Notes on Raw Data

From the email thread of May 2022

From Andy Somers

A potential "raw data" exception:

Something I mentioned in a related thread some months ago, relates to "original data" for example:

Camera original .mov, .avi or similar movie files are often important to be kept as-is and unaltered, for evidentiary purposes for example. Embedding things like caption data (into the file) typically results in the file being re-compressed, which results in data loss. As such, a reasonable exception to the captioning requirement relates to camera original files which reasonably need to be left in their unaltered form.

Caption files can be created as sidecars, of course-and naturally, a separate version of the video file can be created to make captions available, but consider a site such as WikiLeaks, where information that is socially/politically important is held for dissemination. It is better that a site be able to hold a mass of such data than to be prohibited from doing so due to a compliance issue. And when possible, evidentiary data is best held/provided in an unaltered form.

Naturally, a commercial news operation should not be able to use such an exception when it comes to their prepared newscasts, but even a commercial news operation should be able to provide raw/unaltered footage as a separately available file, and "raw" files can not reasonably be required to be altered.

As such, this points to needed exception language for raw, original, and archival materials.

From Bruce Bailey:

We had a similar issue/concern for "raw data" with the Revised 508 Standards. Jeanne, can you suggest a wiki or GitHub page where I might share/memorialize some of that experience?

The issue comes up in Technical Assistance in that if the business need is, for example, an mpeg file format - that does not include captioning. For federal agencies under 508, we point to the allowance for "fundamental alteration": https://www.access-board.gov/ict/#E202.6

As Andy notes, any prepared product would need captioning. Drawing the line for public facing raw data gets pretty tricky pretty fast. Is the agency really only posting B-roll stuff? If it worth sharing, why is not also worth providing some kind of timed-text file? During the 508 public comment period, there were conversations about exceptions for "drafts" and "works in progress" and the Access Board ultimately came to the conclusion that would have been too much of a loophole.

Still there are a couple of additional notable caveats related to the limits of file formats:

https://www.access-board.gov/ict/#504.1 Authoring Tools, General ...to the extent that information required for accessibility is supported by the destination format.

https://www.access-board.gov/ict/#504.2 Content Creation or Editing ...to file formats supported by the authoring tool.