Proposal on Third Party Content

Proposal on Third Party Content Conformance Draft as of 8 July 2021

What is Third Party Content?

For the purposes of this proposal third party content is content that is part of a site or product that wasn't created by the site author or owner, and which may be substantially or completely outside the control of the owner or author of the site or product.

First party content is content controlled by the author or owner of the site or product. Employees, contractors, or agencies hired for site development are all examples of creators of first party content. They are not a part of this proposal.

We expect WCAG 3 outcomes to specifically address improving accessibility of third party content so the content can be appropriately accounted for in testing and in conformance claims. For example, we may not be able to expect that individuals uploading photos to social media will always provide good quality alternative text, but we should be able to expect the social media platform they are using to prompt their users for alternative text and provide guidance on creating appropriate alternative text. We also want to allow flexibility for continued accessibility tool development to identify and repair missing alternative text. Not all WCAG3 outcomes can apply directly to third party content so there is also a generic set of steps to conform where there are no specific outcomes.

Note: This proposal is intended as an eventual sub-heading in the Conformance section of WCAG3 and inclusion into specific guidelines for publication potentially as soon as the August working draft.

Not an exemption for third party content

This proposal is intended to improve the accessibility of third party content. Under WCAG 2.x, site owners are permitted to declare inaccessible third party content as partial conformance which is then outside of their conformance statement. 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. This proposal outlines how they can do more to make third party content more accessible, noting that it may not be possible to make third party content 100% accessible.

We intend to be comprehensive of third party content and include our expectations for improving accessibility when web content publishers turn to third parties for services (like payment processing), for media (like Hollywood movies), and for content that is invited from users (like blog comment postings and uploaded social media photos and videos).

Problem Statement

Web content sourced from third parties might not be fully accessible. In important cases it also might not be possible to fully remediate all of the accessibility failings in that third party content.

The only Conformance options available to the web content publisher under the WCAG 2.x specification today are either:

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

Note: Content proposed for the WCAG 3 Working Draft begins here but does NOT include items marked as Note:.

Conformance of Third Party Content

Web content publishers may include content from third party providers for specific services or content in their digital products. Examples include:

Providing subscribers on demand access to digital media such as music, movies, and ebooks.
Providing secure payment processing.
Providing shipping services and shipment tracking services for hard goods.
Providing authenticated subscriber access based on widely used third party services

Such content may be an aggregation of licensed/copyrighted content along with public domain content, along with user-provided content, all delivered through a common interface.

Steps to Conform for third party content is defined below for two categories of third party content, Author Arranged Third Party content, and User Generated Third Party content,.

Note: precise scoring of these is pending an update to the WCAG 3 Scoring proposal.

Definitions

Author Arranged

Author Arranged third party content is content that is part of a site or product that wasn't created by the site author or owner, and which may be substantially or completely outside the control of the owner or author of the site or product. Author Arranged Third Party Content is further subdivided into two subcategories, services and media, in order to accommodate the somewhat different Steps to Conform for each.

Examples of Author Arranged Third Party Services might include:

Payment processing.
Shipment tracking
Login authentication.

NOTE: Content publishers sometimes provide such services themselves, making them First Party services; or they may arrange for these services from a Third Party. In some cases content publishers do both creating an environment of both First and Third Party services for the same function giving users options. Which WCAG 3 guidance applies is determined by whether the content being evaluated is First or Third Party content.

Examples of Author Arranged Third Party Media might include:

Music, movies, or ebooks, or
Digitized image archives of content predating the web. Examples of such legacy archives include portions of major national libraries such as the U.S. Library of Congress, the U.K. British Museum, and The Bibliothèque nationale de France Catalogue Général. A specific example is this Image of a handwritten 19th Century document at the U.S. Library of Congress.

NOTE: Any individual item of Author Arranged Media content may be either First Party or Third Party. The difference is not in the media but in the legal authority to publish, for example copyright licensing. Authority to publish is governed by law, and laws differ among nations.

User Generated

User Generated third party content is created by site visitors using the authoring environment provided by the owner or author, or imported from content otherwise contributed to the author (for example, sent via email).

Examples of User Generated Third Party content might include:

blog postings,
uploaded photographs, or
uploaded videos.

NOTE: User generated content is provided for publication by visitors where the content platform specifically welcomes and encourages it. It does not include any content provided by employees, contractors, or authorized volunteers. Such content is First Party content. It also does not include tools used to create content such as component libraries or Content Management Systems (CMS).

NOTE: we plan to write a different proposal for external tools used to facilitate website and other web-based digital product creation.

NOTE: Two use cases are provided below to help us think through the validity of the approach proposed here.

Specific guideline recommendations

An important part of WCAG Conformance is the specific guidance that is associated with individual WCAG3 guidelines and outcomes. Not all WCAG3 guidelines have unique outcomes and testing for third party content. Where no specific third party content guidance is provided, the guideline applies to third party and first party content alike.

Note: This gives us the flexibility to provide specific third party guidance where appropriate without forcing it to be provided in each guideline whether or not it's actually needed.

The specific Guidelines provided below are taken from the WCAG 3 First Public Working Draft (FPWD). Since the Outcomes and Scoring models for WCAG3 are currently being revised, these are the adjustments we recommend to specific guidelines for now.

Text alternatives

Examples of user generated third party content needing text alternatives are images, photos, and graphics in:

social media where the owner has limited control over the input of users
user reviews such as "unboxing photos" or "here is the meal I ordered"
"For Sale" listings with a photo of a product

Recommendations for making third party content more accessible:

follow ATAG2 guidance in B.2.3: Assist authors with managing alternative content for non-text content.

Note: Additional examples and recommendations may follow.

Steps to Conform

Editor's Note: Appropriate scoring is yet to be provided. Fully conforming content will clearly score as fully conformant. It remains to be determined how to score third party content that has accessibility issues; and to define what minimum threshold scores might be acceptable; and what critical errors might prevent a conformance assertion. We expect WCAG 3 to provide this guidance within individual guidelines and outcomes and to support testing for conformance. The working group is looking at alternative requirements to apply to third-party content, and is looking for feedback on what would serve as reasonable requirements on how to host third-party content with known accessibility issues.

In addition to the requirements on third party content -- which need further development in the subgroups working on specific guidelines, outcomes, methods and testing -- this proposal attempts to develop the Conformance Section portion of WCAG3 with general conduct for the web content publisher, who is asked to:

Meet the specific guideline outcomes and methods for third party content;
Clearly indicate to users where the third party content is; and
Encourage the providers of that third party content to make it fully accessible; and
Do so in the context of making a WCAG 3 conformance claim.

End of Editor's Note

Author Arranged Service Content

Where services are provided by a third party:

The web content publisher should identify the areas of third party content (i.e. payment processing, shipping management, authentication, etc.), and perform standard accessibility evaluation analysis for them. If there are no accessibility issues, the third party content is fully conforming.

If accessibility issues are identified, then all of the following should be clearly indicated alongside the third party content, or in an Accessibility Statement published on the site or product:

Identify the third party content provider(s).
Identify where the third party content can be found on the claimant's digital product (perhaps by id href).
Identify the accessibility issues present in that third party content (where known).

Further, the web content publisher should report the problems identified to the third party provider, e.g. via github issue or bug report, or by citing the needed & missing accessibility metadata (e.g. ALT tags, ARIA) to the content owner. Where appropriate, include relevant WCAG references.

Author Arranged Media Content

Where media content is provided by a third party:

The web content publisher should identify locations of third party content (i.e. video catalog URL) and perform standard accessibility evaluation analysis for each. If there are no accessibility issues, the third party content is fully conforming.

If accessibility issues are identified, then all of the following should be indicated alongside the third party content or in an Accessibility Statement published on the site or product:

Identify the third party content provider. For media this may be the entity which owns the copyrighted media, or it may be the owner's agent.
Identify where the third party content can be found on the claimant's digital product (perhaps by id href).
Identify the accessibility issues present in that third party content (where known).

Further, the web content publisher should report the problems identified to the third party provider, e.g. via github issue or bug report, or by citing the needed & missing accessibility metadata (e.g. captions or audio descriptions). Where appropriate, include relevant WCAG references.

User Generated Content

Note: See also [2] github issue #450

The web content publisher should identify all locations of User Generated Content (e.g., commentary on hosted content, product descriptions for consumer to consumer for sale listings), and perform standard accessibility evaluation analysis for each. If there are no accessibility issues, the User Generated content is fully conforming.

If accessibility issues are identified, or if the website author wants to proactively address potential accessibility issues that might arise from user generated content, then all of the following should be indicated alongside the third party content or in an Accessibility Statement published on the site or product:

Clearly identify where User Generated third party content can be found on the claimant's digital product (perhaps by id href).
Clearly identify the steps claimant takes to encourage accessibility in User Generated content, e.g., prompting the user for ALT text for their images before they are uploaded [replace with language from ATAG], disallowal of text attributes except as they are part of semantic markup such as strong, headings, etc., as enumerated in Guideline Outcomes.
We encourage using AI tools as they become available to search user generated content and repair accessibility problems.

Note: End of content proposed for the WCAG Working Draft

Use Cases

The following use cases are provided to help us think through the validity of the approach proposed for WCAG 3 in this document.

Use Case A: Travel Site Featuring Both Author Arranged and User Generated Content

There is a very popular and active website that connects frequent travelers with each other for discussing their travel, and contains pages that intermix professional reviews of destinations developed by the site itself, with professional reviews licensed from third party reviewers, all alongside contributions and comments from the traveler/members. Content from all three sources includes text, photos, videos, audioscapes, and even 3D models of destinations. Licensed content is owned and under copyright of the owner, with the site acting as a reseller of that content. Traveler/user content often includes first person travelogues, which may make reference to sensory information such as Down the street you can find the entrance to Benny's tavern, clearly identifiable by its distinctive red awning. Thanks to the popularity and enthusiasm of the site, over 1 million page updates take place each and every day.

Applying the proposal to this use case

The travel site provides a collection of pages on how to author accessible content. This includes links to vendors who will add captions or audio description to videos (for a fee), as well as how to write good ALT text, and how to create posts with clear language, which don't make reference to sensory characteristics. All of the travel site's employees and contracted reviewers are required to ensure that their content complies with these guidelines. Separately, the travel site makes this material available to all of the companies that they license content from, and their contracts with those companies require that everywhere that captions and audio descriptions have already been created for licensed videos, that they are provided alongside those videos. Further, they likewise point end users to their pages on authoring accessible content, but specifically to a slightly different version that takes users through the authoring environment provided by the website for user generated content, showing precisely where and how to add ALT text, and providing examples of how to author content that doesn't refer solely to sensory characteristics, and what plain language is, etc. Finally, the authoring tool for user generated content doesn't allow for non-semantic markup (e.g., it is impossible to simply change font face information separate from semantic markup like Strong or emphasis).

Use Case B: Small Site with Author Arranged Payment Processing

A local scouting group has a website that includes a section for buying scouting merchandise. It uses the third party PaymentFriend commercial payment service for processing payments (just as does our travel site in Use Case A above). Unfortunately, PaymentFriend's embedded web payment interface contains a few accessibility failures, and the scouting group hasn't found an alternative that both meets their needs and doesn't have any accessibility failures.

Applying the proposal to this use case

On the page where website visitors can buy merchandise, just above the embedded PaymentFriend payment processing flow, there is a clear statement that payment processing is handled by this third-party. Furthermore, the scouting site contains an accessibility statement, which mentions that payment servicing is handled by PaymentFriend, with a link to the location within the payment workflow where this third-party content is hosted. Finally, when the scouting website decided to adopt PaymentFriend for financial transaction processing, it did an analysis of accessibility and provided that company with a list of accessibility defects found. On a regular schedule, the scouting website updates the embedded payment processing functionality to the latest version, scanning the bug list to see whether any accessibility bugs have been fixed.

Relevant WG & TF Discussion Minutes

AGWG

Silver

Note: Further work on this omnibus Third Party Content proposal has been superceded by the User Generated Content focussed proposal per AGWG RESOLUTION of 13 July 2021.