Accessibility Conversations: Sanjay Nasta and Jeff Kline
Editor’s Note: Our CEO, Sanjay Nasta visits with accessibility consultant and author Jeff Kline in our series of accessibility conversations around the 8 Key Elements for Creating a Culture of Accessibility. In this installment the pair tackle Prioritization. Where do we start? What do we need to do the job? What is the size of the effort? There are many ways to prioritize, but what makes the biggest impact?
Getting Started: The Upside-Down Pyramid Approach
Today, we wanted to talk about how to prioritize an accessibility initiative. I know bringing a culture of accessibility and organization can be a significant lift with many moving parts. You have a ton of experience with that. Jeff, can you walk us through how you prioritize the accessibility initiatives within an organization?
Certainly, I believe that prioritization should be approached from a risk mitigation perspective.
If there has been a complaint already, the status of any pending cases or judgments often helps determine the areas that need immediate attention based on whether the case is still pending or if there’s been a judgment, a consent decree, etc., and you have specific things that you need to do.
However, let’s assume that you’re starting a program and are unaware of your portfolio’s accessibility status, for both your organization’s external and internal IT assets. It might require substantial resources to fully understand the technical issues, where the issues lie, and where to start.
I discussed an “upside-down pyramid approach” to prioritization in my book. This strategy first considers the areas of highest impact: a public website or application with significant traffic, the segment with the most users, or even those driving considerable revenue in a private sector organization. Following these high-impact considerations, you then focus on medium-impact areas. The determination process can be facilitated if you use analytical tools on your websites (apps, etc..) by providing insights on website traffic and identifying crucial pages for focus.
You can use the same process for the internal IT assets of a larger organization. You might want to start with applications or an intranet that sees high usage. Critical applications, like timekeeping that everyone interacts with, could be prioritized next.
It is helpful when undertaking a prioritization to catalog your assets in a database with fields for various risk factors. Subsequently, you can delve into additional factors like whether the product was procured or developed in-house, whether accessibility criteria were incorporated during development or procurement, and if its accessibility has ever been validated. These insights can guide a risk-based model to start addressing accessibility issues.
I’m a strong proponent of tackling prioritization from a risk mitigation angle…if there’s already been a complaint, that will probably help set a priority direction, right? Often, you’d find that the state of any pending cases, judgments, settlements, or consent decrees gives you an “involuntary” roadmap of the areas that will need immediate attention.
Now, imagine you’re starting a program from scratch, and you’re not exactly sure where you stand with the accessibility of your internal and external portfolio. It might take a fair bit of effort and resources to get a clear picture of the situation, the issues, and the best point to kick things off.
Now, back to the upside-down pyramid and starts from the top (the areas with the greatest impact). Again, if you use some kind of analytical tools, they can do wonders in providing insights into your website traffic and spotlighting the pages that need your focus, given that you can’t always fix everything all at once.
Then move to your internal IT assets. You start with the applications or an intranet that everyone in the organization uses. As I mentioned earlier, important applications, like timekeeping, essential for everyone, should be high on your list.
Remember, while the scope and size of your organization are important aspects it’s also about the “reach” of your organization’s digital presence. Even if you’re a small organization, your website may have global reach with tons of consumers and readers, I’d advise focusing on implementing your accessibility policy for your external customers first. Why? Simply because (usually) you’re impacting a larger number of users.
But be very mindful that your internal technology environment also needs to be accessible to employees. So, suppose you’re part of a large organization with a complex IT infrastructure used by many employees. In that case, it’s essential to have a balanced approach to your accessibility policy. That way, you’re delivering accessibility to both internal and external stakeholders.
A Linear Process is Not Required
In our previous conversations, we’ve discussed the prerequisites for delving into IT-related prioritization, such as setting policies, ensuring stakeholder buy-in, and securing budget allocation. Therefore, when considering prioritization, these foundational elements should already be in place.
Helpful for sure – but the process doesn’t necessarily have to be linear. One could acknowledge the need for accessibility in their products, possibly even driven by the legal team, who might be concerned about compliance. You don’t necessarily have to have a policy in place to understand compliance posture, and many organizations don’t and seem resistant to take that step even though they could be working diligently to improve the accessibility of their IT. I have a couple of ideas on why that might be, but having a policy is helpful to drive and motivate or incentivize people to cooperate.
Getting back to the prioritization piece, understand that even generating a list of the areas you want to focus on can be quite a challenge, especially in a large company with hundreds of products and thousands of internal applications worldwide.
So, while a linear progression can be helpful, it’s not a requirement. You can start this process at any time. Once you’ve made some progress in prioritization, you can do a deeper dive into the issues, estimate the resources and time needed for remediation, and consider whether it applies to internal or external assets.
From there, you can start incorporating these considerations into your budget. I would say, on the budget side, it needs to happen at a point where you can feasibly include remediation costs in your budget plans.
When we’re called upon to help an organization with accessibility, one of the first things is to inventory its diverse set of assets. This ranges from software and websites to documents, e-learning materials, and more. We also examine both internal and external applications. Doing an inventory from such a broad spectrum is challenging, but it remains a crucial part of the journey toward making sure an organization’s digital assets are accessible.
Yes, and it takes cooperation from an organization’s internal resources. An external company can’t create an accessibility plan in a vacuum. And while it can be challenging for an organization to take stock independently, by working with the correct areas, and focusing on the right parameters, a pretty good snapshot of the environment can be obtained.
Well, one of the phrases you used was “a risk-based approach.” What risks are we looking at mitigating?
The larger the user base, the higher the probability of encountering issues, particularly if we consider that approximately 10% of the population has some form of disability. We can dissect that further and examine the breakdown of specific types of disabilities to prioritize what to fix. However, the main point is that the larger your user base, the higher the likelihood you’ll have users experiencing difficulties with a particular application.
This can result in a range of repercussions, including complaints that may lead to litigation. Depending on the scope of the issue, it can escalate quite dramatically. As an example, I believe we’ve previously discussed the Domino’s Pizza case. They’ve become a poster child for having accessibility issues and the way not to handle them. That is, taking the wrong approach in terms of dealing with these issues through resistance and the courts rather than just working with the plaintiff on committing to fix their application and being a good corporate citizen.
So, in terms of risk, that’s one key area. However, there are other risks too. For instance, if you’re procuring products – and we’ve discussed that around 90% of your IT is likely procured – complaints can trigger disputes between customers and suppliers, depending on contract stipulations. This can create a web of complexities that can become very risky, especially once it reaches the public sphere, leading to potential PR issues. This risk increases depending on the extent of the information’s reach.
Setting Roles and Responsibilities
That is a good summary. How do you choose who’s responsible for the prioritization process?
If an organization has an accessibility center, coordinator, or Chief Accessibility Officer (CAO), they would be good candidates to oversee this process. Alternatively, if the IT department, which manages internal and external environments, has enough vested interest, they could also take the lead. However, it’s crucial to note that this task requires a substantial commitment from management – someone who understands the importance of ensuring as many assets as possible are compliant.
What role do stakeholders and user feedback playing the prioritization process?
Stakeholders can be found both within and outside an organization. Internally, they could include product managers or IT directors, HR, or other areas of the organization. After all, issues related to accessibility could leave a mark on a company’s reputation/brand, especially if they were aware of these problems and chose to ignore them until they escalated.
Then, there are the stakeholders who are the users of these digital assets – internal stakeholders within your organization or, external stakeholders from the disability community who must interact with your digital assets.
Additionally, the heads of various departments within the organization where these digital assets reside are important stakeholders as they ultimately have responsibility/accountability for the IT they deploy. But, essentially, there are many different parties involved who have a vested interest or “skin in the game,” if you will, in ensuring accessibility – a term that might be more apt than ‘stakeholder.’
When it comes to prioritization, how actively should we involve the stakeholders? Are they integral to this process?
In my view, you don’t necessarily need end users who have encountered difficulties involved directly in the prioritization stage. It’s more beneficial to bring them into the conversation when developing plans to address and resolve accessibility issues. Here, their insights on where they experience the most trouble can be extremely valuable.
But when it comes to the actual task of prioritizing, their involvement may not be crucial.
So, their input becomes more valuable later in the process?
Yes, that’s how I see it.
Much like any project, maintaining momentum can be challenging. A common struggle we encounter is the push and pull of resource allocation. Everyone understands the need for accessibility, but there always seems to be a ‘but’, often related to product release or other pressing needs. So, how do you champion prioritizing accessibility amidst these constant constraints?
You’ve touched upon two intertwined topics here. First is the act of creating prioritization, maybe via a risk-based or revenue model, and the second is once we know what lies ahead, how do we best allocate resources to address these matters efficiently and take the risk level down.
There are strategies like addressing low-hanging fruit. For instance, if you have a high-risk procured product, engage the manufacturer, and discuss their plans for compliance. If you’re using third-party services for the web you can hold their feet to the fire….if (big if), you’ve got verbiage somewhere in your agreements that deal with accessibility. Even if your agreements with these third parties don’t explicitly mention accessibility, broad compliance clauses could be leveraged to push them.
Remember, the goal isn’t always to have every single element fixed and remediated immediately. Demonstrating consistent effort and progress can go a long way in showing commitment to accessibility.
That’s a good point. I’m using prioritization in two different ways. On one hand, we have how you develop the culture of accessibility; on the other hand, we’re discussing how to prioritize the practical aspects of implementation. We have discussed the latter more thoroughly in a previous conversation.
It’s fundamentally about the organizational aspects, such as establishing a clear policy, integrating accessibility into the various processes, and creating an organizational structure that supports these efforts.
Challenges and Constraints
What are some challenges when prioritizing accessibility efforts that you have seen at large organizations?
When an organization lacks maturity in its approach to accessibility, it faces numerous uncertainties. They might be unsure whether accessibility provisions were incorporated into contracts, or if any assets were ever tested for accessibility. Determining who was responsible for the development of an asset or who to engage for questions can also be unclear. Consequently, collating these pieces of information to gain a comprehensive understanding can be a formidable task. Nevertheless, you often have to assume that there have been no previous efforts, starting from zero. Of course, the importance of the asset to the organization will inevitably influence the approach taken.
One challenge you highlighted earlier relates to gaining access to all digital assets for inventory or testing purposes, whether you’re within an organization or external to it. How do you navigate this challenge?
Sanjay, allow me to clarify. You don’t necessarily need direct access to these assets. You need access to the individuals who can provide you with a list of what they consider their most critical assets, along with relevant information about them. During the initial phase, when you’re prioritizing, there’s no need to have access to the assets themselves. This comes into play later when you’ve determined which assets are of high priority and you’re devising plans to address potential issues.
What’s the next step after you get all this stuff prioritized? What do you do after that?
Digging deeper into each is crucial once you’ve prioritized all the digital assets. Suppose you’ve included a reasonable subset of them. In that case, might take the top two or three from each key business area since each business unit will have its high-priority products. These can then be targeted for a deeper technical analysis to understand the scope of the accessibility issues, associated costs to remediate, or even where the product is in the IT life cycle. If planned for sunset in the near future, you may choose just to maintain the risk until it goes bye-bye. So, the challenge is to understand how these factor into the overall pool.
Let’s consider a high-risk example: your website has no accessibility measures in place. A third party developed it, and there was no stipulation for accessibility in the contract. Neither was there any accessibility testing or criteria applied. This needs attention right away.
Next, you develop a plan of action, and there might be multiple ways to approach this. One might be to confront the vendor and express your dissatisfaction. Another might be to start addressing key pages if you’re now managing the website. You might begin to fix the most critical pages and remove irrelevant content or documents.
Alternatively, you might decide to limp along with the current website, knowing that you plan to overhaul it in a year or so. At that point, you would be adamant about incorporating accessibility into the new contract.
You might then turn to another high-priority asset that your organization owns. For instance, let’s say you’ve built this asset on an inaccessible platform requiring significant work to rectify. Given the business issues, you must evaluate its importance: should you buy this or a similar asset from a third party in the future? Do you invest in the effort to fix it now? Other solutions??
Ultimately, each asset must be treated individually. This process often requires testing to understand where the issues lie fully, and someone needs to estimate the effort involved. It all comes down to fundamental project management principles.
There’s certainly an intriguing contrast in prioritizing accessibility efforts. For example, a public website viewed daily by countless customers and employees clearly has high risk.
On the other end of the spectrum, we see examples of low-use assets, such as archival documents from board meetings 20 years ago, that haven’t been touched in years. So we have this contrast: an asset used thousands of times a day versus an asset that hasn’t seen the light of day in years.
That’s where analytics can come into play.
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 that includes policy, rulemaking, process integration, procurement, and risk mitigation. He currently serves as Microassist’s Strategic IT Accessibility Consultant and was recently the Program Director of Statewide Electronic and Information Resources (EIR) Accessibility at the Texas Department of Information Resources. In addition, Mr. Kline consults on IT accessibility policy matters for federal agencies, NGOs, and accessibility certification bodies. Prior to his position in public service, Mr. Kline managed IBM’s Worldwide Accessibility Consulting and Business Transformation initiatives and 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.
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