Strategic Approach to IT Accessibility

A Strategic Approach to IT Accessibility Jeff Kline, Statewide Accessibility Coordinator Texas Department of Information Resources October, 2011 1

Scenario: Online RecruitingCorporation X had just completed the procurement and deployment of a large new web application forrecruiting new employees and managing job candidates. Company A Software developed the product.Both Company A and Corporation X’s studies indicated that this system would offer significantadvantages in cost savings, productivity, and candidate quality over the previous, mostly manualprocesses.• A highly qualified applicant, Cynthia, attempts to search for and apply for jobs on their website, but she is blind and the new website is not accessible.• Cynthia tries to contact Corporation X by sending an email to the main Corporation X address. After a week or so, it found its way to the recruiters. She identifies herself as blind and requests help searching and applying.• A week or so after receiving Cynthia’s note, a representative of Corporation X contacts Cynthia and tells her that someone would get back to her “soon” to take her application by phone.• After several weeks, Cynthia is very frustrated and shares her issue on a popular, large internet forum for the blind, and her discussion thread attracts a lot of attention. During that time, the jobs she was qualified for were closed and the positions filled.• An attorney from a well-known advocacy group active on the blind forum contacts her about her problem and commits to contact Corporation X regarding the accessibility of their website and its impacts.• After several months of back and forth discussions and negotiations, the attorney concludes that Corporation X is stiff-arming him, so the advocacy group files a class-action lawsuit alleging discrimination under the Title III of the ADA. Corporation X then sues Company A for selling them an inaccessible product.Prior to this event, accessibility was not on the radar at Corporation X or Company A. Corporation X hadnever asked about accessibility during the requirements or procurement process, and Company A neverconsidered accessibility when it developed the application. 2

Approaching EIR accessibility holistically Why is it important to my organization? Getting started Organizing Accessibility Costs and Funding Models Stakeholder areas of an organization Developing strategies and implementation plans 3

Accessibility is about all of us. Disabilities are no longer confined to traditional definitions, especially with the growing need to embrace aging workforces and citizens. World Wide USA Total Population 6 Billion 281 Million Disabled 750 Million (16%) 54 Million (19%) Nonnative languagePeople with Disabilities Aging speakers & low literacy Temporary disabilities 16% of world By 2025 nearly 20% of the Globalization is driving many Everyday situations population is disabled* industrialized nations’ people to communicate in disable certain senses population will be over 65 nonnative languages temporarily 4

Other DemographicsTen percent of the world’s population (more than 600M people) lives with life-alteringdisabilities (vision, hearing, speech, cognition, and mobility).Two-thirds of people with disabilities live in developing countries.Disability is a key driver of poverty: 70 percent of blind people in the United States areunemployed.The U.S. Department of Labor estimates that people with disabilities have an aggregateannual income of nearly $700 billion, including $175 billion in discretionary spending power.Between 2011 and 2031 the phenomenon of aging baby boomers will cause the variousmarkets of consumers with disabilities to converge and expand dramatically. U.S. adultsolder than fifty are estimated to have more than $1.7 trillion in discretionary spending powerand $17 trillion of net worth.Source: ―The Missing Link: Financing the Industry,‖ a 2007 paper by Barry K. Fingerhut of Synconium Partners 5

New, emerging, and evolving standards & guidelines driveaccessibility requirements around the world United States Federal Laws US Sections 504, 508 Section 504 of the 1973 Rehabilitation Act ADA Amendments • Prohibits organizations and employers from Act excluding or denying individuals with disabilities an equal opportunity to receive program benefits andInternational services. Link to section 504 of the rehabilitation Act of 1973Standards EU Mandate 376 Americans with Disabilities Act (ADA) of 1990 • National mandate to eliminate discrimination against people with disabilities. Link to ADA act of 1990 WCAG 2.0 UN Convention on Rights of Section 508 of the 1973 Rehabilitation Act ATAG 2.0 PwDs (Amended in 1998) • Applies accessibility standards to procurement and development of electronic and information technologies by federal government agencies. Link to section 508 of the rehabilitation Act of 1973 China Law on the Protection of 9241-171 Disabled People Canada Accessibility for Ontarians with Disabilities Act United Kingdom Equality Act 6

State Accessibility LawsAt least 21 states have explicit statutes orexecutive orders.At least 6 states have accessibility policies.Most reference Section 508.All have procurement requirements. 7

State of Texas Accessibility Laws & RulesTexas Administrative Code • 1 TAC Chapter 206: State Web Sites  Subchapters B: State Agency Web Sites  Subchapter C: Higher Education Web Sites • 1 TAC Chapter 213: Electronic & Information Resources  Subchapter B: Accessibility Standards for State Agencies  Subchapter C: Accessibility Standards for Higher EducationTexas Government Code 2054.456 Access to Electronic & Information Resources by State Employees w Disabilities 2054.457 Access to Electronic & Information Resources by Other Individuals w Disabilities 8

Accessibility-related litigation & legal inquiries in the U.S. Will pay up to $16 million to compensate individuals who experienced discrimination in violation of Title III of the Americans with Disabilities Act (ADA) Sued by NFB for inaccessible website. Settlement of $6M not including legal expenses, site remediation, and other incidentals. Major tech company and State of TX sued by NFB – Software is inaccessible to blind State of TX employees. PMI (US-based organization) sued in UK due to inaccessible training application. Sued by DoJ for ADA violations. Settlement terms: must provide accommodations for deaf and hard of hearing students. Fined by State of N.Y. for special pricing available only on inaccessible websites. Sued by NFB and state employees because web applications were inaccessible to the blind. Settled. Sued by individuals. Inaccessible online services included in ruling. ADA settlement over inaccessible ATMs. 9

The Case for IT AccessibilityCompetitive advantage Ability to compete and win in markets, sectors and solicitations where accessibility is a requirement Increased market share – Raku Phone SEO benefits Socially responsible messaging Direct and indirect workforce benefitsRisk Mitigation Bid losses External / internal litigation - ADA violations HR issues – Hiring and employment practices, etc. Negative PR 10

The Case for IT Accessibility: ExampleFujitsu Raku-Raku Cell Phone Developed by Fujitsu for the Japanese market. Requirements of People with disabilities included in design specifications Features and functions benefit all users, including those with age-related and other disabilities. • Large screens with the ability to display large letters • One-touch calling and programmable buttons • A ―text-to-speech‖ function for mail and websites • A ―speech-to-text‖ device for composing mail • An integrated text-to-speech player for books and the like Result: more than 80 percent of Japan’s visually impaired use the Raku-Raku phone Over 20 million Raku-Raku phones were sold between 1999 and June 2009. 11

A Few Reasons Why IT Accessibility Doesn’t HappenNo awareness of the requirement for accessibility or considered optional—abonus rather than a requirement.Awareness of the requirement was too late to be addressed. ―The project neededto be accessible? Well, it’s too late now—we’ll do it next time.‖No organizational policies or objectives or related to IT accessibility. ―I’m usingour existing development process, and I don’t see anything about accessibility.‖No awareness of previous projects having been made accessible.No one responsible for overseeing accessibility.No accessibility skills or training programs in accessibility.Employees with skills in IT accessibility were reassigned, unavailable, or left theorganization. 12

What organizational areas may be affected by ITAccessibility? (a non-exhaustive list) Product development Internal IT Web commerce and communications Procurement HR Acquisitions Legal Advertising and marketing communications Internal communications Education and learning Business controls / compliance office Medical / occupational health 13

Getting StartedObtain executive buy-in Develop an IT accessibility policy Create an executive presentation or ―sell‖ package Create a team of SME’s to develop the • Clearly articulate the need for an accessibility program policy The ―big stick‖ Gain the commitment of top executives in the form Foundation on which other aspects of of resources (human and financial) IT Obtain an executive sponsor or ―champion‖ to accessibility are developed oversee and guide the program Should not be voluminous or contain technical specs Leverage, similar existing policies 14

Organizing AccessibilitySenior manager ―executive sponsor‖―Neutral‖ organizational placement • Analysis of implications based reporting organizationCentralized accessibility function • Policy and governance • Technical consulting • Business development / sales support • Project officeSub-Unit focal points / coordinators 15

Program CostsDetermining Factors Speed and trajectory of the IT accessibility initiative driven by • urgency based on business or other requirements • Budget considerations Startup and ongoing costs Start-up Investment Ongoing Investment Cost Type Element Level Level Human resources Enterprise/organization staffing High Medium Human resources External consulting Medium/high Low/very low Human resources Subunit/2nd-level subunit coordinators Low Low Human resources Overall Initiative management Medium Low Human resources Policy and process creation integration Medium Low Human resources Training Medium Medium Human resources Manual testing Medium Medium/high Human resources Accessibility development Low Medium Human resources Management system development Medium Low Human resources Marketing support (private sector) Medium Low IT hardware/ software Tracking/reporting tools Medium Very Low IT hardware/ software Enterprise scan tool(s) Medium Low IT hardware/ software Enterprise scan tool maintenance Low Low IT hardware/ software Developer tools Medium Low IT hardware/ software Test tools Medium Low IT hardware/ software Development and test tool maintenance Low Low IT hardware/ software IT hardware (desktop computers, etc.) Low Low IT hardware/ software IT service (database hosting, etc.) Low Low 16

Funding Models Centralized Accessibility ―Corporate‖ or total organizational level funding • Relatively small when the organization is large Sub-unit ―taxation‖ • Tax units based on size, revenue, cost of operations, etc. • Can involve negotiations and line item detail Centralized Accessibility as a ―Cost Center‖ • Viable after program is up and running Hybrid Models Unit / Subunit Accessibility Focal point / coordinator funded at unit sub-unit level Accessibility implementation factored into development / IT budgets as any other resource • in-house (preferred) or contracted 17

Developing an accessibility strategyKey elements of an organization’s IT accessibility strategy Rationale for the IT accessibility program Business objectives definition Linkage to the organization’s IT accessibility policy and relevant standards, regulations, and policies A description of the role of accessibility in the organization’s primary business or service strategies Assumptions, dependencies, and risks Definitions of high-level organizational and governance models Funding, budget, and other broad financial coonsiderations A strategic framework for developing operational work plans 18

An IT Accessibility Framework Template • Obtain initiative support of agency executive team • Develop long term agency goals • Integrate into or develop processes to ensure consistency over time Plan Strategically • 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 • Provide developers tools to facilitate and remediate accessibility compliance Automate for • Integrate accessibility into content management systems / processes productivity and • Utilize standardized accessible templates (CSS, etc) quality Organization • Ensure browser neutral accessibility Work Plan • Utilize enterprise level scan tools for issue identification / resolution • Internally developed pages and applications • Externally hosted services Validate thoroughly, • Published documents / information early, and often • VPAT analysis and testing of supplier solutions • Corrective actions process management / tools Grow awareness • Evangelize accessibility throughout organization / IT supplier community and provide • Build / maintain organization’s technical capacity with SME’s education / training • Identify skill gaps, and resolve via and training staffing plans • Develop goal appropriate metrics, and reporting tools / methods Measure and track • Communicate and utilize results to drive initiative trajectory progress • Maintain processes and results for ―audit readiness‖ posture 19

Prioritize the work effortPriority classification hierarchy* example 1. Externally facing, mission critical, high number of external users (includes all Internet pages) 2. Externally facing, non-mission critical, high number of external users 3. Externally facing, mission critical, low number of external users 4. Externally facing, non-mission critical, low number of external users 5. Internal use, mission critical, high number of users Prioritized 6. Internal use, non-mission critical, high number of users Applications Template 7. Internal use, mission critical, low number of users 8. Internal use, non-mission critical, low number of users*Priority classification assumptions 1. New applications/application enhancements entering pilot (user acceptance) test phase (Internet or intranet) should receive priority within the priority class (1–6) 2. New applications/application enhancements under development (Internet or intranet) will receive priority within the priority class (1–6) 3. Priority for individual applications may change based upon business needs 20

Identify skill gaps and build“Role Based” Accessibility Training Plans Web Web & Web Knowledge General State Procurement Contract Contract Project Course Title Population Office Content Application Application Staff Writers Compliance Managers Level Producers Testers Developers Introduction toFundamentals Required Required Required Required Required Required Required Required Required Accessibility (Self) Office DocumentsFundamentals Optional Required Required Optional Optional Required Required Optional Required (Internal) PDF (Internal) Required /Fundamentals Required Optional Optional Optional* HTMLFundamentals Required Required Required (Internal or External) HTML FormsFundamentals Required Optional Required (Internal or External) Testing & ToolsFundamentals Required Required Required (Internal or External) CSSFundamentals Optional Optional Required (Internal or External) JavascriptFundamentals Optional Optional Required (Internal or External) Dreamweaver Required / Advanced (Internal or External) Optional* ASP / ASP.Net Required / Advanced (Internal or External) Optional* Java / JSP Required / Advanced (Internal or External) Optional* Web 2.0 Technologies Required / Advanced (Internal or External) Optional* Accessibility Law, and its Specialized Required Required Required Required Impacts Accessibility in Contract Specialized Solicitations Required Required Required Required Understanding/validating Specialized Vendor EIR accessibility Required Required Required Required* As needed based on assignment. 21

Develop short and long term accessibility goals: ExampleWeb Content: Public Web pagesFacing and GeneralAccess Intranet • Maintain less than 2.5% pages with accessibility errors PDFs • Reduction of inaccessible PDF Documents 25% by end of fiscal 2011 • Reduction by 10% each subsequent year Non-PDF documents • Reduction of inaccessible non-PDF Documents 50% by end of fiscal 2011 • Reduction by 20% each subsequent yearValidation • Select and procure accessibility web scanning tool for internet / intranet pages • Begin monthly scans and remediation of errorsInternal / External New internally developed or purchased applicationsApplications • 75% to be accessible Existing applications • 10% per year increase in compliance of existing applicationsTraining Intro level accessibility training to staff • 90% Agency Staff by end of fiscal 2011; Remaining 10% in following year Accessible Office Documents training • 50% staff trained by end of fiscal 2011; 50% balance in 2012 Web developer accessibility training • 100% developers trained by end of fiscal 2011 22

Putting it all together Set organization expectation levels • Multi-year initiative • Dynamic, with course and trajectory adjustments as needed Ensure accessibility policies and objectives are well defined Business needs and make accessibility investments Prioritize the accessibility work Develop strategy and plans using an Accessibility Framework Identify accessibility skill gaps and develop training plans Develop short / long term goals and measure to them 23

Thank youjeff.kline@dir.texas.gov 24

Strategic Approach to IT Accessibility

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