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Results of Questionnaire 3rd Party Content

The results of this questionnaire are available to anybody.

This questionnaire was open from 2021-07-08 to 2021-07-13.

12 answers have been received.

Jump to results for question:

  1. Clarifying that exemptions are not the intention
  2. Definitions
  3. Authoring tools and other digital product building technology
  4. Overall approach

1. Clarifying that exemptions are not the intention

Does this version sufficiently clarify that exemptions are not the intention of the proposal?

Summary

ChoiceAll responders
Results
Agree 5
Agree with the following changes 2
Disagree for the following reason 5

Details

Responder Clarifying that exemptions are not the intentionComments
John Foliot Agree
David MacDonald Disagree for the following reason It may not be the "intention" to create an exemption in order to make a conformance claim for sites that include 3rd party content, but that appears to be *exactly* what the proposal allows.

> WCAG 2.x does not give direction to site owners or authors to do more to improve the accessibility of third party content if they can't make it fully accessible.

WCAG 2.x does not provide exemptions for 3rd party content, which ends up putting positive pressure on the environment to ensure that all content on the site conforms, including 3rd party content. WCAG 2.x is a page by page conformance model, and every page that is declared in scope would need to conform.

> WCAG 2.x does not give direction to site owners or authors to do more to improve the accessibility of third party content if they can't make it fully accessible.

WCAG doesn't need to provide guidance to web authors on how to talk to 3rd party vendors to either procure a conforming service or put pressure on the 3rd party to conform. This is part of procurement negotiation and outside the scope of WCAG. WCAG is like a measuring stick. The WCAG 2 conformance model is
"If a site conforms to these WCAG 2.x guidelines the site will be more accessible to those with disabilities."
Do we want to say instead
"If a site conforms to these WCAG 3.x guidelines the site will be more accessible to those with disabilities except we don't have any responsibility for the content or services we procure from others to present to you, the user."
Laura Carlson Disagree for the following reason Unless I missed it, this proposal does not explicitly state in the actual text that would go into the WCAG 3 draft that exemptions for 3rd party content are not the Working Group's intention.

In addition the proposal seems backward to me. IMHO the conformance group should:

1. Investigate current ways to make third party content more accessible.
2. Document those ways.
3. Do a gap analysis.
4. Figure out and propose ways to incentivize more accessible 3rd party content and services in WCAG 3.
5. Discuss/survey if exemptions for inaccessible 3rd party content and services would help or hurt accessibility for users in WCAG 3.
6. Reach consensus.
7. Add text to the WCAG 3 draft.

It seems we are starting out with wanting to do steps 5-7 with the goal of getting exemption text into the next draft. It seems premature to me.

Hi Janina, Thank you for the links. I will check them out. You asked, "What should WCAG say about such content at the Library of Congress?" WCAG 3 should say that it is insufficient and "Sub-Bronze". Perhaps consider having a WCAG 3 "Substandard" or "Locked Out" Level. I am not saying libraries shouldn't publish such things. I am saying that they should be labeled "Substandard" or "Sub-Bronze" because some people with disabilities are indeed locked out of that content.
Janina Sajka Agree Hi, Laura: Thank you for reminding us all of the important steps that should always be followed when developing new technology and technology standards. I'd like to believe wWe've been doing what you describe and I think our minutes archive linked on our main wiki page https://www.w3.org/WAI/GL/task-forces/silver/wiki/Substantial_Conformance show exactly that. The Google doc also on that page as a number of the other use cases we've considered.
Alternative text in User Generated content is not the only case we've considered, but please also notice there are only 5 guidelines in the latest WCAG 3 Working Draft. We would be getting ahead of ourselves to write third party considerations when the first party ones haven't yet been written. We're very much interested in use cases that may not have been handled yet as well as we might like, whether those are third party or first party use cases. Please note the example we provide with this proposal. What should WCAG say about such content at the Library of Congress?
Cybele Sack Disagree for the following reason Clarifying that an exemption is not the intention is a good start, but more is needed.

If the goal is to increase the accessibility of third party content, the proposal should begin there. This proposal has been edited but it would help to start with the type of process outlined by Laura Carlson and previously by Sarah Horton.

I agree with the comments written above by Laura Carlson and David MacDonald.
Peter Korn Agree with the following changes The clarification would be clearer if the 2nd sentence were instead to read:

"Under WCAG 2.x, site owners are permitted to ignore inaccessible third party content by making a claim partial conformance which places that inaccessible third-party content outside of their conformance statement."

Further, the Problem Statement would likewise be clearer if the second paragraph were to start:

"In these cases, the only Conformance options available..."
Sarah Horton Disagree for the following reason The version states that an exemption is not the intention but the details of the proposal seem to contradict that. Here’s what I think is being proposed:

To achieve WCAG 3 conformance, 3rd party content and services will not need to meet WCAG 3 technical requirements (guidelines, outcomes, methods, tests). Instead, authors that use 3rd party content and services will need to follow processes and procedures and presumably document the actions they take and update that procedural documentation over time.

Even if we don’t intend to provide an exemption for 3rd party content and services, the effect is an exemption—3rd party content and services will be exempt from following WCAG 3 technical requirements.

The additional processes and procedures are definitely beneficial, but we are losing something pretty significant by allowing barriers. What does this mean for all the contexts where WCAG is the measure of accessibility, e.g., court orders, laws, policies, if “WCAG compliance” can include barriers that prevent users from accessing content and services?
Rachael Bradley Montgomery Agree with the following changes In addition to the heading, I suggest add to the first sentence: "This proposal is intended to improve the accessibility of third party content, not exempt it from accessibility requirements."
Bruce Bailey Agree Please see @@ Sarah Horton's paraphrase in this survey.

@Peter and @Janina -- is Sarah's take a fair paraphrase? If not, why not?
Ben Tillyer Agree
Jeanne F Spellman Agree
Michael Gower Disagree for the following reason I remain concerned about this approach:
> site owners are permitted to declare inaccessible third party content as partial conformance which is then outside of their conformance statement

This seems like a pretty broad 'exemption', given that one of the portions of this content is "author arranged".There needs to be more onus put on the author to procure responsibly. If the author no longer needs to pressure the 3rd party, a major catalyst for the 3rd party content becoming more accessible is lost.

2. Definitions

Are the definitions now easier to understand?

Summary

ChoiceAll responders
Results
Agree 7
Agree with the following changes 1
Disagree for the following reason 2

(2 responses didn't contain an answer to this question)

Details

Responder DefinitionsComments
John Foliot Agree
David MacDonald Agree with the following changes If we allow any third party content to be exempt, then it should just be for user generated content, not for content the company procures. The rationale is that the company has more control over procured services than user feedback etc.
Laura Carlson Disagree for the following reason The relationship between the user and the product owner does not need to be defined in WCAG 3.0. Silver already has scaled scoring and all challenges should be considered equally as a single scale within WCAG 3.0. Best to avoid all the added complexities that a user generated definition would add.

With that said, I also agree with David MacDonald. "If" the working group does agree that any third party content is to be exempt, then it should just be for user generated content, not for content that an organization procures.

I fear this proposal would lead to less accessible content than in WCAG 2.X. Organizations could and many more would:

1. Choose to use third party content to avoid having to conform.
2. Not care about procuring accessible third party products or services, if they are not responsible for its conformance.

This could be disastrous for educational institutions and students with disabilities, not to mention users with disabilities who use heath care and banking products and services.

Hi again Janina, as previously mentioned, I am not saying libraries shouldn't publish legacy content. I am saying that they should be labeled "Substandard" or "Sub-Bronze" because some people with disabilities are indeed locked out of that content.
Janina Sajka Agree Thanks, Laura. I agree that LOC content isn't accessible. But what WCAG rule covers it? SC 1.4.2 is the closest, it seems; but, it talks about typesetting terms like "fonts," not about handwritten content. There's another important historical archive of handwritten content at the Israel Museum here: http://dss.collections.imj.org.il/. There are tens and tens of thousands of such pages in various academic and governmental archives around the planet. Are we saying these libraries shouldn't publish such things? Or, are we saying they can't possibly conform to WCAG bercause we haven't figured out how to make them accessible? Neither answer seems right to me.

Thanks, Laura. I'm starting to think we're saying the same thing with different words. If you consider the Steps to Conform spelled out in our proposal wiki: https://www.w3.org/WAI/GL/task-forces/silver/wiki/Proposal_on_Third_Party_Content#Author_Arranged_Media_Content, I think we've specified how to 1. tell people there's an accessibility problem with the content; 2. describe that problem; and (possibly) 3. file a bug report. Doesn't that seem fair if we don't have WCAG guideline for something? Like the LOC and Israel Museum content?
I know we wrote our guidance for Third Party conformance, and I still believe there are Third Party situations like that. But, the truth of the matter with the LOC and Israel Museum examples is that those are both First Party content for which we have no guidance. In these examples it's not even about licenses or copyright. We just don't have guidance for lots of historical content--certainly everything from before the printing press, and much of what was created before there was such a thing as the world wide web.
Cybele Sack Disagree for the following reason I agree with comments by Laura Carlson and David MacDonald.

We should not be incentivizing the use of third party content to avoid responsibility to improve accessibility.
Peter Korn Agree
Sarah Horton
Rachael Bradley Montgomery Agree
Bruce Bailey Agree
Ben Tillyer Agree
Jeanne F Spellman Agree
Michael Gower The definitions are easier to understand, but they also seem pretty loose. Is it a possible situation where a company contracts their whole website out to someone and can then issue a 'clean' conformance claim?

3. Authoring tools and other digital product building technology

Is it clear that authoring tools and other digital product building technologies are not part of of third party proposal?

Summary

ChoiceAll responders
Results
Agree 5
Agree with the following changes 2
Disagree for the following reason 3

(2 responses didn't contain an answer to this question)

Details

Responder Authoring tools and other digital product building technologyComments
John Foliot Agree
David MacDonald Agree with the following changes
Laura Carlson Disagree for the following reason The relationship between the user and the product owner does not need to be defined in WCAG 3.0. Silver already has scaled scoring and all challenges should be considered equally as a single scale within WCAG 3.0. Best to avoid all the added complexities that a user generated definition would add.

With that said, I also agree with David MacDonald. "If" the working group does agree that any third party content is to be exempt, then it should just be for user generated content, not for content that an organization procures.

I fear this proposal would lead to less accessible content than in WCAG 2.X. Organizations could and many more would:

1. Choose to use third party content to avoid having to conform.
2. Not care about procuring accessible third party products or services, if they are not responsible for its conformance.

This could be disastrous for educational institutions and students with disabilities, not to mention users with disabilities who use heath care and banking products and services.
Janina Sajka Agree Hi Again, Laura: I think you've misunderstood what we're trying to say here. Perhaps we should have said it better. We agree that people are responsible for the tooling they use and its consequences, just as they are for the accessibility of their published content. We're proposing to investigate whether we can provide WCAG conformance outcomes that could help authors pick tooling that is more likely to result in accessible published content. There's nothing like that today and authors are very much on their own. Does that help?
Cybele Sack Disagree for the following reason
Peter Korn Agree
Sarah Horton
Rachael Bradley Montgomery
Bruce Bailey Agree
Ben Tillyer Agree
Jeanne F Spellman Agree with the following changes I would like to add the suggestion from Sarah Horton to include an Authoring Service example.
Michael Gower Disagree for the following reason I didn't really get that impression. It certainly doesn't seem to be explicit. The phrase appears 4 times in the doc.

4. Overall approach

Do you agree with the approach of including third party guidance in the individual guidelines?

Notes:

  • Because the outcomes and methods are undergoing structural revision by different groups, we did not include specific outcomes.
  • We probably still will have general guidance for steps to improve accessibility if it is not covered by specific guidelines.

Summary

ChoiceAll responders
Results
Agree 6
Agree with the following changes 1
Disagree for the following reason 4

(1 response didn't contain an answer to this question)

Details

Responder Overall approachComments
John Foliot Agree
David MacDonald Disagree for the following reason I don't agree with the problem statement. There appears to be an assertion that there are only 2 options if a company has inaccessible 3rd party content ("remove it" or "don't conform") I think that is a coarse analysis of what really happens on the ground in a WCAG 2 environment. There are more options:

3) Pressure the 3rd party to remediate their non conforming content by auditing their content and providing a list of fixes to be remediated and allowing the authoring company's accessibility consultant to interact directly with the third party. (I've done this with at least 10 third parties on behalf of corporate clients. 3rd parties are usually eager to fix their non conforming products but didn't know where to start.).
4) If there is no budget for #3, pressure the 3rd party to remediate the non-conforming content with the threat of finding an accessible alternative provider. (This has been successful in several engagements I've been involved with)
5) Provide fixes after page load with JavaScript (adding labels, alt text, keyboard handlers, etc...) Almost every major A11Y consultancy offers this service for emergency accessibility of non editable pages (Deque, PGI, Level Access, etc.)
6) etc...

In the steps to conform section:

> Encourage the providers of that third party content to make it fully accessible; and

How well did "encouraging" providers to meet WCAG 2.x AAA work out? "Encouragement" does very little in today's environment.

===
It think there are more types of pressure that we can put on 3rd parties besides "user creating the content has a legal relationship with the organization that owns the site or product, e.g. employees and contractors."

I'm thinking specifically about checkout systems, user rating services (1 to 5 stars etc.), booking services, shoping tunnels, etc... where there is a contractual relationship, procurement practices, and market forces can be used to pressure the 3rd party to remediate their inaccessible offerings

NOTE:
The AODA (Ontario, Canada) uses these categories for "not practicable"
- accessible commercial software or tools or both are not available;

And most laws have a similar exception. I could accept something like that where there would be market advantage to an accessible service provider.
Laura Carlson Disagree for the following reason I don't agree with the problem statement. As stated in my answer to question #1, the proposal seems backward to me. IMHO the conformance group should have:

1. Investigated current ways to make third party content more accessible.
2. Document those ways.
3. Do a gap analysis.
4. Figure out and propose ways to incentivize more accessible 3rd party content and services in WCAG 3.
5. Discuss/survey if exemptions for inaccessible 3rd party content and services would help or hurt accessibility for users in WCAG 3.
6. Reach consensus.
7. Add text to the WCAG 3 draft.

It seems we are starting out with wanting to do steps 5-7 with the goal of getting exemption text into the next draft. It seems premature to me.
Janina Sajka Agree To David: I'm intrigued that you number your points here beginning at number 3. May I note that points 3, 4, and 5 are not specified by WCAG 2.x? But we certainly intend similar kinds of specificity for WCAG 3.
I'm especially interested in your guideline by guideline suggestions based on your point #5. Are there enhancements to what's proposed in this draft for text alternatives your #5 could address?
I would also be interested in your solution to our specific example at https://www.loc.gov/resource/mss26526.002_0866_0888/?st=gallery. I'd note there are tens and tens of thousands such examples in national libraries, not just the U.S. Library of Congress. How do we scale a solution? And who do we tax to pay for it?
Cybele Sack Disagree for the following reason It is important to prevent organizations from using third party rules to avoid taking responsibility for innovating to improve accessibility. If we allow the exclusion of user-generated content, payment systems, sellers, external media, AI vendors, and others, who is then responsible for the inaccessibility of this content? If the third party is a small organization, they may even be exempted from accessibility legislation, depending on the jurisdiction.

The team looking at this proposal would benefit from diversifying to increase participation from the Inclusive Design and UX community as well as to increase involvement from those with lived experience and those advocating for end-users who are most impacted by these harms, including those in various settings such as education and health care. How might this be done, and what new processes could be used to engage with them without assumptions about the problem (including definitions) and without narrowcasting solutions?

I agree with Laura Carlson and David MacDonald.
Peter Korn Agree Agree that in a number of cases the correct place for third party guidance will be within the guidelines themselves, because the specific guidance will be guideline-specific. For example, the guideline for captioning media might develop a different scoring system for machine captioned content when that technique is used for user generated videos, with a different quality standard to reach a particular score, vs. caption quality for videos created by the site author.


Beyond the specific question above, I would suggest two more edits to the body of the proposal:

First in the Editor's Note that opens Steps to Conform, I would edit the second sentence to read: "Once provided, fully conforming content will score as full conformant." since as noted in the first sentence, "Appropriate scoring is yet to be provided" - and those scoring examples are critical for this proposal to be fully considered and evaluated. I eagerly await the forthcoming revised overall WCAG 3 scoring approach, in which this can then be more clearly centered.

Second, under User Generated Content, item #3, I would change that item to read: "Utilize AI tools as they become available and feasible to use, to search user generated content and repair accessibility problems." (vs. "We encouraging using..."). As our AI/ML techniques improve, and become available for general use, they should absolutely become the minimum bar to reach our minimum conforming score, or our "3rd party conformance score" or whatever makes sense in the forthcoming revised scoring approach.



Further, to survey respondents who disagree with the Problem Statement, would it address your concerns (at least with the Problem Statement) if it read instead something like (changes in ALL CAPS):

"Web content sourced from third parties might not be fully accessible. IT IS VITAL THAT WEBSITE OWNERS DO EVERYTHING IN THEIR POWER TO FIX THIS (SEE ILLUSTRATIVE LIST BELOW). ONCE EVERY OTHER OPTIONS HAS BEEN EXHAUSTED, THE REMAINING options available to the web content publisher under the WCAG 2.x specification today are either..."

With the "ILLUSTRATIVE LIST BELOW" including everything that has been suggested by survey respondents prior to my own response? (e.g. "Pressure the 3rd party to remediate their non conforming content by auditing their content and providing a list of fixes to be remediated and allowing the authoring company's accessibility consultant to interact directly with the third party.").

Finally, again to survey respondents prior to my response who don't agree with this proposal, do you believe it is actually achievable to obtain and attach quality audio descriptions tothe fire hose of videos uploaded to social media and to sites like YouTube? Do you believe it is actually achievable to ensure that every posting to every blog, every social media site, every product review site, every for sale site, makes no exclusive reference to sensory characteristics? Is in clear language? If you believe this may be possible someday, somehow, with automated tools in the future - how far off do you think that future is? And again if so, what guidance (if any) should WCAG provide to websites on what they can do now, before that future arrives?
Sarah Horton Agree with the following changes I am interested to see how 3rd party guidance might be incorporated into guidelines.

The examples in the proposal and shared by the proposal authors focus on 3rd party content. The work of incorporating 3rd party guidance into guidelines might help illustrate more complex scenarios, especially those related to 3rd party services, and show the barriers that would result from adopting this approach and the impact on users.
Rachael Bradley Montgomery
Bruce Bailey Agree
Ben Tillyer Agree
Jeanne F Spellman Agree
Michael Gower Disagree for the following reason At the least, I'd split user-generated from services. I still have concerns with the 'exemption'

More details on responses

  • John Foliot: last responded on 9, July 2021 at 13:20 (UTC)
  • David MacDonald: last responded on 9, July 2021 at 14:39 (UTC)
  • Laura Carlson: last responded on 12, July 2021 at 17:20 (UTC)
  • Janina Sajka: last responded on 12, July 2021 at 22:05 (UTC)
  • Cybele Sack: last responded on 13, July 2021 at 04:08 (UTC)
  • Peter Korn: last responded on 13, July 2021 at 06:25 (UTC)
  • Sarah Horton: last responded on 13, July 2021 at 11:38 (UTC)
  • Rachael Bradley Montgomery: last responded on 13, July 2021 at 12:41 (UTC)
  • Bruce Bailey: last responded on 13, July 2021 at 13:49 (UTC)
  • Ben Tillyer: last responded on 13, July 2021 at 14:07 (UTC)
  • Jeanne F Spellman: last responded on 13, July 2021 at 14:56 (UTC)
  • Michael Gower: last responded on 13, July 2021 at 15:38 (UTC)

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