Web
Accessibility
Working
Group
Revision
History
Maintained by: Eva Grabinski
Last updated by: Jonathan Woodcock, Karen Jack
Last updated on: March 13, 2013
Revision copies at: https://sharepoint.uwaterloo.ca/sites/web‐accessibility
Table
of
Contents
Revision History
...
1
Recommendations
...
3
Abbreviations ...
4
Members of Working Group ...
4
Objectives of Working Group
...
5
Accountability
...
5
Legislation ...
5
Accessibility for Ontarians with Disability Act (AODA) ... 5
Related Legislation ... 6
University’s Position ... 6
Scope
...
6
Websites that Fall Under the AODA Legislation ... 6
Outside of Scope ... 6
InternalorIntranetSites...6
SoftwareorWeb‐BasedApplications...6
Benefits Beyond Legal Compliance ...
7
Website Content and the AODA Legislation
...
7
Examples of Website Content ... 7
WrittenContent...7
WebGraphics...7
Documents...7
InteractiveContent...8
Archival Documents on Publicly Facing University Websites ... 8
Website Design and Development and the AODA Legislation ...
8
Internal Communications
...
9
Audiences ... 9
Channels ... 9
Processes
...
9
Description...9
Recommendation...10
Legal Notification of Non‐Compliance with Website Accessibility Legislation ... 10
Description...10
Recommendation...10
Procuring Web Services and Technologies for Publicly Facing University Websites ... 10
Description...10
Recommendation...10
Website Accessibility Training for Existing and New Website Maintainers ... 10
Description...10
Recommendation...11
Training and Support Resources...
11
Internal Resources ... 11
CentralLocationListingResources...11
TrainingCoursesThroughSkillsfortheElectronicWorkplace(SEW)...11
TechnologiesthatSupportWebAccessibility...12
TemplatesforAccessibleDocuments...12
ClientServiceSupport...13
External Resources ... 13
Peer Institutions ...
13
Staffing ...
14
Risk Assessment ...
14
Technical Risks ... 14
UniversityWebsitesInconsistentlyImplemented...14
LimitedToolsforGeneratingAccessibleWebAlternativesforPublications/Documents...14
Financial Risks ... 15
BudgetforRecruiting/HiringInternalExpertsinWebAccessibility...15
BudgetforProfessionalDevelopmentofInternalExpertsinWebAccessibility...15
BudgetforProcuringExternalExpertiseinWebAccessibility...16
Operational Risks ... 16
CommunicatingAODAWebsiteRequirementsGivenOrganizationalSizeandStructure...16
NotSpecifyingAODARequirementsinProcurementofWebServices...17
ProcuringWebServicesfromVendorsWithInadequateAODAKnowledge...17
ImplementingaWebsiteAccessibilityTrainingProgramforAllWebsiteMaintainers...18
Geographic Risks ... 18
ComplianceofInternationalWebsiteswithAODARequirements...18
Time Risks ... 19
MigrationScheduleforMovingPubliclyFacingUniversityWebsitesIntoWCMS...19
SchedulingofUpdatestoPubliclyFacingUniversityWebsitesNotInWCMS...19
TrainingandSupportStaffinPlacewithWebAccessibilityExpertiseBeforeDeadline...20
TrainingMaintainersofPubliclyFacingUniversityWebsitesBeforeDeadline...20
UnavailabilityofExternalExpertsonWebAccessibilityAroundDeadline...21
Human Resource Risks ... 21
LimitedExternalWebServicesProviderswithAODAWebAccessibilityExpertise...21
LackWebsiteAccessibilityTrainingandSupportPlanDeveloperandCoordinator...21
InadequateNumberofInternalWebAccessibilityExpertsforCampusWideSupport...22
Legal Risks ... 23
WebsiteContentinWCMSWebsitesCompliancewithAODARequirements...23
InternalProcessforCheckingAccessibilityofPubliclyFacingUniversityWebsites...23
NotificationorFinefromProvincialGovernmentforNon‐Compliance...23
IndependentLegalNotificationofNon‐ComplianceofWebsite(s)...24
AssumingLegalRiskforDeliverablesfromWebServicesProviders...24
Political Risks ... 25
ResistancetoChangesNeededtoMeetAODAWebsiteRequirements...25
LeadershipChampioningofNeedtoMeetAODAWebsiteRequirements...25
Recommendations
1.
Draft
a
University
Policy
to
address
compliance
with
legislated
web
accessibility
requirements: draft a University Policy that addresses
governance for compliance with the AODA legislated requirements for Ontario
University websites.
2.
Draft
and
implement
a
web
accessibility
training
and
support
plan
for
University
website
maintainers: draft and implement a training and support
plan for the University’s approximately 2000+ website maintainers (including
training plans and schedules, required courses, required templates/tools, and a
client‐service support model).
3.
Develop
and
hire
staff
with
expertise
in
web
accessibility
to
provide
University
‐
wide
support
for
meeting
legislated
web
accessibility
requirements: develop and hire staff with expertise in web accessibility to
provide training and support (including courses and hands‐on help) to the
University’s approximately 2000+ website maintainers.
4.
Procure
services
in
web
accessibility
where
required
to
support
meeting
legislated
web
accessibility
requirements: define areas where external
expertise in web accessibility is required (e.g., training, audits, testing,
conversion of documents to accessible formats) and procure required services.
5.
Draft
and
implement
a
University
‐
wide
communications
plan
on
legislated
web
‐
accessibility
requirements
and
related
support: draft and implement a
University‐wide communications plan to inform areas about web accessibility,
the
Accessibility for Ontarians with Disabilities Act
(AODA) legislated
requirements, and related information (e.g., available training and support).
6.
Specify
and
implement
procurement
requirements
for
external
providers
of
web
services
to
meet
legislated
web
accessibility
requirements: specify
and implement a procurement process requiring service providers that create or
maintain University websites (including website content such as text, graphics
and videos) to deliver deliverables that comply with AODA legislated website
requirements.
7.
Define
and
implement
a
website
accessibility
audit
process: define and
implement an audit process for checking the compliance of University websites
with AODA legislated website requirements, and provide client‐service support
to areas that need to update their websites for AODA compliance based on audit
findings.
8.
Draft
recommendations
for
archival
content
on
University
websites
within
the
context
of
legislated
web
accessibility
requirements: draft
recommendations for the publishing of archival content that predates January 1,
2012 and resides on publicly facing uWaterloo websites accounting for AODA
legislated website requirements.
9.
Contact
peer
institutions
to
learn
about
their
website
accessibility
plans
and
resources: contact peer institutions in Ontario to learn about their staffing
models, training courses, budgets and templates/tools to support their website
maintainers in complying with AODA legislated website requirements.
Abbreviations
Abbreviation
Description
AODA
Accessibility for Ontarians with Disabilities Act
CECA
Co‐operative Education and Career Action
COU
Council of Ontario Universities
CPA
Communications and Public Affairs
CTSC
Computing Technology and Services Committee
FACCUS
FACulty Computing User Support Group
FEDs
Federation of Students
IST
Information Systems and Technology
SEW
Skills for the Electronic Workplace program
SMC
Social Media Committee
STAC
Student Technologies Advisory Committee
TBD
To be determined
UCIST
University Committee on Information Systems and Technology
uWaterloo
University of Waterloo
WAC
Web Advisory Committee
W3C
The World Wide Web Consortium
WCAG 2.0
Web Content Accessibility Guidelines 2.0
WCMS
Web Content Management System
Members
of
Working
Group
Eva Grabinski (CPA, chair)
Karen Jack (Secretariat)
Liam Morland (IST, web technologies accessibility)
Rose Padacz (AccessAbility Services)
Laura Pfanner (IST, enterprise software applications and procurement)
Susan Shifflett (AccessAbility Services)
Andrea Sweet (CPA, web graphics accessibility)
Heather Wey (IST, web training and support specialist)
Jonathan Woodcock (CPA, web content accessibility)
Objectives
of
Working
Group
With AODA website accessibility legislation coming into effect, many website
maintainers at uWaterloo have questions about website‐accessibility requirements:
what the requirements are; how to meet the requirements; training and support
available; university governance on website accessibility. The goal of this working
group is to identify and address gaps in information, training and support required
for uWaterloo website maintainers pertaining to the AODA website accessibility
legislation.
Accountability
The working group is accountable to:
Web Advisory Committee (WAC)
Web Steering Committee
University administration leading AODA compliance at uWaterloo
Legislation
Accessibility for Ontarians with Disability Act (AODA)
The
Accessibility for Ontarians with Disabilities Act (2005)
(
AODA
) aims to make
Ontario barrier‐free, allowing everyone, regardless of disability, to be able to
participate fully in society. This includes the ability to browse and use websites.
Under the Act, the requirements relating to websites are in the
Integrated
Accessibility Standards
, Ontario Regulation 191/11, Section 14. The requirements
are defined in terms of the W3C’s
Web Content Accessibility Guidelines
(
WCAG
) 2.0.
WCAG 2.0 specifies a number of guidelines (such as having alt text for images),
which contribute to making an accessible website.
There are three levels to WCAG 2.0: Level A, Level AA, and Level AAA. Each level
builds upon the previous one. Level A provides a basic level of accessibility, but
using the website may still be cumbersome for users. Level AA provides a highly
accessible web experience. Level AAA provides maximum accessibility, but it is
widely acknowledged that compliance at this level may not be possible or feasible
for many websites.
By January 1, 2014, websites created or significantly refreshed after
January 1, 2012 must conform to WCAG 2.0 Level A.
By January 1, 2021, all websites must conform to WCAG 2.0 Level AA (with
two exceptions relating to captions and audio descriptions for video).
January 1, 2012 is a key date: anything created or significantly refreshed on or after
that date must be made to follow WCAG 2.0 Level A. Some existing sites will have to
be revised to meet this requirement.
Related Legislation
Canadian Charter of Rights and Freedoms:
http://laws‐lois.justice.gc.ca/eng/Const/page‐15.html
Ontario Human Rights Code:
http://www.ohrc.on.ca/en/ontario‐human‐rights‐code
University’s Position
uWaterloo Accessibility Plan:
https://uwaterloo.ca/disability‐services/policy/university‐waterloo‐accessibility‐
plan
Scope
Websites that Fall Under the AODA Legislation
The AODA legislation applies to all websites controlled, directly, or indirectly
through a contractual relationship, by uWaterloo that are accessible to the public.
Compliance with the legislation is required by all publicly facing uWaterloo‐
controlled websites. The legislation applies to the code, templates and content (text,
graphics, videos) of publicly facing uWaterloo websites. Examples of websites that
the AODA legislation applies to include: faculty, department, school, research,
support‐unit, and university‐college websites.
Outside of Scope
Internal or Intranet Sites
Websites that are internal (i.e., password‐protected internal sites or intranets) used
to privately and securely share University information fall outside of the scope of
this document. However, other law covers accommodation for employees and
students with disabilities who require access to content on internal sites or
intranets. Questions about providing accessible content for internal sites or
intranets can be directed to AccessAbility Services (https://uwaterloo.ca/disability‐
services/).
Software or Web‐Based Applications
Today, many software applications are web‐based or produce web content. Any
publicly facing web pages or web content generated by these applications can fall
under the AODA legislation. Consideration to AODA legislation must be given by
uWaterloo in the purchasing and development of software or web‐based
applications. Procurement and development of software or web‐based applications
fall outside of the scope of this document. Questions about AODA and software or
web‐based applications can be directed to Information Systems and Technology
(http://ist.uwaterloo.ca/).
Benefits
Beyond
Legal
Compliance
As an educational institution competing for student enrollment our websites are key
communications and marketing tools. To maximize our audience reach, we need
search engine optimization and websites that are accessible and usable by the
largest number of visitors possible keeping in mind not only those with disabilities
but those limited by their environment, bandwidth, or mobile device.
A website featuring consistent design with clear and logical navigation; simple
language with text that is easy to scan; understandable links; good color contrast;
text descriptions of essential visual elements; and transcripts or captions for audio,
video, and multimedia content improves the experience of all users. Visitors achieve
their goals efficiently and this positive experience with our websites translates into
a positive impression of the University.
Website
Content
and
the
AODA
Legislation
Examples of Website Content
This section provides examples of website content that falls under the AODA
legislation. If there is this kind of content on a uWaterloo website, then it needs to
be accessible (including but not limited to):
Written Content
Colour (text and background)
Headers
Links
Lists
Tables
Text
Web Graphics
Colours in graphics
Images of text
Informational graphics (e.g., pie charts)
Moving or flickering graphics or effects
Documents
Excel
PowerPoint
Word
Interactive Content
Audio files
Forms
Image maps
Plug‐ins (e.g., Flash)
Videos
Archival Documents on Publicly Facing University Websites
Legal opinion on the status of archival material on publicly facing uWaterloo
websites is required. Archival information would include old publications, old
meeting minutes, old academic calendars, old theses, and the like. For example,
several University websites have a large number of research papers going back
decades. Most of these research papers are PDFs that are scans of paper documents.
Electronic files of these research papers no longer exist and thus accessible PDFs
cannot be easily created.
Section 14 of the
Integrated Accessibility Standards
states that all websites and
content on those websites must be accessible by January 1, 2014. Making all of the
University’s scanned PDFs accessible for January 1, 2014 is not feasible. To comply
with legislative requirements, is the only option to remove these scanned PDFs from
public access? Doing so clearly makes the information much less available. Is it a
reasonable interpretation of the legislation that current information on websites
must be accessible and archival information from before January 1, 2012 can be left
as‐is? Archival information dated prior to January 1, 2012 could be indicated as
being made accessible on‐demand. Of course, on‐demand is not a substitute for
something being accessible from the start, but is preferable than the information
being completely unavailable.
Website
Design
and
Development
and
the
AODA
Legislation
Website design and development impact on the accessibility of websites. As such,
website designs (e.g., templates) and website development (e.g., code) are affected
by the AODA legislation. Website design and development must be implemented
such that AODA legislative requirements for websites are met and supported.
Attention must be paid to the following in website design and development
(including but not limited to): HTML, CSS, JavaScript, frames, plug‐ins.
Internal
Communications
This section addresses internal communications about the legislation as it pertains
to uWaterloo websites, and internal communications about training and support
available to help areas at the University comply with the legislation.
Audiences
Students employed by uWaterloo (coop, work study, part‐time, casual, research
assistants, teaching assistants, etc.)
Faculty members
Staff members
Anyone working on behalf of uWaterloo or as an agent of uWaterloo who creates
or maintains a uWaterloo website
Channels
Communications Council
Computing Technology and Services Committee (CTSC)
Cooperative Education and Career Action (CECA)
Daily Bulletin (uwaterloo.ca/bulletin)
Executive Council
Faculty Computing User Support Group (FACCUS)
Federation of Students (Feds)
Graduate Students Association
Faculty Association
IST Friday Morning Seminar
Leadership Forum
Social Media Committee (SMC)
Student Technology Advisory Committee (STAC)
Undergraduate Marketing Roundtable
University Committee on Information Systems and Technology (UCIST)
WatITis Conference
Web Advisory Committee (WAC)
Web Maintainers E‐Mailing List
Web Resources Website (uwaterloo.ca/web‐resources)
Processes
Internal Review of Websites for Compliance with Accessibility Legislation
Description
Random audits of publicly facing uWaterloo websites to test for compliance with
AODA legislative requirements are proposed to help areas – and the University in
general – comply with the legislation. Staff with expertise in website accessibility
will be required to conduct the audits. While website‐accessibility‐testing tools are
available to assist with audits, the tools alone are insufficient to assess compliance:
human review of website code, design and content are required. Importantly,
training and support need to be available to areas that are audited and are required
to make corrections to their websites to meet AODA legislated website
requirements.
Recommendation
Specify and implement an audit process for checking the compliance of University
websites with AODA legislated website requirements.
Legal Notification of Non‐Compliance with Website Accessibility Legislation
Description
Members of the University community may receive notice from outside parties
claiming that a website does not meet legislated accessibility requirements.
Recommendation
Anyone who receives notice that a website does not meet legislated accessibility
requirements should not respond to it and instead should redirect the notice to the
Secretariat (https://uwaterloo.ca/secretariat/contact‐us) for response.
Procuring Web Services and Technologies for Publicly Facing University
Websites
Description
External service providers that create or maintain University websites must deliver
code, design, and content (e.g., text and graphics) that comply with AODA website
accessibility legislated requirements. Incorporating legislated website accessibility
requirements into contracts for website development, website design, and website
content creation is required. This needs to be part of the procurement processes
managed by Procurement and Contact Services. As well, since many contracts for
website services are not managed by Procurement and Contract Services, areas
must be informed of this requirement in procuring contracted website creation and
maintenance services.
Recommendation
Writing accessibility requirements into RFPs and contracts for website design, web
development, and/or web content provision (e.g., text, graphics, videos).
Website Accessibility Training for Existing and New Website Maintainers
Description
Students
The University regularly hires
students
(coop, work study, part‐time, casual,
research assistants, teaching assistants, etc.) to work on web applications, web
technologies, and web content. Training of these students is required to help ensure
that the work done by these students complies with website accessibility legislated
requirements.
Staff
It is estimated that approximately 2000+ university
staff members
create and
maintain University websites, including website content and web technologies.
Training current and future staff in website accessibility is required to help ensure
that the University’s websites meet website accessibility legislated requirements.
Faculty
Many
faculty members
have publicly facing uWaterloo websites. Training of these
faculty members is required to help ensure that their websites comply with website
accessibility legislated requirements.
Recommendation
Draft and implement a website accessibility training and support plan for the
university’s 2000+ website maintainers.
Training
and
Support
Resources
Internal Resources
Central Location Listing Resources
Web Resources Website: https://uwaterloo.ca/web‐resources/
Training Courses Through Skills for the Electronic Workplace (SEW)
Training courses are an effective way to help University website maintainers learn
about AODA website accessibility requirements.
Given the very high number of University website maintainers (approximately
2000+), it is recommended that more than one staff member be available to deliver
a particular training course so that backups for training courses always exist.
The table immediately below lists courses identified that would be of benefit to
University website maintainers; additional courses may be identified over time.
Course
Offered Staffing
Resources
Accessible
Website
Design
and
Development
Yes
Internal (1)
Creating
Accessible
Audio
Files
No
TBD
Creating
Accessible
Numerical
Content
No
Internal (1)
Creating
Accessible
PDFs
from
PowerPoint
No
TBD
Creating
Accessible
PDFs
from
Word
Yes
Internal (1)
Creating
Accessible
Tables
for
Websites
No
Internal (1)
Creating
Accessible
Web
Graphics
Yes
Internal (1)
Producing
Accessible
Videos
No
TBD
Testing
Your
Website
for
Accessibility
No
TBD
Technologies that Support Web Accessibility
Central
uWaterloo
Web
Content
Management
System
(WCMS)
The WCMS is a huge boon for accessibility. It takes care of much of the work of
creating a website and ensuring that the website is accessible. The WCMS generates
the navigation menus and other webpage‐parts that appear on more than one
webpage, and it does this in a way that is accessible.
Content maintainers need only be concerned about making their own website
content accessible. The WCMS helps with this by providing prompts, tools and tips
within the editing interface to assist content maintainers, who also have training
available to them via the uWaterloo SEW program. For example, the WCMS requires
that content maintainers provide a text alternative for every image, thus benefiting
users with particular visual impairments.
The WCMS allows content maintainers to easily create web forms in an accessible
way. Content maintainers can define fields to be filled in or questions to be asked.
They can define the validation rules, such as mandatory fields or the format of a
number. The WCMS takes care of generating the HTML code, which displays the
form in the web browser in an accessible way.
The tools available in the WCMS allow for the creation of accessible equivalents for
existing PDF files that are not accessible. Content maintainers can create an HTML
version of a document, upload the PDF file to the WCMS, and link to the PDF file
from the HMTL page. Forms that currently exist on paper or as PDF files can be
recreated in the WCMS as web forms, replacing the inaccessible form with one that
is accessible.
Templates for Accessible Documents
The availability of accessible templates for various types of documents regularly
produced as part of University operations can assist areas with the creation of
accessible documents.
Importantly, any documents placed on uWaterloo publicly facing websites must
comply with AODA legislated requirements. Compliance with AODA legislated
requirements for documents can be achieved in two ways: the posting of an
accessible document on the website and/or the creation of an equivalent accessible
website or webpage for the document.
Templates identified thus far are listed in the table immediately below. It is
recommended that this list be reviewed to identify if any other templates are
needed to support areas across the University in meeting website accessibility
legislated requirements.
Template
Available Staffing
Resources
Letterhead
No
CPA
Meeting
Agendas
No
IST
Meeting
Minutes
No
IST
Reports
/
Plans
No
IST
Theses
No
IST
Client Service Support
Client‐service‐support staff with expertise in web accessibility and related AODA
legislated requirements need to be readily available (e.g., via phone and email) to
provide support to areas across the University in meeting AODA legislated website
requirements; importantly, the web accessibility support staff must be
knowledgeable in website development, design and content.
The number of client service staff members that will be required to support the
approximately 2000+ website maintainers at the University needs to be determined
as part of a training and support plan. It is also expected that support staff will have
expertise in different areas of website accessibility (e.g., website development vs.
website content). It is recommended that each support staff member has at least
two areas of expertise so that the University has more than one human resource
trained in a particular area of website accessibility.
External Resources
COU Web Accessibility Toolkit for Information and Communications Standard:
http://cou.on.ca/policy‐advocacy/accessibility/accessible‐toolkit‐
homepage/information‐‐‐communications‐standard
WAVE Web Accessibility Evaluation Tool:
http://wave.webaim.org/
Web Content Accessibility Guidelines (WCAG) 2.0 Quick Reference:
http://www.w3.org/WAI/WCAG20/quickref/
WebAim Color Contrast Checker:
http://webaim.org/resources/contrastchecker/
Peer
Institutions
It is recommended that peer institutions in Ontario be contacted to learn about:
Their staffing models to support AODA website accessibility compliance
(including internal and contracted resources).
Training courses they have available to help their website maintainers with
AODA website accessibility compliance.
Templates they have available to help their website maintainers with AODA
website accessibility compliance.
It is recommended that the following universities in Ontario be contacted: Laurier,
McMaster, Ottawa, Queen’s, Toronto, and Western (based on proximity and U15
membership).
Staffing
Based on information gathered thus far, the following roles are recommended to
support the University’s compliance with AODA website accessibility legislation:
Website Accessibility Training and Support Coordinator (1)
Website Accessibility Auditor (1+)
Website Accessibility Client Services Support Staff (number TBD; minimum 4)
Website Accessibility Training Course Developers (number TBD)
Website Accessibility Training Course Instructors (number TBD)
Contracted Website Accessibility Experts (number TBD)
Risk
Assessment
This section addresses risks associated with uWaterloo’s ability in meeting
legislated accessibility requirements for January 1, 2014.
Technical Risks
Technical risks focus on the technical capabilities of the organization: technical
implementations that do not or may not support the requirements; or technical
implementations that do not exist and would help in meeting the requirements.
University Websites Inconsistently Implemented
Description: University websites are inconsistently implemented. For example, some
University websites are: in the WCMS; created via Dreamweaver and apply variations of the University’s Common Look and Feel for uWaterloo websites; implemented in different WCMSs and/or have unique designs. This
inconsistent implementation poses a risk to meeting legislated AODA website requirements.
Impact: High (since only 200+ websites are in the central WCMS).
Probability: High (since it is infeasible to move all websites into the central WCMS before
the compliance deadline in AODA comes into effect).
Mitigation strategy: Continue moving University websites into the WCMS; implement a University‐
wide communications plan to communicate about legislated AODA website requirements; provide training and support on web accessibility and AODA website requirements for website maintainers University‐wide.
Contingency plan: Increase the number of staff on the WCMS team to increase the rate of
migration of University websites into the WCMS.
Limited Tools for Generating Accessible Web Alternatives for Publications/Documents
Description: Limited tools exist for University website maintainers to create or convert
websites. For example, tools are required to support accessible online versions of University annual reports, magazines and theses. The accessible online formats could be the publications/documents themselves, and/or could be equivalent accessible websites/webpages for the publications/documents. Tools for generating equivalent accessible websites/webpages would help University‐wide website maintainers meet AODA requirements.
Impact: Moderate (The WCMS provides some support for generating accessible
equivalents for publications/documents; however, functionality is still required for various types of publications/documents such as annual reports, magazines and theses).
Probability: High (Resources are limited on the WCMS team for allocating to such
tools/functionality).
Mitigation strategy: Develop tools in the WCMS for generating equivalent accessible
websites/webpages for publications/documents.
Contingency plan: Hire external contractors to develop tools for the WCMS for generating
equivalent accessible websites/webpages for publications/documents.
Financial Risks
Financial risks focus on budget allocations to address the legislated requirements;
financial risks address whether enough money has been allocated to properly
address the requirements. Short‐term costs and long‐term costs need to be
addressed in assessing financial risks.
Budget for Recruiting / Hiring Internal Experts in Web Accessibility
Description: A specific budget has not been specified and allocated for the
recruitment/hiring of internal full‐time experts in web accessibility.
Impact: Moderate (While the University would benefit from recruiting/hiring internal
experts in web accessibility, the University can also invest in the professional development of existing staff in web accessibility).
Probability: High (Given that more work needs to be done on defining the web
accessibility expertise required by the University, it is expected that recruitment/hiring of internal experts in web accessibility could be delayed beyond the date that the compliance deadline in AODA comes into effect).
Mitigation strategy: Define critical high‐priority human resources required to support accessible
University websites in compliance with AODA (e.g., expertise lacked among existing staff, number of client‐service staff to provide campus‐wide training and support), and submit a request for hiring such mission critical staff.
Contingency plan: Provide professional development in web accessibility to existing uWaterloo
staff; hire external experts in web accessibility on an as‐needed basis.
Budget for Professional Development of Internal Experts in Web Accessibility
Description: While staff members in certain support units (e.g., IST, CPA) are already
receiving professional development in web accessibility to provide campus‐ wide support, a specific budget for the training of particular staff as internal experts in web accessibility has not been specified and allocated. Areas where there are needs and gaps in expertise in web accessibility for providing campus‐wide support need to be defined, and particular staff members need professional development (e.g., training) to obtain the required expertise in order to provide campus‐wide support.
Impact: Moderate (Staff members in certain support units are already receiving
exist in certain web‐accessibility areas, such as video production).
Probability: Moderate (Some professional development is underway and is likely to
continue).
Mitigation strategy: Define gaps in expertise; identify staff members who can provide campus‐
wide training and support; obtain professional development for the staff in areas where there are gaps.
Contingency plan: Hire external experts to provide campus‐wide support in certain areas of web
accessibility.
Budget for Procuring External Expertise in Web Accessibility
Description: A specific budget allocated to procurement of external expertise (e.g.,
consultants, trainers, contractors) has not been allocated, and there are some gaps where external expertise could be beneficial in supporting uWaterloo to meet legislated AODA web accessibility requirements.
Impact: Moderate (Staff members in certain support units, such as IST and CPA, are
already receiving professional development to address some of the gaps in areas of web accessibility to help provide campus‐wide support; however gaps still do exist in certain web‐accessibility areas, such as video production. It is expected that the cost to procure external expertise will rise immediately before and after the January 1, 2014 deadline due to demand).
Probability: High (It is expected that budget may not be allocated in time to procure
external expertise in time to meet the AODA deadline of January 1, 2014 for web accessibility compliance).
Mitigation strategy: Define areas where there are notable gaps in web‐accessibility knowledge at
uWaterloo (that is, areas where there is notably little or no internal expertise), and focus on allocating budget to procuring external expertise for these gaps. Assess what knowledge already exists internally campus‐wide, and the level of expertise of each of the staff members in the respective areas of web accessibility; use this information to inform where procurement of external expertise should be focused.
Contingency plan: Professional development of existing uWaterloo staff in areas of web
accessibility where there are currently gaps. Note that obtaining training services may prove more difficult and/or expensive around the January 1, 2014 AODA deadline. The workload of current staff also needs to be
accounted for in assessing who should receive professional development and who can provide campus‐wide support in particular areas of web accessibility.
Operational Risks
Operational risks address how things are done in the organization and how this can
be an impediment to meeting the requirements. Operational feasibility includes
considerations such as procurement processes, external vendors, organizational
structure, etc.
Communicating AODA Website Requirements Given Organizational Size and Structure
Description: Areas regularly express that they are unaware of AODA website requirements
(e.g., when migrating to the WCMS). While communications about AODA website requirements have been delivered via various channels (e.g., Web Advisory Committee, UCIST, Communications Council), communications are not reaching all University website maintainers.
Impact: High (This poses a significant risk for hundreds of uWaterloo websites not
2014 deadline).
Probability: High
Mitigation strategy: Draft and implement a University‐wide communications plan to inform areas
campus‐wide about web accessibility, the AccessibilityforOntarianswith
DisabilitiesAct (AODA) legislated requirements, and related information (e.g., available training and support). Incorporate information about web
accessibility, the AccessibilityforOntarianswithDisabilitiesAct (AODA) legislated requirements, and related information (e.g., available training and support) into the initiation/onboarding of newly recruited staff and faculty.
Contingency plan: Increase training‐and‐support staff on the WCMS team to increase the rate of
migration of University websites into the WCMS; supplement this with training in web content accessibility for University website maintainers.
Not Specifying AODA Requirements in Procurement of Web Services
Description: Legislated AODA website accessibility requirements need to be part of the
procurement process of external web services (e.g., web development, web design, web content production) in support of University websites. Some web services involve the Procurement and Contract Services Office; as such, the Procurement and Contract Services Office can work to ensure that AODA requirements are part of the procurement process where required. However, many areas across the University procure external web services without going through the central Procurement and Contract Services Office, and without knowledge about the legislated AODA website accessibility requirements.
Impact: High (Areas across the University regularly procure web services, including
web development, web design and web content production. The risk of receiving deliverables that do not comply with AODA requirements where required is high, and the related risk of rework to meet AODA requirements is high).
Probability: High (Areas across the University regularly procure web services, including
web development, web design and web content production. The risk of areas procuring web services without specifying legislated AODA website
accessibility requirements is high).
Mitigation strategy: Work with the Procurement and Contract Services Office to ensure that any
RFPs/contracts for web services provision (e.g., web development, web design, web content production) include legislated AODA web accessibility requirements. As part of University‐wide communications about web accessibility and AODA, include information about the need to include legislated AODA web accessibility requirements in RFPs/contracts.
Contingency plan: Implement an internal auditing process to check compliance of University
websites with legislated AODA web accessibility requirements.
Procuring Web Services from Vendors With Inadequate AODA Knowledge
Description: In procuring web services (e.g., web development, web design, web content
production), some vendors may claim knowledge of AODA but may deliver deliverables to uWaterloo that fail to meet the legislated AODA web accessibility requirements.
Impact: High (The University could be subject to widespread sign‐offs or acceptance of
deliverables that do not meet, but are required to meet, legislated AODA web accessibility requirements based on current and dispersed procurement practices at the University).
Probability: High (The probability of occurrence is high due to dispersed procurement
communicating University‐wide the need to comply with legislated AODA web accessibility requirements).
Mitigation strategy: Establish pre‐approved vendor lists of suppliers that can provide web services
(e.g., web development, web design, web content production) in compliance with legislated AODA website requirements. Work with the Procurement and Contract Services Office to ensure that any RFPs/contracts for web services provision (e.g., web development, web design, web content production) include legislated AODA web accessibility requirements to transfer risk to web services providers. As part of University‐wide communications about web accessibility and AODA, include information about the need to include legislated AODA web accessibility requirements in RFPs/contracts.
Contingency plan: Implement an internal auditing process to check compliance of University
websites with legislated AODA web accessibility requirements.
Implementing a Website Accessibility Training Program for All Website Maintainers
Description: The large number of Website maintainers employed by the University and the
dispersed nature of the organization make the delivery of training to all University website maintainers difficult.
Impact: High (The delivery of AODA training University‐wide impacts a significant
number of website maintainers across the University, with the number of University website maintainers estimated at around 2000+).
Probability: High (The delivery of AODA web accessibility training to all University
website maintainers is difficult due to the large size and organizational structure of the University).
Mitigation strategy: Include information about the University’s requirement to meet AODA
requirements (including web accessibility) in new staff and faculty initiation/onboarding processes. Draft and implement a University‐wide communications plan to inform areas campus‐wide about web accessibility, the AccessibilityforOntarianswithDisabilitiesAct (AODA) legislated
requirements, and available training and support. Ensure adequate training‐ and‐support resources exist to provide training and support to all University website maintainers.
Contingency plan: Implement an internal auditing process to check compliance of University
websites with legislated AODA web accessibility requirements.
Geographic Risks
Geographic risks address risks associated with having resources (e.g., staff, technical
capabilities) geographically dispersed, making the ability to meet requirements
difficult or infeasible.
Compliance of International Websites with AODA Requirements
Description: Because uWaterloo is headquartered in Ontario, its international websites
must comply with AODA legislation (even if these websites are not hosted in Ontario by uWaterloo). The ability to train uWaterloo website maintainers internationally and to address internationally hosted uWaterloo websites poses a challenge.
Impact: Low (It is expected that only a limited number of uWaterloo websites hosted
internationally exist).
Probability: High (It is expected that all or most uWaterloo websites hosted internationally
do not comply with AODA requirements).
offered via the main uWaterloo campus headquartered in Ontario. Hosting of international websites in the University’s central WCMS where feasible.
Contingency plan: Auditing of uWaterloo websites hosted internationally. Migration of
international websites hosted outside of Ontario into the University’s central WCMS where feasible.
Time Risks
Time risks focus specifically on schedule risks for the University associated with
meeting the AODA requirements by January 1, 2014.
Migration Schedule for Moving Publicly Facing University Websites Into WCMS
Description: The University’s central WCMS ensures that the website development and
design of uWaterloo websites comply with legislated AODA web accessibility requirements (note that the WCMS cannot guarantee the accessibility of web content entered into the WCMS by University website maintainers). The migration of University websites into the WCMS increases the likelihood of compliance of University websites with legislated AODA web accessibility requirements. However, the current rate of migration of uWaterloo into the University’s central WCMS means that most University websites will not be in the WCMS before the AODA deadline date of January 1, 2014.
Impact: High (most university websites will not be migrated into the WCMS before the
AODA deadline date of January 1, 2014; only about 25% to 30% of the
University’s ~1200 websites will be migrated into the WCMS before the AODA deadline date of January 1, 2014).
Probability: High (only about 25% to 30% of University websites will be migrated into the
WCMS before the AODA deadline date of January 1, 2014).
Mitigation strategy: Temporarily increase staff on the WCMS team to increase the rate of
migration of University websites into the WCMS.
Contingency plan: Provide web accessibility training and support in compliance with AODA to
website maintainers across the University responsible for maintaining
websites outside of the University’s central WCMS. Training and support could be provided in several ways, including via internal University staff or external service providers.
Scheduling of Updates to Publicly Facing University Websites Not In WCMS
Description: A large number of University websites (60% to 75% of the University’s
~1200 websites) will not be hosted in the University’s central WCMS by the AODA deadline date of January 1, 2014. The University’s central WCMS ensures that the website development and design of uWaterloo websites comply with legislated AODA web accessibility requirements (note that the WCMS cannot guarantee the accessibility of web content entered into the WCMS by University website maintainers). Note, not all websites can be migrated into the University’s central WCMS due to specific features or functionality not available in the WCMS.
Impact: High (60% to 75% of the University’s ~1200 websites will not be hosted in
the University’s central WCMS by the AODA deadline date of January 1, 2014).
Probability: High (many areas across the University are still unaware of legislated AODA
web accessibility requirements).
Mitigation strategy: Draft and implement a University‐wide communications plan to inform areas
DisabilitiesAct(AODA) legislated requirements, and available training and support. Provide web accessibility training and support in compliance with AODA to website maintainers across the University responsible for
maintaining websites outside of the University’s central WCMS. Training and support could be provided in several ways, including via internal University staff or external service providers.
Contingency plan: Temporarily increase staff on the WCMS team to increase the rate of
migration of University websites into the WCMS.
Training and Support Staff in Place with Web Accessibility Expertise Before Deadline
Description: Having the required number of internal training‐and‐support staff in place
with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support to University website maintainers to meet the AODA deadline of January 1, 2014.
Impact: High (there are ~1200 University websites and ~2000+ University website
maintainers; there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support campus‐wide to University website maintainers)
Probability: High (there are currently not enough fully allocated internal human resources
with the required expertise across the areas of web accessibility covered in AODA in order to provide training and support campus‐wide to University website maintainers)
Mitigation strategy: Allocation and professional development of existing uWaterloo staff to
provide web‐accessibility training and support campus‐wide. Supplemented by the procurement of external experts in web accessibility to provide campus‐wide support to University website maintainers in meeting the AODA deadline of January 1, 2014.
Contingency plan: Procurement of external experts in web accessibility to provide campus‐wide
support to University website maintainers in meeting the AODA deadline of January 1, 2014. Note, it may be difficult or more expensive to procure
external expertise in web accessibility during the time before and shortly after the AODA deadline date of January 1, 2014.
Training Maintainers of Publicly Facing University Websites Before Deadline
Description: There are ~1200 University websites and ~2000+ University website
maintainers; there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide campus‐wide training to University website maintainers before the AODA deadline of January 1, 2014.
Impact: High (there are ~2000+ website maintainers who require training in
legislated AODA web accessibility requirements)
Probability: High (there are currently not enough fully allocated internal human resources
with the required expertise across the areas of web accessibility covered in AODA in order to provide campus‐wide training)
Mitigation strategy: Allocation and professional development of existing uWaterloo staff to
provide training campus‐wide. Supplemented by procurement of external experts in web accessibility to provide campus‐wide training to University website maintainers in meeting the AODA deadline of January 1, 2014.
Contingency plan: Procurement of external experts in web accessibility to provide campus‐wide
training to University website maintainers in meeting the AODA deadline of January 1, 2014. Note that it may be difficult or more expensive to procure
external expertise in web accessibility during the time before and shortly after the AODA deadline date of January 1, 2014.
Unavailability of External Experts on Web Accessibility Around Deadline
Description: It is expected that external web accessibility experts will be difficult to
procure just before and just after the AODA legislated deadline of January 1, 2014.
Impact: Moderate (uWaterloo has internal expertise across most areas of legislated
AODA web accessibility requirements).
Probability: Moderate (Depending on the area of web‐accessibility expertise and where
the experts are based, variability is expected in their availability).
Mitigation strategy: Identify gaps in web accessibility expertise required by uWaterloo to meet
AODA requirements, and proceed with procuring external web expertise in these gap areas.
Contingency plan: Invest in hiring and professional development of internal staff to obtain the
web accessibility expertise required to meet areas of web accessibility legislated under AODA.
Human Resource Risks
Resource risks address whether the organization has enough human resources, and
whether the resources are the right resources with the required skills and expertise.
Limited External Web Services Providers with AODA Web Accessibility Expertise
Description: It is expected that there are a limited number of external service providers
with AODA web accessibility expertise.
Impact: High (many areas across the University procure external web services, and
many of the web‐services providers do not have AODA web accessibility expertise with many being entirely unaware of AODA).
Probability: High (many web‐services providers do not have AODA web accessibility
expertise with many being entirely unaware of AODA; due to this, web service providers with AODA web accessibility expertise are expected to be in high demand).
Mitigation strategy: Research available web services providers with AODA web accessibility
expertise, and establish a pre‐approved vendor list of suppliers that can provide web services (e.g., web development, web design, web content production) in compliance with legislated AODA website requirements.
Contingency plan: Increase the number of staff on the WCMS team to increase the rate of
migration of University websites into the WCMS.
Lack Website Accessibility Training and Support Plan Developer and Coordinator
Description: A full‐time allocated human resource is required to develop a campus‐wide
web‐accessibility training‐and‐support plan for University website maintainers, and to coordinate the campus‐wide web accessibility training and support outlined in the plan. This human resource currently does not exist.
Impact: High (allocating a full‐time resource to plan and coordinate campus‐wide
training and support in web accessibility for University website maintainers will significantly improve the probability of University website maintainers receiving the required training and support).
Probability: Moderate (it is expected that approval will be granted to allocate or hire a full‐ time human resource to plan and coordinate campus‐wide training and support in web accessibility for University website maintainers).
Mitigation strategy: Hiring a full‐time human resource to develop a campus‐wide web‐accessibility
training‐and‐support plan for University website maintainers, and to coordinate the campus‐wide web accessibility training and support outlined in the plan.
Contingency plan: Reallocating an existing human resource to develop a campus‐wide web‐
accessibility training‐and‐support plan for University website maintainers, and to coordinate the campus‐wide web accessibility training and support outlined in the plan.
Inadequate Number of Internal Web Accessibility Experts for Campus Wide Support
Description: There is currently not enough staff with the required web accessibility
expertise available to provide campus‐wide client‐service support to
University website maintainers in meeting legislated AODA web accessibility requirements.
Impact: High (there are ~1200 University websites and ~2000+ University website
maintainers; there are currently not enough fully allocated internal human resources with the required expertise across the areas of web accessibility covered in AODA in order to provide support campus‐wide to University website maintainers).
Probability: High (it is currently realized that there are not enough staff with the required
web accessibility expertise available to provide campus‐wide client‐service support to University website maintainers in meeting legislated AODA web accessibility requirements).
Mitigation strategy: Hire full‐time staff with the required web accessibility expertise to provide
campus‐wide client‐service support to University website maintainers in meeting legislated AODA web accessibility requirements.
Contingency plan: Procure external experts in web accessibility to provide campus‐wide client‐
service support to University website maintainers in meeting legislated AODA web accessibility requirements.
Gaps in Web Accessibility Expertise in Particular Areas
Description: While the University has web accessibility experts across many areas covered
by AODA (e.g., text‐content on websites, website graphics, web development), there are still gaps in particular areas of web accessibility (e.g., videos, audio files).
Impact: Moderate (the University has web accessibility experts across many areas
covered by legislated AODA web accessibility requirements).
Probability: High (there exist gaps in some areas of web accessibility covered in the
legislated AODA web accessibility requirements).
Mitigation strategy: Identify gaps in web accessibility expertise. Hire staff with the required web
accessibility expertise and/or obtain professional development for staff in the required web accessibility expertise.
Contingency plan: Identify gaps in web accessibility expertise. Procure external expertise in
areas where there are gaps in internal web accessibility expertise in order to meet legislated AODA web accessibility requirements.
Legal Risks
Legal risks address limitations or risks in meeting legal requirements, as well as
legal action that the University could be exposed to in not meeting AODA website
accessibility legislated requirements.
Website Content in WCMS Websites Compliance with AODA Requirements
Description: The University’s central WCMS ensures that the website development and
design of uWaterloo websites comply with legislated AODA web accessibility requirements. However, the WCMS cannot guarantee the accessibility of web content (e.g., text, graphics, videos) entered into the WCMS by University website maintainers.
Impact: Moderate (website maintainers of websites in the WCMS are informed about
legislated AODA web accessibility requirements and about related web accessibility training courses available through the SEW program).
Probability: Moderate (while most content maintainers of websites in the WCMS work to
comply with AODA website requirements, some maintainers inadvertently or deliberately disregard web accessibility requirements or best practices).
Mitigation strategy: Provide campus‐wide training and support in web‐content accessibility to
maintainers of University websites.
Contingency plan: Implement an internal auditing process to check compliance of University
websites with legislated AODA web accessibility requirements. Note that the WCMS team provides web accessibility reports to website maintainers for sites in the WCMS.
Internal Process for Checking Accessibility of Publicly Facing University Websites
Description: Define and implement a random audit process for checking the compliance of
University websites with AODA legislated website requirements, and provide client‐service support to areas that need to update their websites for AODA compliance based on audit findings.
Impact: High (regularly scheduled random audits of the University’s ~1200 websites
can help support the compliance of University websites with legislated AODA web accessibility requirements).
Probability: High (it is expected that audits will regularly reveal updates that are required
to University websites for compliance with legislated AODA web accessibility requirements).
Mitigation strategy: Regularly scheduled random audits of publically facing websites with training
and support to update websites to comply with AODA.
Contingency plan: Removal of websites from the University’s web‐space that fail audit 6 weeks
after the audit fails if failure to comply with AODA continues.
Notification or Fine from Provincial Government for Non‐Compliance
Description: The University could receive a notification or fine from the Provincial
Government for non‐compliance with legislated AODA web accessibility requirements.
Impact: Low (expect that the Provincial Government will provide initial warnings to
the University with compliance criteria for meeting legislated AODA web accessibility requirements before fines are imposed on the University)
Probability: Moderate (expect that the Provincial Government will be diligent in assessing
accessibility requirements).
Mitigation strategy: Take measures to ensure that University websites comply with legislated web
accessibility requirements, such as providing tools (e.g., the University’s central WCMS), training (e.g., SEW courses in web‐content accessibility), and support (e.g., client service via phone and email) for University website maintainers.
Contingency plan: Regularly scheduled random audits of publically facing University websites,
with training and support in place to update websites to comply with AODA in areas where the audits uncover incompliance.
Independent Legal Notification of Non‐Compliance of Website(s)
Description: Members of the University community (e.g., staff and faculty) may receive
notice from outside parties claiming that a website does not meet legislated accessibility requirements.
Impact: Moderate (the level of impact can vary on a case‐by‐case basis).
Probability: Moderate (the probability is moderate since the majority University websites
do a good job at providing web content that is accessible).
Mitigation strategy: As part of a University‐wide communications plan about legislated AODA web
accessibility requirements, inform that anyone who receives notice that a website does not meet legislated accessibility requirements should not respond to it and instead should redirect the notice to the Secretariat for response. Incorporate this recommendation from the Secretariat into all web accessibility training offered to University website maintainers.
Contingency plan: Contact the Secretariat for advice and guidance.
Assuming Legal Risk for Deliverables from Web Services Providers
Description: The University assumes the full legal risk for non‐compliant web deliverables
(e.g., code, design, content) from web service providers if the service
providers are not informed of the requirement of their deliverables to comply with AODA legislation.
Impact: High (The University could be subject to widespread sign‐offs or acceptance of
deliverables that do not meet, but are required to meet, legislated AODA web accessibility requirements based on current and dispersed procurement practices at the University).
Probability: High (The probability of occurrence is high due to dispersed procurement
practices that do not require central oversight, and due to the complexity of communicating University‐wide the need to comply with legislated AODA web accessibility requirements).
Mitigation strategy: Establish pre‐approved vendor lists of suppliers that can provide web services
(e.g., web development, web design, web content production) in compliance with legislated AODA website requirements. Work with the Procurement and Contract Services Office to ensure that any RFPs/contracts for web services provision (e.g., web development, web design, web content production) include legislated AODA web accessibility requirements to transfer risk to web services providers. As part of University‐wide communications about web accessibility and AODA, include information about the need to include legislated AODA web accessibility requirements in RFPs/contracts.
Contingency plan: Implement an internal auditing process to check compliance of University
Political Risks
Political risks address whether organizational politics (e.g., leadership, resistance to
change) pose a risk to meeting the requirements.
Resistance to Changes Needed to Meet AODA Website Requirements
Description: Individuals who maintain University websites may be resistant to
implementing changes to their websites in order to comply with legislated AODA web accessibility requirements. The resistance could arise for many reasons, ranging from heavy workloads or fear of incorrectly implementing changes to blatant or deliberate disregard for the legislation.
Impact: Low (it is expected that most University website maintainers will do their best
to comply with legislated AODA web accessibility requirements).
Probability: Moderate (change, even if required by law, can be difficult for some
individuals to accept for various reasons; some individuals at the University have expressed resistance to required changes to websites in order to comply with legislated AODA web accessibility requirements).
Mitigation strategy: Create a change management plan that outlines the vision of where University
websites will be with respect to web accessibility within the next 5 years, obtain support and championship for the change from senior University leadership, support change management through readily available training and support, provide examples of University websites that do a good job of complying with legislated AODA web accessibility requirements, take appropriate action where resistance to complying with legislated web accessibility requirements is occurring (e.g., removal of non‐compliant websites or web content, appropriate disciplinary action of individuals).
Contingency plan: Consult with senior leadership about addressing continuing issues with
instances of regular or deliberate resistance to changing University websites in order to comply with legislated AODA web accessibility requirements.
Leadership Championing of Need to Meet AODA Website Requirements
Description: Awareness and active championing of legislated AODA web accessibility
requirements by senior University leadership are required to foster support and compliance with the legislation by University website maintainers.
Impact: High (support and championing of web accessibility and AODA by senior
University leadership is expected to have a high impact on University website maintainers’ compliance with legislated AODA web accessibility
requirements
