved in two ways: the posting of an accessible document on the website and/or the creation of an equivalent accessible website or webpage for the document. Templates identified thus far are listed in the table immediately below. It is recommended that this list be reviewed to identify if any other templates are needed to support areas across the University in meeting website accessibility legislated requirements. Template Available Staffing Resources PowerPoint Templates No CPA 12

13 Letterhead No CPA Meeting Agendas No IST Meeting Minutes No IST Reports / Plans No IST Theses No IST Client Service Support Client service support staff with expertise in web accessibility and related AODA legislated requirements need to be readily available (e.g., via phone and ) to provide support to areas across the University in meeting AODA legislated website requirements; importantly, the web accessibility support staff must be knowledgeable in website development, design and content. The number of client service staff members that will be required to support the approximately website maintainers at the University needs to be determined as part of a training and support plan. It is also expected that support staff will have expertise in different areas of website accessibility (e.g., website development vs. website content). It is recommended that each support staff member has at least two areas of expertise so that the University has more than one human resource trained in a particular area of website accessibility. External Resources COU Web Accessibility Toolkit for Information and Communications Standard: advocacy/accessibility/accessible toolkithomepage/information communications standard WAVE Web Accessibility Evaluation Tool: Web Content Accessibility Guidelines (WCAG) 2.0 Quick Reference: WebAim Color Contrast Checker: Peer Institutions It is recommended that peer institutions in Ontario be contacted to learn about: Their staffing models to support AODA website accessibility compliance (including internal and contracted resources). Training courses they have available to help their website maintainers with AODA website accessibility compliance. Templates they have available to help their website maintainers with AODA website accessibility compliance. Budgets they have allocated to meeting AODA accessibility compliance. 13

14 It is recommended that the following universities in Ontario be contacted: Laurier, McMaster, Ottawa, Queen s, Toronto, and Western (based on proximity and U15 membership). Staffing Based on information gathered thus far, the following roles are recommended to support the University s compliance with AODA website accessibility legislation: Website Accessibility Training and Support Coordinator (1) Website Accessibility Auditor (1+) Website Accessibility Client Services Support Staff (number TBD; minimum 4) Website Accessibility Training Course Developers (number TBD) Website Accessibility Training Course Instructors (number TBD) Contracted Website Accessibility Experts (number TBD) Risk Assessment This section addresses risks associated with uwaterloo s ability in meeting legislated accessibility requirements for January 1, Technical Risks Technical risks focus on the technical capabilities of the organization: technical implementations that do not or may not support the requirements; or technical implementations that do not exist and would help in meeting the requirements. University Websites Inconsistently Implemented University websites are inconsistently implemented. For example, some University websites are: in the WCMS; created via Dreamweaver and apply variations of the University s Common Look and Feel for uwaterloo websites; implemented in different WCMSs and/or have unique designs. This inconsistent implementation poses a risk to meeting legislated AODA website requirements. High (since only 200+ websites are in the central WCMS). High (since it is infeasible to move all websites into the central WCMS before the compliance deadline in AODA comes into effect). Continue moving University websites into the WCMS; implement a Universitywide communications plan to communicate about legislated AODA website requirements; provide training and support on web accessibility and AODA website requirements for website maintainers University wide. Increase the number of staff on the WCMS team to increase the rate of migration of University websites into the WCMS. Limited Tools for Generating Accessible Web Alternatives for Publications/Documents Limited tools exist for University website maintainers to create or convert publications/documents into accessible formats for posting on University 14

15 websites. For example, tools are required to support accessible online versions of University annual reports, magazines and theses. The accessible online formats could be the publications/documents themselves, and/or could be equivalent accessible websites/webpages for the publications/documents. Tools for generating equivalent accessible websites/webpages would help University wide website maintainers meet AODA requirements. Moderate (The WCMS provides some support for generating accessible equivalents for publications/documents; however, functionality is still required for various types of publications/documents such as annual reports, magazines and theses). High (Resources are limited on the WCMS team for allocating to such tools/functionality). Develop tools in the WCMS for generating equivalent accessible websites/webpages for publications/documents. Hire external contractors to develop tools for the WCMS for generating equivalent accessible websites/webpages for publications/documents. Financial Risks Financial risks focus on budget allocations to address the legislated requirements; financial risks address whether enough money has been allocated to properly address the requirements. Short term costs and long term costs need to be addressed in assessing financial risks. Budget for Recruiting / Hiring Internal Experts in Web Accessibility A specific budget has not been specified and allocated for the recruitment/hiring of internal full time experts in web accessibility. Moderate (While the University would benefit from recruiting/hiring internal experts in web accessibility, the University can also invest in the professional development of existing staff in web accessibility). High (Given that more work needs to be done on defining the web accessibility expertise required by the University, it is expected that recruitment/hiring of internal experts in web accessibility could be delayed beyond the date that the compliance deadline in AODA comes into effect). Define critical high priority human resources required to support accessible University websites in compliance with AODA (e.g., expertise lacked among existing staff, number of client service staff to provide campus wide training and support), and submit a request for hiring such mission critical staff. Provide professional development in web accessibility to existing uwaterloo staff; hire external experts in web accessibility on an as needed basis. Budget for Professional Development of Internal Experts in Web Accessibility While staff members in certain support units (e.g., IST, CPA) are already receiving professional development in web accessibility to provide campuswide support, a specific budget for the training of particular staff as internal experts in web accessibility has not been specified and allocated. Areas where there are needs and gaps in expertise in web accessibility for providing campus wide support need to be defined, and particular staff members need professional development (e.g., training) to obtain the required expertise in order to provide campus wide support. Moderate (Staff members in certain support units are already receiving professional development to provide campus wide support; however gaps 15

16 exist in certain web accessibility areas, such as video production). Moderate (Some professional development is underway and is likely to continue). Define gaps in expertise; identify staff members who can provide campuswide training and support; obtain professional development for the staff in areas where there are gaps. Hire external experts to provide campus wide support in certain areas of web accessibility. Budget for Procuring External Expertise in Web Accessibility A specific budget allocated to procurement of external expertise (e.g., consultants, trainers, contractors) has not been allocated, and there are some gaps where external expertise could be beneficial in supporting uwaterloo to meet legislated AODA web accessibility requirements. Moderate (Staff members in certain support units, such as IST and CPA, are already receiving professional development to address some of the gaps in areas of web accessibility to help provide campus wide support; however gaps still do exist in certain web accessibility areas, such as video production. It is expected that the cost to procure external expertise will rise immediately before and after the January 1, 2014 deadline due to demand). High (It is expected that budget may not be allocated in time to procure external expertise in time to meet the AODA deadline of January 1, 2014 for web accessibility compliance). Define areas where there are notable gaps in web accessibility knowledge at uwaterloo (that is, areas where there is notably little or no internal expertise), and focus on allocating budget to procuring external expertise for these gaps. Assess what knowledge already exists internally campus wide, and the level of expertise of each of the staff members in the respective areas of web accessibility; use this information to inform where procurement of external expertise should be focused. Professional development of existing uwaterloo staff in areas of web accessibility where there are currently gaps. Note that obtaining training services may prove more difficult and/or expensive around the January 1, 2014 AODA deadline. The workload of current staff also needs to be accounted for in assessing who should receive professional development and who can provide campus wide support in particular areas of web accessibility. Operational Risks Operational risks address how things are done in the organization and how this can be an impediment to meeting the requirements. Operational feasibility includes considerations such as procurement processes, external vendors, organizational structure, etc. Communicating AODA Website Requirements Given Organizational Size and Structure Areas regularly express that they are unaware of AODA website requirements (e.g., when migrating to the WCMS). While communications about AODA website requirements have been delivered via various channels (e.g., Web Advisory Committee, UCIST, Communications Council), communications are not reaching all University website maintainers. High (This poses a significant risk for hundreds of uwaterloo websites not meeting AODA legislated accessibility requirements in time for the January 1, 16

17 2014 deadline). High Draft and implement a University wide communications plan to inform areas campus wide about web accessibility, the Accessibility for Ontarians with Disabilities Act (AODA) legislated requirements, and related information (e.g., available training and support). Incorporate information about web accessibility, the Accessibility for Ontarians with Disabilities Act (AODA) legislated requirements, and related information (e.g., available training and support) into the initiation/onboarding of newly recruited staff and faculty. Increase training and support staff on the WCMS team to increase the rate of migration of University websites into the WCMS; supplement this with training in web content accessibility for University website maintainers. Not Specifying AODA Requirements in Procurement of Web Services Legislated AODA website accessibility requirements need to be part of the procurement process of external web services (e.g., web development, web design, web content production) in support of University websites. Some web services involve the Procurement and Contract Services Office; as such, the Procurement and Contract Services Office can work to ensure that AODA requirements are part of the procurement process where required. However, many areas across the University procure external web services without going through the central Procurement and Contract Services Office, and without knowledge about the legislated AODA website accessibility requirements. High (Areas across the University regularly procure web services, including web development, web design and web content production. The risk of receiving deliverables that do not comply with AODA requirements where required is high, and the related risk of rework to meet AODA requirements is high). High (Areas across the University regularly procure web services, including web development, web design and web content production. The risk of areas procuring web services without specifying legislated AODA website accessibility requirements is high). Work with the Procurement and Contract Services Office to ensure that any RFPs/contracts for web services provision (e.g., web development, web design, web content production) include legislated AODA web accessibility requirements. As part of University wide communications about web accessibility and AODA, include information about the need to include legislated AODA web accessibility requirements in RFPs/contracts. Implement an internal auditing process to check compliance of University websites with legislated AODA web accessibility requirements. Procuring Web Services from Vendors With Inadequate AODA Knowledge In procuring web services (e.g., web development, web design, web content production), some vendors may claim knowledge of AODA but may deliver deliverables to uwaterloo that fail to meet the legislated AODA web accessibility requirements. High (The University could be subject to widespread sign offs or acceptance of deliverables that do not meet, but are required to meet, legislated AODA web accessibility requirements based on current and dispersed procurement practices at the University). High (The probability of occurrence is high due to dispersed procurement practices that do not require central oversight, and due to the complexity of 17

18 communicating University wide the need to comply with legislated AODA web accessibility requirements). Establish pre approved vendor lists of suppliers that can provide web services (e.g., web development, web design, web content production) in compliance with legislated AODA website requirements. Work with the Procurement and Contract Services Office to ensure that any RFPs/contracts for web services provision (e.g., web development, web design, web content production) include legislated AODA web accessibility requirements to transfer risk to web services providers. As part of University wide communications about web accessibility and AODA, include information about the need to include legislated AODA web accessibility requirements in RFPs/contracts. Implement an internal auditing process to check compliance of University websites with legislated AODA web accessibility requirements. Implementing a Website Accessibility Training Program for All Website Maintainers The large number of Website maintainers employed by the University and the dispersed nature of the organization make the delivery of training to all University website maintainers difficult. High (The delivery of AODA training University wide impacts a significant number of website maintainers across the University, with the number of University website maintainers estimated at around 2000+). High (The delivery of AODA web accessibility training to all University website maintainers is difficult due to the large size and organizational structure of the University). Include information about the University s requirement to meet AODA requirements (including web accessibility) in new staff and faculty initiation/onboarding processes. Draft and implement a University wide communications plan to inform areas campus wide about web accessibility, the Accessibility for Ontarians with Disabilities Act (AODA) legislated requirements, and available training and support. Ensure adequate trainingand support resources exist to provide training and support to all University website maintainers. Implement an internal auditing process to check compliance of University websites with legislated AODA web accessibility requirements. Geographic Risks Geographic risks address risks associated with having resources (e.g., staff, technical capabilities) geographically dispersed, making the ability to meet requirements difficult or infeasible. Compliance of International Websites with AODA Requirements Because uwaterloo is headquartered in Ontario, its international websites must comply with AODA legislation (even if these websites are not hosted in Ontario by uwaterloo). The ability to train uwaterloo website maintainers internationally and to address internationally hosted uwaterloo websites poses a challenge. Low (It is expected that only a limited number of uwaterloo websites hosted internationally exist). High (It is expected that all or most uwaterloo websites hosted internationally do not comply with AODA requirements). Online training courses on legislated AODA web accessibility requirements 18

19 offered via the main uwaterloo campus headquartered in Ontario. Hosting of international websites in the University s central WCMS where feasible. Auditing of uwaterloo websites hosted internationally. Migration of international websites hosted outside of Ontario into the University s central WCMS where feasible. Time Risks Time risks focus specifically on schedule risks for the University associated with meeting the AODA requirements by January 1, Migration Schedule for Moving Publicly Facing University Websites Into WCMS The University s central WCMS ensures that the website development and design of uwaterloo websites comply with legislated AODA web accessibility requirements (note that the WCMS cannot guarantee the accessibility of web content entered into the WCMS by University website maintainers). The migration of University websites into the WCMS increases the likelihood of compliance of University websites with legislated AODA web accessibility requirements. However, the current rate of migration of uwaterloo into the University s central WCMS means that most University websites will not be in the WCMS before the AODA deadline date of January 1, High (most university websites will not be migrated into the WCMS before the AODA deadline date of January 1, 2014; only about 25% to 30% of the University s ~1200 websites will be migrated into the WCMS before the AODA deadline date of January 1, 2014). High (only about 25% to 30% of University websites will be migrated into the WCMS before the AODA deadline date of January 1, 2014). Temporarily increase staff on the WCMS team to increase the rate of migration of University websites into the WCMS. Provide web accessibility training and support in compliance with AODA to website maintainers across the University responsible for maintaining websites outside of the University s central WCMS. Training and support could be provided in several ways, including via internal University staff or external service providers. Scheduling of Updates to Publicly Facing University Websites Not In WCMS A large number of University websites (60% to 75% of the University s ~1200 websites) will not be hosted in the University s central WCMS by the AODA deadline date of January 1, The University s central WCMS ensures that the website development and design of uwaterloo websites comply with legislated AODA web accessibility requirements (note that the WCMS cannot guarantee the accessibility of web content entered into the WCMS by University website maintainers). Note, not all websites can be migrated into the University s central WCMS due to specific features or functionality not available in the WCMS. High (60% to 75% of the University s ~1200 websites will not be hosted in the University s central WCMS by the AODA deadline date of January 1, 2014). High (many areas across the University are still unaware of legislated AODA web accessibility requirements). Draft and implement a University wide communications plan to inform areas campus wide about web accessibility, the Accessibility for Ontarians with 19

20 Disabilities Act (AODA) legislated requirements, and available training and support. Provide web accessibility training and support in compliance with AODA to website maintainers across the University responsible for maintaining websites outside of the University s central WCMS. Training and support could be provided in several ways, including via internal University staff or external service providers. Temporarily increase staff on the WCMS team to increase the rate of migration of University websites into the WCMS. Training and Support Staff in Place with Web Accessibility Expertise Before Deadline Having the required number of internal training and support staff in place with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support to University website maintainers to meet the AODA deadline of January 1, High (there are ~1200 University websites and ~2000+ University website maintainers; there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support campus wide to University website maintainers) High (there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support campus wide to University website maintainers) Allocation and professional development of existing uwaterloo staff to provide web accessibility training and support campus wide. Supplemented by the procurement of external experts in web accessibility to provide campus wide support to University website maintainers in meeting the AODA deadline of January 1, Procurement of external experts in web accessibility to provide campus wide support to University website maintainers in meeting the AODA deadline of January 1, Note, it may be difficult or more expensive to procure external expertise in web accessibility during the time before and shortly after the AODA deadline date of January 1, Training Maintainers of Publicly Facing University Websites Before Deadline There are ~1200 University websites and ~2000+ University website maintainers; there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide campus wide training to University website maintainers before the AODA deadline of January 1, High (there are ~2000+ website maintainers who require training in legislated AODA web accessibility requirements) High (there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide campus wide training) Allocation and professional development of existing uwaterloo staff to provide training campus wide. Supplemented by procurement of external experts in web accessibility to provide campus wide training to University website maintainers in meeting the AODA deadline of January 1, Procurement of external experts in web accessibility to provide campus wide training to University website maintainers in meeting the AODA deadline of January 1, Note that it may be difficult or more expensive to procure 20

21 external expertise in web accessibility during the time before and shortly after the AODA deadline date of January 1, Unavailability of External Experts on Web Accessibility Around Deadline It is expected that external web accessibility experts will be difficult to procure just before and just after the AODA legislated deadline of January 1, Moderate (uwaterloo has internal expertise across most areas of legislated AODA web accessibility requirements). Moderate (Depending on the area of web accessibility expertise and where the experts are based, variability is expected in their availability). Identify gaps in web accessibility expertise required by uwaterloo to meet AODA requirements, and proceed with procuring external web expertise in these gap areas. Invest in hiring and professional development of internal staff to obtain the web accessibility expertise required to meet areas of web accessibility legislated under AODA. Human Resource Risks Resource risks address whether the organization has enough human resources, and whether the resources are the right resources with the required skills and expertise. Limited External Web Services Providers with AODA Web Accessibility Expertise It is expected that there are a limited number of external service providers with AODA web accessibility expertise. High (many areas across the University procure external web services, and many of the web services providers do not have AODA web accessibility expertise with many being entirely unaware of AODA). High (many web services providers do not have AODA web accessibility expertise with many being entirely unaware of AODA; due to this, web service providers with AODA web accessibility expertise are expected to be in high demand). Research available web services providers with AODA web accessibility expertise, and establish a pre approved vendor list of suppliers that can provide web services (e.g., web development, web design, web content production) in compliance with legislated AODA website requirements. Increase the number of staff on the WCMS team to increase the rate of migration of University websites into the WCMS. Lack Website Accessibility Training and Support Plan Developer and Coordinator A full time allocated human resource is required to develop a campus wide web accessibility training and support plan for University website maintainers, and to coordinate the campus wide web accessibility training and support outlined in the plan. This human resource currently does not exist. High (allocating a full time resource to plan and coordinate campus wide training and support in web accessibility for University website maintainers will significantly improve the probability of University website maintainers receiving the required training and support). 21