Jeff Kline is the author of Strategic IT Accessibility: Enabling the Organization and is a recognized subject matter expert in key areas of IT accessibility, including policy, rule making, process integration, procurement, and risk mitigation. He formerly served as Program Director of Statewide Electronic and Information Resources (EIR) Accessibility at the Texas Department of Information Resources. Jeff consults on IT accessibility policy matters for federal and state agencies, educational institutions, NGOs, and accessibility certification bodies. We are excited to have Jeff work with Microassist on consulting engagements with our clients.
Before his recent position in public service, Mr. Kline managed IBM’s Worldwide Accessibility Consulting and Business Transformation initiatives. He held other management positions in research and product development during his 26-year IBM career, including industrial design, operating system UI development, and system usability.
Accessibility policy is essential to establishing an accessible culture within an organization. We are pleased to talk to Jeff today about the various facets of accessibility and how an effective policy drives change, as we dive deeper into accessibility elements covered in our previous interview with Jeff–8 Key Elements for Creating a Culture of Accessibility
Sanjay Nasta: Jeff, let’s start with the basics, what is an accessibility policy?
Jeff Kline: An accessibility policy is the defined, and overarching governance at the organization level that communicates to the entire organization the importance of accessibility, what needs to be done at the high levels of the organization to make sure that accessibility gets pushed down into all the tiers of an organization, and drives accessibility activities across the organization.
Accessibility Policy is the foundation on which all parts of an accessibility initiative are built. It is also sometimes considered the “stick” side of the “carrot and stick” approach to achieving organizational goals. Without a policy, there’s nothing to point to for the enforcement of accessibility initiatives at the organization level.
Sanjay Nasta: To summarize, a policy is a governance tool.
Jeff Kline: Yes, it’s a high-level governance tool. It doesn’t delve into the details of what needs to be done, but does provide an overarching framework.
Sanjay Nasta: How do you determine what kind of organizations need an accessibility policy?
Jeff Kline: The size of an organization is one factor that drives the need for an accessibility policy however it is not the sole factor.
The “reach” of an organization’s digital presence, that is, selling products and services on the web or having information resources on the web that can be used by the general population drives an increased need for an accessibility policy focused on external customers.
Even if your organization is relatively small, with few employees, the organization’s website could have a worldwide reach with lots of consumers and readers. In this case, I’d recommend that the organization focus on implementation of their accessibility policy for your external customers first due to the high number of potential users and therefore would have a broader impact.
Also, in an organization, you must consider making your internal technology environment accessible for employees. The number of internal vs. external stakeholders can drive which portion of accessibility policy to prioritize.
When you get into larger organizations with more employees and a complex IT infrastructure that’s being used by all those employees, and you have a large external digital presence then it is important to have a balanced approach to an accessibility policy that delivers accessibility to both internal and external stakeholders
Sanjay Nasta: Are there organizations that are legally required to have an accessibility policy?
Jeff Kline: Yes, many government and educational organizations have regulations that mandate an accessibility policy. For example, the State of Texas requires all Texas government agencies and state-funded higher ed institutions to have an accessibility policy.
The State of Texas also mandates accessibility criteria in digital procurement policy. Most people don’t think about having a procurement policy related to accessibility, but procurement is one of THE most important areas, as it can impact so much of an organization’s internal and external accessibility.
Unfortunately, there is currently no language in the ADA that specifically addresses digital accessibility, but the Department of Justice has stated that websites are considered a public accommodation. Note that while this does not direct businesses to have an accessibility policy for their website, it should be noted that when accessibility lawsuits are resolved in favor of the plaintiff, courts have frequently included a requirement for the defendants to implement an accessibility policy as part of the remedies.
Sanjay Nasta: What’s the difference between an accessibility statement and an accessibility policy?
Jeff Kline: There often seems to be confusion between an accessibility statement and an accessibility policy. An accessibility statement is a published communication that focuses on the intent of the organization, typically about an organization’s “commitment” to accessibility. Many times, accessibility statements are flowery and optimistic. That’s not really governance.
An accessibility policy is a document that directs the organization and employees to implement digital accessibility. It is frequently only published internally, although in the public sector it can be published publicly. The policy communicates:
- The purpose of an accessibility policy
- Why accessibility is important
- Who’s responsible for various facets of accessibility
- Key elements to drive accessibility
Without having an overall policy driving the organization there are not a lot of teeth to drive people to work on accessibility within an organization. A good accessibility policy tells the organization: Who is responsible for accessibility. What needs to be done? How to deal with accessibility issues. An accessibility policy mandates that IT buys and uses technology that is as accessible as possible.
Sanjay Nasta: What are the key components of the accessibility policy?
Jeff Kline: Well, that really depends on a lot of things. the size of the organization, the culture of the organization, and whether the organization is a public sector organization or a private company. There are a lot of ways to go about it.
When an organization is getting ready to build a policy, one of the first things they should do is go out and do some research as to policies in organizations that may be like theirs. Look at the strengths and weaknesses of those policies and try to build the policy based on that.
I always get a question. Well, who has the best policies out there, I don’t really have an answer for that because it depends on lots of factors such as the type of organization and the culture of the organization.
Sanjay Nasta: How would you recommend an organization start creating an accessibility policy?
Jeff Kline: First, obtain buy-in from the organization’s high level to develop the policy since you don’t want to go through all this effort and the policy is then rejected by the organization’s leadership.
Make sure that you present digital accessibility in a compelling way so that leadership of the organization recognizes the importance and need for the policy.
Once you have this buy-in, assemble a team of experts to help create an accessibility policy. The team should include one or more accessibility subject matter experts, somebody within the organization who’s familiar with the organization’s policy processes and how to implement them. You might consider hiring a consultant who is well-versed in accessibility governance to assist as well. An external expert brings expertise from similar organizations and has a sense of what can be realistically achieved.
Make sure that the heads of all critical departments have a chance to review and comment on the draft policy before it’s implemented and take their input seriously. It’s difficult to secure approval for a policy if you can’t build support throughout the company. Even if you manage to get the plan approved, getting your organization to follow the guidelines and do what needs doing is tough without buy-in.
Sanjay Nasta: Developing an accessibility policy is a complex process with a lot of different roles involved.
Jeff Kline: It can be. But not necessarily dissimilar to policy work within an organization needed in other areas.
One area that you don’t want to forget to include in your workgroup is a representation within the organization from the disability community. This is very important.
There’s a slogan within the accessibility community – “Nothing for us without us.” If you try to do all this in a kind of a vacuum, without this representation, you could end up missing the mark.
Sanjay Nasta: A couple of these roles might be external to the organization.
Especially smaller organizations that might not have a subject matter expert on accessibility, nor a person who is disabled on the team.
Sanjay Nasta: I frequently compare accessibility to security. I think another characteristic is security requires constant vigilance. Constant update of policy constant update of tools. Is that a similar Process for accessibility?
Jeff Kline: Yes, I would say so. The landscape is always changing and there are lots of tools and techniques that are becoming available to help improve the accessibility posture. The policy should be designed to be somewhat dynamic, meaning that it should be reviewed at regular intervals and modifications considered based on new knowledge and experience obtained during the implementation of the organization as it evolves the program.
Sanjay Nasta: You’ve got a policy created with this team. Now, what’s next? What do you do with this policy?
How does it become? How does it start affecting the organization in a positive way?
Jeff Kline: Great question.
Once you have the policy fully approved and you’ve obtained the buy-in from all the executives and leadership you put together a communications plan to communicate the policy to the organization. The communication plan should outline how to communicate the accessibility policy with staff and the outside world if required, as well as what an accessibility policy entails for the business and how a stakeholder’s role fits within the policy.
There’s going to be a little bit of ramping up time for your team. The development communities, programmers, and content producers are going to need to learn about what accessibility means and what they need to do technically to ensure that the things that they’re building, and publishing are compliant with accessibility such as WCAG 2.0 AA and WCAG 2.1 AA
HR will need to consider how the accessibility policy should be put into action and how hiring processes and performance goals must be altered to some extent for accessibility criteria to be considered.
The procurement department is crucial since typically 90% of an organization’s IT is purchased. So, you’ll always be buying non-accessible items, which has a negative influence on internal accessibility and, in some cases, the products you sell in the market.
Sanjay Nasta: There’s a lot to cover in future sessions, from purchasing to training that helps make the accessibility policy a living document.
Jeff Kline: The one thing I want to emphasize is that once you have that policy, the next step is to ensure that accessibility is integrated into your organization’s processes and procedures. Some of it will have to do with updating current procedures and making them more accessible. It may also necessitate the creation of new processes and standard operating procedures.
Without process, you’re dependent on various individuals who maybe understand accessibility. But if those individuals leave the organization, then that knowledge and progress on accessibility leave with them and you’re back to square one, so the policy drives processes.
Sanjay Nasta: That’s powerful because documenting processes is a way to capture the expertise that you have in-house and make sure that it continues.
Jeff Kline: Yes, absolutely. If you’re dependent on one or two individuals who understand accessibility, then you’ve really failed to understand what accessibility is and how to care for and feed it over time.
Sanjay Nasta: When you’ve gone into an organization to be in to consult on accessibility policy. What are the issues that you have typically seen?
Jeff Kline: In general, what I’ve seen is a lack of what I call accessibility maturity within the organization.
I developed a maturity model for accessibility in conjunction with my counterparts for other states–Massachusetts and Minnesota. There are other folks both commercial and non-profit that have also developed accessibility maturity models. The W3C is working on one as we speak, and I am participating in that effort.
One of the key elements of accessibility maturity is having and using a policy. However, there are other elements to accessibility maturity.
Some of the biggest IT organizations have a good handle on the accessibility maturity model. This doesn’t mean that all an organization’s products are accessible because they deal with many complexities that the smaller companies don’t, but they do have a policy in place. In addition, they have an organizational structure to drive accessibility in place. A mature accessibility organization also has training available for their team. Mature organizations are making incremental improvements to their accessibility posture every day
Sanjay Nasta: Thank you, Jeff. A lot of great information and I look forward to the next interview on the elements of building a culture of accessibility.
What do colleges and universities need to know about accessibility?
Most colleges, universities and government organizations are required to make their online content and platforms—including elearning—accessible.
We’ll help you make sure your website, applications, and digital files comply with accessibility standards such as WCAG 2.1 or Sections 504 and 508 of the U.S. Rehabilitation Act, enabling people of all abilities to access your content with ease.
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