May Report to the Silver TF

Report to the Silver Task Force

May Report to the Silver TF Draft! --- Draft! --- Draft!

Report of the Conformance Options Subgroup

3 June 2021

Uncovered for WCAG 3

As set forth in our sub-team's timeline of work, we are delivering additional proposals for use cases not addressed by WCAG 3, for Silver to consider. This report covers [X] Principles and [Y] use cases we have developed which have yet to be addressed by WCAG 3.

Third Party Content (Continued)

Note the Proposal on Third Party Content slated for Silver discussion on Friday 11 June and AGWG discussion on Tuesday 21 June.

NOTE: See also [2] github issue #450

Principle on 3rd party content

WCAG 3 should be designed with 3rd party content in mind; there shouldn’t be a notion of “partially meeting the solution” that only looks at 1st party content. The language of an assessment of the solution might nonetheless call out any 3rd party distinctions.

Categories of 3rd party content (Updated)

Contrary to our April Report, we now believe third party content breaks down into only two major categories for purposes of conformance:

• Author Arranged (which includes copyrighted content where the authority to publish may be provided in law). Author Arranged is defined as content the claimant hosts or facilitates but controls neither the underlying markup nor what the user sees and interacts with.
• User Generated third party content, e.g. blogs, photos, etc. User Generated Third Party Content is created by site users using the authoring environment provided by the claimant. User Generated Third Party Content is defined as any user facing interfaces deployed to facilitate end user content publishing, but which is fully controlled by the claimant who is free to edit, modify, or even replace it at any time for any reason (subject only to it's own published Terms of Service).

Author Arranged Content

Use Case A: Learning Management System

A community college has taken deliberate steps to use [https://www.w3.org/WAI/GL/WCAG3/2020/how-tos/clear-words/ clear words] in their public-facing website. However, they use a third-party learning management system (LMS) whose instructions, terms of use, and privacy policy are at times technical and involved. The LMS is used by instructors, students, and sometimes parents. No safeguards are in place to ensure that instructors use clear words in the content they create.

Conformance Approach

The following is a suggested approach for discussion:

• Where content or services are provided by a third party under contract, clearly identify each category location (i.e. payment processing, shipping, management, authentication, etc). Perform standard scoring analysis for each. If no accessibility issues, score is a perfect 4 and conformance claim statements stop at this point for that item.

1. If issues are identified, assign 1 point for identifying the third party content provider, and where it can be found on the claimant's site (perhaps by id href).

• Attest that no accessible service option was found and describe claimant's requirements andhow you searched for an accessible alternative. Scores 1 additional point.

1. Identify the accessibility issues present in that third party content. Scores 1 additional point.
2. Report the problems identified to the third party provider, e.g. via github issue. Scores 1 additional point.

Use Case B: Technical Journal with User Comments

An on-line journal publisher of highly technical, subject-specific material allows user comments on posted articles. While authors of journal articles are required to include clear language summaries (in keeping with WCAG 3s Clear Words guideline (which are verified by editors), website visitors are not required to similarly make clear language summaries of the comments they submit on articles.

Suggestion: Review and repurpose relevant portions of ATAG, especially ATAG Principle B for possible approach that would include providing accessibility support in forms used to capture content from contributors.

NOTE: Factors to consider in crafting a conformance scheme for User Generated Third Party Content:

• Locations where user content is invited should be specifically identified, perhaps using id hrefs.
• Reliance on, and conformance with ATAG sections of WCAG 3 should be attested.
• Is claimant using its own forms? Or a third party CMS or library. If third party, which? Include any relevant accessibility claim from the third party.
• Users should be gently prompted to provide any missing accessibility data, e.g. alt text.
• Claimant should be held to looser scoring requirements because end users are providing the content.

Poorly Supported Content Structures

Use Case C: Accessibility in the Legislative Process

As a legislative bill becomes law there are things like strike-through, redaction, and other legislative markup conventionss that are updated sometimes daily onto public facing websites to enable citizen participation in government. The current posted format is often PDF. as future web technologies address this use case, citizens will still need to be aware of what proposed legislative language is current, what line it is on, etc. That is how conversations about a bill happen. Knowing the legislative markup components used in the bill are essential for facilitating true citizen participation.

NOTE: More discussion needed--may involve updated "Accessibility Supported" guidance for best results, i.e. do we even have effective methods with AT?

Instant Accessibility Is Infeasible

Our current concept of conformance is only defined for a snapshot in time. We have no functional concept of tracking conformance over time. However, it has become evident to us that some time may be needed in order to make newly posted content accessible.

Use Case D: Posting Content Recieved via Postal Mail

Some citizens continue to send public comment to governmental agencies through

   > physical mail. Sometimes these even arrive as multiple pages of hand-written content. There are times where all public comments must be
   > posted. It is not that they should not be made accessible, however, the

time frame for making them accessible, especially during times where an extreme amount may come in, say during the beginning of a pandemic or

   > times of civil unrest, may be something that needs to be considered.

NOTE: See also Use Case G from our April Report.

NOTE: More discussion needed. Learn what legal constraints might be involved here?

Principle 3: Scoping for Primary Purpose

NOTE: There is no consensus yet on a wording for this principle. Essentially, it suggests that processes and views relevant to completing the primary purpose of a site should factor in conformance assessments. If some unrelated (or tangentially related) feature occurs in the process, it should not factor in assessment.

Principle 3 currently says: "Assessments of the solution should be modeled around what the site is designed for, and leverage expected user interactions with the site (e.g. what are the P0, P1 tasks, and evaluating the accessibility of those paths through the site for those tasks)."

Use Case E: Remote Access for Civic Events

The City of Whoville's website includes a calendar of upcoming events, so that citizens of Whoville can learn about what will be happening in the future, and decide whether they want to participate in any given event. As a few Whoville citizens travel, and some events take place virtually, as a convenience there is also a tool on the calendar site for converting event times into different timezones. Generalized timezone conversion isn't a primary use of the site, and an assessment of the accessibility of the Whoville calendar might assess the accessibility of the primary calendar information (what the events are, and when they take place in the timezone that Whoville is situated in) to be at a different, and higher, priority than the accessibility of the timezone conversion convenience feature (which in any case is commonly available elsewhere).

NOTE: As previously discussed, this use case suggests the need to provide guidance on how to define a process and its component views. Usually, we have said the footer may be irrelevant. However, we likely don't intend that auditors may pick and choose what markup structures in the views do, and do not pertain. Likely, we want some kind of definition that looks at defining the main content of each view, and likely defining it as contiguous content.

NOTE: This use case proposes the time conversion feature is a secondary feature, and not part of the site's primary purpose. However, where the time zone conversion feature is located with respect to the defined Whoville Use Case view may determine how it factors in conformance assessment. We can conceive it could easily fall outside the main purpose view, or inside it. We can even conceive it will only appear when the controlling code determines the user is in a different time zone than Whoville.

Suggestion: Develop guidance on defining acceptable view and process declarations, for WCAG 3, including scoring approaches for testing and conformance assessment.