Media Considerations

From Silver

Media Content Considerations

Draft as of 7 October 2021

Web content publishers may host various types of media content. Examples of hosted media include:

  • Video, including motion pictures
  • Music, including commercial recordings
  • Digitized images of art, letters, etc.
  • 3D immersive experiences, such as house tours

Each of these categories of media content may have methods for making them accessible. there may be methods for some classes of persons with disabilities, but not for others. Whether or not accessibility methods exist, WCAG requires web publishers to apply all available context appropriate methods at the time of digitization, and then again upon any major refresh of the content. However, there are still additional situations that require special conformance treatment. The remainder of this proposal considers the examples above for the purpose of illustrating conformance distinctions in specific situations.

Conformance Treatments

There are four situations, not necessarily mutually exclusive, which need to be treated differently for purposes of conformance. These are:

  • Legacy Media. This is media that predates broadly available mechanisms for making that media accessible, such as movies published prior to the pre-1970s, before broad availability of closed captions and descriptions of video.
  • Media with Limited Rights for web Publishers. This is media for which the publisher lacks the right to create an accessible version, such as adding captions or descriptions.
  • Media lacking access mechanisms. This is media for which we don't yet have broadly available methods to make the media accessible for the full range of persons with disabilities , such as 3D on-line building tours, 3D "street view" mapping interfaces.
  • Media with supported access mechanisms. This is media created after publication of WCAG 2, where the publisher owns or receives the media from a source where it is already accessible or has rights to make it accessible, such as captioned TV shows published online after the release of HTML 5.

Editor's note:

The only Conformance options available to the web content publisher under the WCAG 2.x specification today for legacy media, media with limited rights for web publishers, and media lacking access techniques are either:

  1. Remove the content; or
  2. Make a statement of partial conformance. Such a statement effectively ignores that media content by declaring it out of scope. By definition, this constitutes a statement of non-conformance for the site as a whole.

However, under the new WCAG 3 specification, the conformance options are to be expanded to include:

  1. Direct web publishers to make that content as accessible as possible
  2. Add requirements that more fully and directly inform users before they attempt to access that media content
  3. Prioritize identifying who should be contacted concerning any identified accessibility issues

End Editor's note

Media Conformance

Specific guideline recommendations

An important part of WCAG Conformance are the specific requirements that are associated with individual WCAG 3 guidelines and outcomes. As of this publication, none of these have yet been created. Some guidelines will be explicitly identified as media related guidelines. Other guidelines may include media related outcomes, and those will be so identified.

Common steps to Conform

In all cases--whether or not media content is author owned or provided under restricted legal authority, or is impractical to make fully accessible even when it's in the public domain, in order to conform, the publisher of the web site will at least:

  1. Inform the user what accessible features are (or are not) present in the provided media resource, preferably through standard metadata disclosure mechanisms.
  2. Identify who should be contacted concerning accessibility issues. For licensed media this may be the entity which owns the copyrighted media, or it may be the owner's agent.

Editor's Note:

We expect the metadata types, values, and disclosure mechanisms will vary with the media, and will be addressed within the guidelines, outcomes, and mechanisms addressing media. We seek comment on what programmatically exposable metadata types and values are needed to express a full range of possible accessibility-related features in media. We also seek comment on how best to expose which specific ones are available to users within any particular media publication.

Step #2 above enables the publisher to proxy for the copyright holder, or direct the user to the ultimate source of the problem, as best works for them, or for the specific content instance.

End Editor's Note

Objectives based on media treatment

Legacy Media

Legacy Media includes digitized images of contemporary or historic content such as archives of silent movies, or collections of handwritten letters. While it may be possible to provide an alternative accessible version of any individual item of legacy content, it may be prohibitively resource intensive to do so for large archives of such content. This distinction therefore considers the scale of the task of making such archives fully accessible.

In order for Legacy Media to conform, the publisher of the web site will at least:

  1. Implement all relevant guidelines for which there are WCAG methods at time of digitization.
  2. Repeat the above step when the archive is substantially refreshed.

Editor's note:

This approach proposes adopting a model common in the built environment where specific building codes apply as a building is constructed. Then, a newer version of the building code may be applied whenever major renovations are performed on that building. In other words when first digitized, the media archive should be made accessible to the extent there are broadly available mechanisms for doing so; when significantly refreshed, again apply the most currently available accessibility methods at that time.

End Editor's note

Media with Limited Rights for Publishers

A complicating factor for all media is the legal authority to provide accessible alternatives. Web publishers who make content available under some licensing arrangement may lack rights to existing accessible versions, and may also lack the authority to create accessible versions themselves. This complicating factor is itself further exacerbated by differing legal provisions in different nations.

Whether sourced from other entities or owned outright, media might not be fully accessible. It is also not uncommon for a media work to exist in multiple, but unidentical versions; so that the title from one vendor may provide certain accessibility features while the same title from another vendor will lack those same accessibility features. Much legacy media, and especially media that predates the web, may not support accessibility features. The content publisher may also simply lack the legal authority to make content more fully accessible, even when they may wish to do so.

In order for Media with Limited Rights for Publishers to conform, the publisher of the web site will at least:

  1. Provide the full range of accessibility versions and features for which authority has been granted.
  2. Update the media when the copyright holder updates the accessibility features of that media.

Editor's note:

Some entities may have rights exceeding those available to commercial entities, especially to make content accessible on demand in an educational or governmental setting. We seek comment on whether and how a third-party tester should be able to identify and validate when media has limited rights.

End Editor's note

Media Lacking Access Methods

WCAG may not have methods to make some types of media accessible to some groups of people with disabilities. Examples include street views in map applications, and 3D tours of buildings.

In order for Media Lacking Access methods to conform, the publisher of the web site will at least:

  1. Implement all relevant guidelines for which there are WCAG methods at time of digitization.
  2. Repeat the above step anytime the archive is substantially refreshed, applying any newly available methods as available.

Media with supported access Methods

WCAG conformance requires newly produced media which can be made accessible to be made accessible according to guidelines and outcomes described throughout the WCAG specification.

User Generated Media

Consult the conformance requirements for User Generated Content.

Editor's note:

We have not described how any of this will be scored, or what conformance level would result when a site does everything set forth for the different situations described. That work is pending work revising the WCAG 3 scoring mechanisms and conformance levels. We have not identified how a 3rd party test could validate some of the scenarios presented. For example, we have not identified how to tell when content was digitized, in order to ascertain if that took place prior to broad availability of mechanisms to make that content accessible. Similarly, we have not identified how to tell when the rights holder of a piece of media is refusing permission for the publisher to make it accessible.

End Editor's note