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Results of Questionnaire 3rd Party Content Definitions

The results of this questionnaire are available to anybody.

This questionnaire was open from 2021-06-24 to 2021-06-29.

20 answers have been received.

Jump to results for question:

Author Arranged Definition
User Generated Definition
Other Types of Third Party Content

1. Author Arranged Definition

Author Arranged third party content may be services or media, and may include copyrighted content where the authority to publish may be provided in law. This Author Arranged third party content is defined as content the claimant hosts or facilitates, but which the web content publisher has limited or no control of either the underlying markup or what the user sees and interacts with. Services or media for which the content publisher lacks the legal authority to adapt for accessibility, or where wholesale adaptation is impractical (such as 19th Century newspaper or judicial opinion archives) is considered Author Arranged Third Party Content.

Summary

Choice	All responders
Choice	Results
Agree	4
Agree with the following changes	8
Disagree for the following reason	8

Details

Responder	Author Arranged Definition	Comments
Inka Taagehøj	Disagree for the following reason	This definition is very hard to read, which is why I'm not sure if I understand enough to comment on if I agree with it. The definition should be made easier to read. For instance, this sentence: "This Author Arranged third party content is defined as content the claimant hosts or facilitates, but which the web content publisher has limited or no control of either the underlying markup or what the user sees and interacts with." is 39 words long. This sentence is 38 words long: "Services or media for which the content publisher lacks the legal authority to adapt for accessibility, or where wholesale adaptation is impractical (such as 19th Century newspaper or judicial opinion archives) is considered Author Arranged Third Party Content." Studies from the American Press Institute have shown that when the average sentence length is 14 words, readers understand more than 90% of what they are reading. At 43 words, comprehension drops to less than 10%.
John Foliot	Agree with the following changes	"...such as a 19th Century newspaper.." (Minor grammatical edit)
David MacDonald	Agree with the following changes	I think we are missing a question on this survey for Section 1. 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... === Regarding this specific question This definition seems broad. "...but which the web content publisher has limited or no control of either the underlying markup or what the user sees and interacts with..." The cases I've discussed above (#3-5) could fix a high percentage of this type of content on a corporate web site. We would loose that progress towards an accessibility web if it was written off as an exception. If this was in the WCAG 2, there are at least 20 projects of 3rd party content that I've helped fix would not have been fixed. Those fixes have propagated to 1000s of other sites for clients of those 3rd parties.
Peter Korn	Agree	While improved, the text of the definition could be made more concise and easy to digest. I'm not opposed to it going into the draft while we in parallel to further wordsmithing, as I think the benefits to ensuring this makes it out in the August heartbeat to get wider review are worth the risk of us running out of time for better wordsmithing before the publication date.
Kim Dirks	Agree with the following changes	This is great - I agree with going down this path but think we don't quite have the wording right. If time is too short to modify, I would agree to using the current definition, but this needs more work. We should also have a longer list of examples since this is a new concept. Possible edit (I broke it down to be understandable for myself, but it may not accurate reflect the original content) Author Arranged Third Party Content is defined as services or media content that is either • protected by intellectual property rights such as copyright or trademark and where the web author legally cannot make changes to the content or how it is presented, or • content where complete remediation would be much more difficult or much more expensive than is commercially reasonable (such as remediating all content from a 19th century newspaper's archives or judicial opinion archives) Note: Author Arranged Third Part Content may not be deemed accessible unless fully remediated. However it is excused from the accessibility claim, and must be accurately identified as third party content.
Suzanne Taylor	Disagree for the following reason	I have to disagree because it's not clear to me what is meant by “agree” in the question. Will this be taken to mean that you agree that the legal issues of copyright exceptions and undue burden can effectively be addressed within a scoring mechanism inside a global technical standard? Or, does “agree” just mean you that you think the definition will work for right now, for continuing this discussion. I think that the discussion is valuable, since it likely parallels the discussions that will take place when legislation is being considered.
Detlev Fischer	Agree with the following changes	I am not sure what "where the authority to publish may be provided in law" and "lacks legal authority" means here, I think this should be spelled out a lot more clearly. I think it would be useful to discuss relevant examples and use cases (not just boy scout group publishing woes). I am especially thinking of high impact, big player examples, say, a hypothetical large e-commerce provider buying (or buying a stake in) a hypothetical Hollywood studio and its back catalogue of movies. If said e-commerce provider and the studio remain separate legal entities, and it comes to the matter of selling access to possibly uncaptioned movies to a large audience, can the service provider point to a legal argument to justify selling inaccessible media content even if they would have the means (both financially and in terms of direct or arm-wrestling power) to ensure content is made accessible? "Limited or no control": My second concern relates to lack of clarity regarding obligations to improve accessibility where it is awkward, put possible. Say (to take a real world example) your CMS, or some 3rd party form you embed, does not identify input purpose on its login forms, making you fail 1.3.4. It is quite easy to add autocomplete attributes by running a script after page load. The same way you may give the play button of some embedded video player a meanngful name. Of course these are nasty hacks but they are feasible if you feel forced to accept inaccessible 3rd party content for whatever reason. Lumping together "limited or no control" makes it too coarse an attribute to decide what a provider should be expected to do, especially providers with very deep pockets.
Cybele Sack	Disagree for the following reason	I agree with those above who suggested that the framing of this questionnaire is missing a first question. As a result, this could be interpreted as a leading questionnaire. There are fundamental questions that need to be asked first: 1 - Who benefits from 3rd party exemptions and why do they want them? 1b - Who proposed 3rd party exemptions to WCAG 3.0? 2 - If those proposing/lobbying for 3rd party exemptions get this added to 3.0, how will their company's users be impacted? 2b - If these exemptions are added to 3.0, how could this also impact users of other organizations' sites and services? 2c - How could limitations to accessibility from 3rd party exemptions increase existing social barriers for people with disabilities (such as barriers to employment and education)? 3 - Are there alternative solutions that increase rather than decreasing accessibility and accountability? What are they? 3b - Are we giving enough room to develop those alternatives that increase rather than decreasing accessibility and accountability for users with disabilities and their communities? If we did provide more time and space for this work, who ought to lead and participate, to ensure those users needs are well-represented? 4 - How would baking 3rd party exemptions into WCAG 3.0's conformance model lead to incentivizing the use of 3rd parties and reduced transparency? We know some answers to these questions, don't we? My understanding is that the answer to 1a is Amazon and the answer to 1b is Peter Korn. Can these questions please be answered in the 3rd party proposal documentation, for greater transparency of process and development?
Sarah Horton	Disagree for the following reason	This definition addresses a specific use case, inaccessible third-party media content, that is clearly important to authors who would benefit from a third-party content exemption in WCAG 3 conformance. Since that use case appears to be the focus of this effort, it would be helpful to address that use case only, and remove others, in this definition and throughout the proposal. For example, in this definition, “services” is included but is not defined either explicitly or through examples, and should be removed. Recognizing in some way the challenges of third-party content and services is important for accessibility guidelines. The conformance options subgroup had been working through multiple use cases that illuminated the nuances of the issue and its impact on users and authors. Unfortunately, the work of that group shifted precipitously from doing design research together, as a group, to the leadership proposing solutions for the group to respond to. I raised my concerns at several meetings without effect. In the end, I stopped attending the meetings because I felt unable to be heard. The outcome of the group is an incomplete position statement (from question 1, which for some reason we have not been asked to respond to), confusing definitions, and steps to conform that do not address user needs. I disagree with moving forward with this proposal in its current form, and I have concerns about the ability of the conformance options subgroup to present a balanced proposal.
Andrew Kirkpatrick	Agree
Stefan Schnabel	Disagree for the following reason	Clarify in wording if this definition involves also external web apps
Rain Breaw Michaels	Disagree for the following reason	If I understand correctly, this definition is meant to only cover materials that are unique and that cannot be altered, like art, movies, or the archival newspaper example above. It is not meant to also cover third party services (for example, which system does a health care provider purchase and use for payment processing), where the content publisher is making a business decision to use one service over another, and while they cannot control what that other company does, they can make choices about whether to use their money to engage with that company or do something else to provide the feature. This wording "but which the web content publisher has limited or no control of either the underlying markup or what the user sees and interacts with" could be interpreted as including both types. I'm not sure if this wording helps or introduces more problems, but here is an attempt at alternative wording: "but which is unique, often historical, content that the web content publisher and original producer cannot control" I also have concerns with how complex the language is in this paragraph. It took a few reads and I'm not certain I'm really understand the nuance, which means that it might be interpreted in different ways. I'm hesitant to offer alternative language since I'm not sure I'd be capturing the full intent.
Gundula Niemann	Agree with the following changes	For clarity, I suggest to add more examples, positive ones as well as negative ones. What about, video content (not provided by the page author), images, applications, other software?
Laura Carlson	Disagree for the following reason	Disagree for the following reasons: I'm don't think legal issues of copyright and undue burden for publishing inaccessible content should be specified in a W3C standard. (Does the W3C have even that authority?) I feel that this is something better left to courts and legal systems. In any event: I agree with David MacDonald when he says we are missing a question on this survey for Section 1. 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 agree that is a coarse analysis of what really happens in a WCAG 2 environment. There are more options: * Choose accessible products or services to begin with. When an author says "that's a 3rd party tool/implementation and we can't control its accessibility" remember that they chose that 3rd party tool in the first place. Authors should CHOOSE products that are accessible and not shirk that responsibility. For instance it can be incorporated into Request for Proposal process language. There are users who will not be able to access some of the content if products or services are not accessible. * Pressure the 3rd party to remediate their non conforming content and and work with them to make their product or service accessible. * Improve it after the fact. For example some media for which the content publisher lacks the legal authority to adapt for accessibility, can indeed be made accessible. When accessibility and copyright collide, innovative technology solutions can help. For example, a YouTube embed option allows for providing accurate captioning and audio descriptions of third-party video. https://www.3playmedia.com/services/features/plugins/captions-plugin/ If third-party videos lack needed captions and audio descriptions are allowed to be considered conforming, I fear people will forgo the embed option and publish inaccessible content on their sites. As Sarah Horton said in her June 20, 2021 email: "I am concerned about an approach to conformance for third-party content that allows WCAG conformance for inaccessible/not fully accessible content and services. This is counter to the user-first aims of WCAG 3. Including requirements for alternatives to removing barriers, such as a phone number for ordering merchandise in the case of the scouts website, is an attempt to align conformance and meeting user needs." https://lists.w3.org/Archives/Public/public-silver/2021Jun/0108.html
Janina Sajka	Agree	Thanks to everyone who has provided specific suggestions. It's clear we'll continue to wordsmith. Among other things it seems we need to more clearly state the importance of searching for an accessible option--even though this is implicit in the Steps to Conform section.
Alastair Campbell	Agree with the following changes	Just on structuring, it would help to have a concise definition first, then extra scoping/examples. E.g. ----------------- Author Arranged Third Party Content is content that the author hosts or facilitates from a third party, but has limited or no control of either the underlying markup or what the user sees and interacts with. Examples include services or media for which the content publisher lacks the legal authority to adapt for accessibility, or where wholesale adaptation is impractical (such as 19th Century newspaper or judicial opinion archives). --------------- Regarding the other options people mentioned (e.g. pressuring the 3rd party to re-mediate), those are good things that we should account for somewhere, but it doesn't get around the core problem of how you do a conformance statement that includes something you are not responsible for (but may have to include). I think we can progress with a definition, but to use it we also need to ensure that the responsibility lands somewhere (e.g. procurement). Someone asked "Who benefits from 3rd party exemptions and why do they want them?" Many of our clients would, for example: - A public sector client had to choose a GIS product (maps) and there were no accessible ones available. That product has to power the maps they provide to the public. They have made alternative accommodations, but cannot claim conformance for any area that includes their core service. - A public sector client that has to publish legal evidence, often PDFs of scanned in images/text that they are not allowed to edit. - A private sector client that is in a multi-year contract with a payment provide that doesn't provide an accessible interface. Thankfully our region is not as litigious as some, but it is still a concern.
Michael Gower	Disagree for the following reason	As stated in last call, I think there need to be distinctions between advertising and other forms of third party content (to the degree it is clear; infotainment really blurs the line). Advertising is a fairly different beast from most other 3rd party content, changing frequently, in most practical senses without any author ability to modify or control. However, it meets your current definition. A possible approach to author-arranged third party content is to require provision of an ACR for that content from the provider; in other words, an author is responsible for obtaining and providing, along with their own content, ACRs for all arranged content hosted on their site. They would not be responsible for the accuracy of those provided ACRs (which would be the responsibility of the owner). Theoretically such reporting could also be placed on the owners of advertising content as well. I'm deviating from what is proposed, which is for the author to test the 3rd Party material. It make sense that if the 3rd Party material affects the processes identified in WCAG 3 testing guidance, the author would be responsible for reporting and resolving that; however, where the 3rd party material is not in the idenfitied user processes that are assessed, it seems of a lesser author responsibility.
Ben Tillyer	Agree with the following changes	Slight grammar improvements, as mentioned by other respondents Also agree that wordsmithing is needed to improve readability
Jeanne F Spellman	Agree
Jennifer Chadwick	Agree with the following changes	Based on the Silver meeting on June 25th which contained a discussion about "legacy" content, I feel like this falls into that category. Some of the biggest challenges with third-party content come from functionality and not content. Making an old newspaper image accessible is not difficult; it can be remedied by the website owner and not the third-party. They can simply place that content in text below the image. However, if there is an <iframe> used that has been embedded with an interactive newspaper widget for reading the content, for example - this poses a far more significant technical barrier to certain people with disabilities. The functionality - the code - must be amended. Please include at least three examples of "services" so this is clearly defined. These would be more complex, functional services that contain content and trigger actions or offer interactions. Suggestions: 1) Chat widget 2) Interactive floorplan for a model home 3) Imbedded video from YouTube with media player. Please include at least three examples of "media". Is this content that is traditionally in text but is now stuck as an image because it's been scanned? I understand that this would be impractical to make the element itself accessible (i.e. the image), and a media alternative (text) could be made available. The key question I have is: Why, in our industry, would be allow any software or services third-party NOT to make their interactive component, element, service, etc. accessible? If it was standardized and an expectation - that vendor would change their product to be accessible. Else they lose business. Being functionally inaccessible should be a disadvantage for a software company. Sharing feedback on my colleague at Siteimprove who has low vision: "There should be NO exemptions for third-party content."

2. User Generated Definition

User Generated third party content, e.g. blogs, photos, videos, etc is created by site users using the authoring environment provided by the claimant, or ingested from content otherwise contributed to the author (e.g., sent via email). User Generated Third Party Content originates from outside the site or product owner's platform and is provided to the content publisher at will. This expressly excludes sites and other similar platform products where the user creating the content has a legal relationship with the organization that owns the site or product, e.g. employees and contractors. Website hosting and development services are also specifically excluded from this definition of user generated third party content.

Summary

Choice	All responders
Choice	Results
Agree	6
Agree with the following changes	9
Disagree for the following reason	4

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

Details

Responder	User Generated Definition	Comments
Inka Taagehøj	Agree with the following changes	Please improve the readability of this definition.
John Foliot	Agree with the following changes	"...e.g. blog posts, photos, videos,..." (Minor grammatical edit)
David MacDonald	Agree with the following changes	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.
Peter Korn	Agree	Portions of this text could also be further wordsmithed (specifically the penultimate sentence talking about content where the author has a "legal" relationship with the site or product owner; I would think "acting as an agent of" would be a better and more specific form of legal relationship). @David - the stipulation in item 1 is that it "might not be possible to fully remediate all of the accessibility failings in that 3rd party content". I agree there are a number of strategies to remediate quite a accessibility failings in third-party content, and you enumerate a number of them. I have no objection – and warmly welcome(!) – an enumeration of those, with strong encouragement to use them all. However, that shouldn't take away from the very real situations where full remediation isn't achievable. Here are two examples were full remediation isn't achievable.1) Movies lacking audio descriptions being presented on the website under license, where the license does not grant the website the right to add audio descriptions. At the end of the day, under WCAG 2, the website can either remove the content, or exclude it from a claim. Sure, they can put pressure on the copyright holder to fix the problem, but if the copyright holder doesn't agree, what other choice does the website have? 2) User generated content that is arriving too fast to possibly remediate. According to https://www.statista.com/statistics/259477/hours-of-video-uploaded-to-youtube-every-minute/ 500 hours of video are uploaded to YouTube every minute, as of May 2019. That's a ratio of 30,000:1. If you assume that it takes a talented audio describer eight hours to properly describe one hour of original content (a number which I think is generous, given the turnaround times we've seen for audio descriptions for Prime Video), and that this describer is working eight hours a day, five days a week, with only two weeks off for vacation (giving us the nice round number of 2,000 hours a year of audio description work), you would need to employ a staff of over 1.05 million audio describers full-time just to keep up with those uploads. Add in Facebook videos, TikTok, and the rest of social media, and that number grows substantially further still. Underway WCAG 2, this leaves social media with those same two options: disallow user generated content uploads, or exclude them from the claim. I mean, I guess you could require users to describe all of their videos… But that's really a recipe for the first choice: not allowing those uploads. And of course, if we have any description quality requirements in our guidelines, then that becomes a recipe for failing the quality bar as far too many polluters will put in an essentially empty description in order to make their upload pass, just as we see people doing with required ALT text.
Kim Dirks	Agree with the following changes	This is great - I agree with going down this path but think we don't quite have the wording right. If time is too short to modify, I would agree to using the current definition, but this needs more work. Possible edit (I broke it down to be understandable for myself, but it may not accurate reflect the original content) User Generated Third Party Content originates from outside the product owner’s platform and is any one of the following • Created by site users from the site’s authoring features (example, social media), or • Taken from a source where it is attributed to the author (example, news picked up from and attributed to another news source), or • Provided to the product owner voluntarily (example, via email, picked up from a public domain source) (probably need better examples) Expressly excluded from this definition are • sites and other similar platform products where the user creating the content has a legal relationship with the organization that owns the site or product (example, employees or contractors creating content). • Website hosting and development services
Suzanne Taylor	Disagree for the following reason	I do think not think that the exact relationship between the user and the product owner needs to be defined. WCAG 3.0 has already proposed scaled scoring and all challenges should be considered equally as a single scale is refined. Company A may struggle to provide alt-text for all images because many images are provided by users. Company B may struggle to provide alt-text for all images because their images are particularly complex. Neither struggle is more or less valid or more or less ethical. They are both barriers to making a barrier free experience. We should provide methods that explain how to address these challenges and move toward an increased score. Then, regardless of who is involved or what their legal relationships may be, teams can select the methods that are helpful to them. So, if Company C has images that are both particularly complex and user-provided, their needs are also addressed. Otherwise WCAG 3.0 would start to need different scoring for every type of challenge (third-party, legacy, micro-entity, low bandwidth, academic subject matter), and the complexity of calculating a score when you have 3 or 4 of the challenges in one product would be unmanageable. Imagine the amount of overhead this would add for project managers at a large company! Collecting all of this information up-front to request an accessibility review would be a major task. Better to use those resources moving the accessibility needle for the product forward. This is discussion is so valuable, though, because it highlights that there is advice/direction to be given to teams facing these challenges. All how-too advice should live in the same place, in the Methods. This is where W3C/WAI expertise is most relevant: Methods can address: If you have a large number of legacy scanned documents, and your target technology is html, here’s how to automate a solution. Or, if you are collecting images from users and targeting a compliance level that requires 80% of those images to have alt-text, here are some good UI techniques that have been proven effective. Etc.
Detlev Fischer	Agree
Cybele Sack	Disagree for the following reason	Here I could propose possible solutions to the alternative question 3 I proposed above: 3 - Are there alternatives that increase rather than decreasing accessibility and accountability? What are they? 3b - Are we giving enough room to develop those alternatives that increase rather than decreasing accessibility and accountability for users with disabilities and their communities? If we did provide more time and space for this work, who ought to lead and participate, to ensure those users needs are well-represented? But should I be proposing solutions here? Isn't it up to a dedicated group of those with a range of lived experience and experiential knowledge, technical, design, and communication skills as well as knowledge of the legal landscape internationally to be identifying this collectively? Has this happened? Where is the proposal, for example, on how larger sites with a great deal of crowd-sourced content can provide frameworks and UI templates for users to complete when submitting content, that would prompt them to add accessible content? There are certainly other examples of strategies that could be used. So why are we already limiting these definitions, before having these conversations about what might be possible and who might benefit?
Sarah Horton
Andrew Kirkpatrick	Agree with the following changes	Question whether a standard EULA for a site would constitute a legal relationship. I don't think that this is intended here so might need to be clarified.
Stefan Schnabel	Agree
Rain Breaw Michaels	Agree with the following changes	Suggest changing this wording: "This expressly excludes sites and other similar platform products where the user creating the content has a legal relationship with the organization that owns the site or product, e.g. employees and contractors." to also include relationships such as formal volunteers (example, I've done a lot of work with the League of Women Voters, and league webmasters are volunteers with no legal relationship, but still content editors). Possible change: "This expressly excludes sites and other similar platform products where the user creating the content has an official relationship with the organization that owns the site or product, e.g. employees, contractors, and volunteers designated as editors." I also suggest making it exceptionally clear that site building frameworks (Drupal, Wordpress, etc.) are also excluded by changing the last sentence slightly: "Website hosting and development services and frameworks are also specifically excluded from this definition of user generated third party content."
Gundula Niemann	Agree	Still I see the obligation to have this kind of content accessible, so the authoring environment should provide everything needed to enable the user to make their content accessible.
Laura Carlson	Disagree for the following reason	I agree with Suzanne Taylor and her rationale that 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.
Janina Sajka	Agree	We'll also continue wordsmithing here. I especially like the notion of defining "legacy content." That will help us clean up the awkward last sentence in the current definition.
Alastair Campbell	Agree with the following changes	Suggest a restructure to start with a definition: ---------------------- User Generated Third Party Content is created by site users using an authoring environment provided by the author, or ingested from content otherwise contributed to the site. User Generated Third Party Content can include blog articles, photos, videos, micro-blogging, or other sources. It excludes sites and platforms where the user creating the content has a legal relationship with the organization that owns the site, e.g. employees and contractors.
Michael Gower	Disagree for the following reason	I think there needs to be a clear distinction between user content generated on the author's site and third party sites providing user content. The language in the background document doesn't appear to consistently make this distinction, including in this definition. The first 2 sentences seem to contradict each other: sentence one, it's "created by site users"; or sentence two, it "originates from outside the site or product owner's platform". Those are two very different things, which should have different requirements. I'm surprised the phrase "authoring tool" occurs once in the document. It's incorporation starts to become apparent in the Use Cases, but it seems notably absent from the definitions we have. I'm not sure how all these things the author does for authoring tool practices are covered here. Either the use cases need to be contained, or there needs to be more discussion about how/why ATAG considerations are excluded.
Ben Tillyer	Agree with the following changes	Slight grammar improvements, as mentioned by other respondents Also agree that wordsmithing is needed to improve readability
Jeanne F Spellman	Agree
Jennifer Chadwick	Agree with the following changes	Again, it would be great to have clear-cut examples and a use case, in the way the EOWG tends to provide specific use cases or a user story of a need and that need being met through an experience, web page element, component, piece of content, etc. that are common for organizations. From the definition I'm still unsure as to an example in the real world. Would this be the use of Rise360, an authoring platform by Articulate? For example: I would input the course content into the structured pages that are provided by the system (Rise360). In this scenario, Articulate would be responsible for updating the interface/functionality of the course learning management system page - but I would be responsible for inserting accessible text (with headings, labels, images with a text alternative, etc.) In this example, I would NOT purchase Articulate's LMS platform if it were inaccessible as arguably 70-80% of the user experience is in their "shell" or system. I only manage the content. They would lose my business as a vendor if they made MY course materials inaccessible. Hopefully in this Proposal we a) acknowledge the split in responsibility and b) ask the Vendor for a roadmap to remediate their service/software/product. If they do not, they will lose businesses that have an Accessibility Standard that adheres to WCAG. They would fail.

3. Other Types of Third Party Content

Some types of third party content are excluded from this proposal. We would like to start making a list and developing use cases so we can address that type of content. Please list any examples we should be considering in the comments field.

The list so far from the ATAG 2.0 definition of authoring tools and previous meeting is:

web page authoring tools (e.g. WYSIWYG HTML editors)
software for directly editing source code
software for converting to web content technologies (e.g. "Save as HTML" features in office document applications)
integrated development environments (e.g. for web application development)
software that generates web content on the basis of templates, scripts, command-line input or "wizard"-type processes
software for rapidly updating portions of web pages (e.g. blogging, wikis, online forums)
software for generating/managing entire websites (e.g. content management systems, courseware tools, content aggregators)
email clients that send messages using web content technologies
multimedia authoring tools
software for creating mobile web applications
advertising

Summary

Choice	All responders
Choice	Results

Details

Responder	Other Types of Third Party Content	Comments
Inka Taagehøj
John Foliot
David MacDonald		I agree with these exclusions. However, I'm concerned we haven't had a thorough discussion of the general concept of exempting 3rd party content. I think it might offset the progress that is made on cognitive issues and result in lower accessibility for WCAG 3 than WCAG 2 which might slow down its adoption in the EU and other jurisdictions where they are looking to strengthen the requirements for a more accessible web, not loosen them.
Peter Korn		I agree there are a number of third-party categories that need special treatment, that we should expressly exclude for now. However, I'm not entirely sure this is the right list of things to exclude. Specifically, what is it about email clients that one might embed from a third-party party that makes it so different from a payment processing third-party embedding? Similarly an embedded source code editor. Is there a particular class of third-party content creation that we think falls under the same group such that we could gather them together in a further refinement of third-party content? On the other hand, advertising makes sense as a special case to me, as do content management systems.
Kim Dirks		1. There may be a hybrid category for content that is legally at issue. For example, if someone is being sued because they uploaded alleged defamatory images or videos, there may be limitations on what can be said in alt text during court proceedings without further defaming the harmed individual, biasing a jury, etc. This may be a very edge case. 2. Also wondering whether documents that are partially redacted or presented as images or inaccessible PDFs for security reasons should be on the list to contemplate. 3. Legacy materials (similar to author arranged third party content above) may need special status also. If something existed before the web, or before JAWS, is it appropriate to expect instant remediation of historical/legacy materials? We may need a category just for legacy content. If at the time the content was created it would have been impossible to make it digitally accessible because digital accessibility didn't yet exist, is it commercially reasonable to expect it to be remediated? Maybe this needs to be remediated "on reasonable demand" or something.
Suzanne Taylor		Some edges cases (not particularly exclusions) to consider and discuss: • Users who have their own users. For example, when you sign up for Discord as a completely ordinary random user, you are given “a server”. You can ignore that and just visit other people’s servers. Or you can set up a little world of your own, with users, user roles, media, text chats with different permissions, voice chat, video chat, moderators, bots, etc. Sometimes those who set this up are companies that have physical locations and this is their online presence. Other times those who set this up are individuals. • Recognized power users. Many platforms have people who receive a badge or title of some type that indicates that they have some authority on the platform. For example, Google Reviews have “local guides”. Since these users are unlikely to abandon the platform easily, I think that the method about how to elicit a high-percentage of images with good alt-text should suggest making alt-text mandatory for posting images for these users. This would have 2 effects: 1) they likely post a good percent of the images and those images would have alt-text and 2) they are often influencers and others may copy this especially if the UI also visually indicates when an image comes with alt-text and allows non-screen-reader access to the text (which any UI to encourage good alt-text writing should do).
Detlev Fischer
Cybele Sack		If no third party exemption existed, what could WCAG 3.0 deliver? Should Amazon be allowed to lobby for loopholes to international accessibility standards to reduce their own accountability, and undermine digital accessibility more broadly? Who benefits and who may be harmed?
Sarah Horton
Andrew Kirkpatrick
Stefan Schnabel
Rain Breaw Michaels
Gundula Niemann
Laura Carlson
Janina Sajka		Legacy Content would clearly include any collection of pre Gutenberg documents such as the Dead Sea Scrolls. We should consider whether it applies to anything pre web, though some pre web movie media does have captions and described video. While that may be too simplistic, I suspect it' comes fairly close.
Alastair Campbell		I don't think we should include CMS / editing software as "3rd party content", it is a different concept. Of the list above I think Advertising is a good example. Others I can think of: - An twitter feed embed is probably a mix of 'author arranged' and 'user generated', but in this context would be author arranged? - An aggregated feed of news articles (author arranged?) - A form-builder used by a local authority to collect user-data. - External video from a platform, e.g. YouTube (author arranged?)
Michael Gower		Okay, so here's mention of ATAG. I'm a little concerned with how you are forming a division between some of the things on this list, such as "software for rapidly updating portions of web pages (e.g. blogging, wikis, online forums)," and what you describe in third party content. Is the division between software (aka tool) and content always that clear cut?
Ben Tillyer
Jeanne F Spellman		Hosting (from the meeting suggested by JohnK
Jennifer Chadwick		Great. This is what is needed.

More details on responses

Inka Taagehøj: last responded on 25, June 2021 at 07:32 (UTC)
John Foliot: last responded on 25, June 2021 at 14:18 (UTC)
David MacDonald: last responded on 25, June 2021 at 17:13 (UTC)
Peter Korn: last responded on 25, June 2021 at 21:13 (UTC)
Kim Dirks: last responded on 25, June 2021 at 22:48 (UTC)
Suzanne Taylor: last responded on 26, June 2021 at 20:22 (UTC)
Detlev Fischer: last responded on 28, June 2021 at 08:44 (UTC)
Cybele Sack: last responded on 28, June 2021 at 22:36 (UTC)
Sarah Horton: last responded on 29, June 2021 at 11:16 (UTC)
Andrew Kirkpatrick: last responded on 29, June 2021 at 12:56 (UTC)
Stefan Schnabel: last responded on 29, June 2021 at 13:17 (UTC)
Rain Breaw Michaels: last responded on 29, June 2021 at 13:26 (UTC)
Gundula Niemann: last responded on 29, June 2021 at 13:37 (UTC)
Laura Carlson: last responded on 29, June 2021 at 14:09 (UTC)
Janina Sajka: last responded on 29, June 2021 at 14:31 (UTC)
Alastair Campbell: last responded on 29, June 2021 at 14:33 (UTC)
Michael Gower: last responded on 29, June 2021 at 14:35 (UTC)
Ben Tillyer: last responded on 29, June 2021 at 14:48 (UTC)
Jeanne F Spellman: last responded on 29, June 2021 at 15:53 (UTC)
Jennifer Chadwick: last responded on 29, June 2021 at 19:01 (UTC)

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Results of Questionnaire 3rd Party Content Definitions

1. Author Arranged Definition

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