Accessible Information Policy Implementation Report (2014-15) Trinity College Dublin, the University of Dublin Report prepared by the Disability Service, May 2015 Table of Contents 1. Executive Summary………………………………………………………………………………………………………………………………..3 2. Report .......................................................................................................................................................... 4 2.1 Print Communication………………………………………………………………………………………………………………………..4 2.2 Web Accessibility ................................................................................................................................... 5 2.3 E-Learning…………………………………………………………………………………………………………………………………………6 2.4 Person to Person Communication…………………………………………………………………………………………………….9 2.5 Information Technology Procurement……………………………………………………………………………………………10 2.6 Organised Events……………………………………………………………………………………………………………………………11 2.7 Conclusions…………………………………………………………………………………………………………………………………….13 3. Appendices………………………………………………………………………………………………………………………………………….16 2 1. Executive Summary The Trinity Accessible Information Policy highlights Trinity’s requirements in relation to the Disability Act (2005), the Universities Act (1997), the Employment Equality Act (1998, as amended) and the Equal Status Acts (2000, as amended). Trinity’s Disability Service (DS) was delegated responsibility by the Provost when the Disability Act 2005 applied to public bodies such as Trinity in 2007. Trinity’s Accessible Information Policy addresses the following areas: Print communication College web accessibility e-Learning accessibility Person to person communication Information Technology procurement College organised events The DS is responsible for reporting to the Equality Committee and Board on Trinity’s compliance with this policy and this report details work undertaken in academic year 2014-15. The Trinity Audit Committee via the College Risk Register continues to note non-compliance with this policy, stating: 1247.5.1 Non –compliance with the accessible information policy and legislative requirements and action taken immediately 1247.6.1 Following the poor response to the Trinity Inclusive Curricula evaluation programme and ceasing of funding, a Project sponsor, at a senior academic level, should be considered for future projects to encourage buy in to the project to increase uptake in the initiative. In addition the recent external Quality Review of the Disability Service raised significant concern in regard to Disability policy and implementation and recommendation two in the review of the Disability Service states: Senior managers should support the DS by championing relevant disability related policies, including the use of Blackboard VLE in advance of lectures, and where possible to provide notes or video capture of the lectures. The College should ensure that all academic staff follow and abide by the Trinity Inclusive 3 Curriculum (TIC). Robust implementation of disability policy – the reviewers consistently reference the significant legal risks associated with the lack of consistency of application of these policies. It is recommended that the Trinity Accessible Information Policy is consumed in the revised Trinity Equality Policy along with a clear implementation plan with reporting annually from all areas (academic and administrative) on progress through this key Trinity policy. In addition this report focusses on the following areas in particular: print communication (2.1), web accessibility (2.2), e-Learning accessibility (2.3), person to person communication (2.4), Information Technology procurement (2.5) and college organised events (2.6). The report outlines the Disability Service’s actions with regard to the Accessibility Information Policy and outlines the areas that require increased college ownership. 4 2. Trinity Disability Service - Accessible Information Policy Implementation Report – Year 2014-15 This report highlights work undertaken by the Disability Service in academic year 2014-15 to the Equality Committee with regard to the implementation of the Trinity Accessible Information Policy (www.tcd.ie/about/policies/accessible-info-policy.php). This policy highlights Trinity’s requirements in relation to the Disability Act (2005), the Universities Act (1997), the Employment Equality Act (1998 as amended) and the Equal Status Acts (2000 as amended). 2.1 Print Communication Section 28 of the Disability Act states: Access to Information (Section 28 Disability Act) "As far as practicable", such information is transmitted or published in a format that is compatible with adaptive technologies used by visually impaired people.” Activities: a. Accessible Information Training: In January 2015, the Disability Service ran a series of training events for the staff of Trinity in order to communicate their responsibilities under the accessible information policy (appendix A – list of attendees). The event was open to all staff and academics to attend and was publicized to all school administrators/academic liaison officers and executive officers within administrative areas. The topics covered included: 1. Microsoft Word 2010 & 2013 2. Microsoft PowerPoint 2010 & 2013 3. Adobe Acrobat Reader & Adobe Acrobat Professional 4. Web accessibility via Dreamweaver 5 5. Accessible e-mail formats 6. Use of the TIC tool 7. Use of CAPSL/Disability Service online resources The session focused on giving a basic understanding to university staff of their responsibilities with regards to the provision of accessible information in both print and electronic format. Good practice was demonstrated through examples, and formatting tools were demonstrated to highlight how quickly information can be made accessible to all users without the need for advanced accessibility training. In addition, the Trinity Inclusive Curriculum (TIC) self-assessment tool http://www.tcd.ie/CAPSL/TIC/evaluation/ was demonstrated to support staff as an aid to identifying good practice in the creation of print communication. Attendees were advised to engage with the tool and promote it among their staff as a step to implementing the policy guidelines. Actions: The Disability Service will continue to support end-users with advice and group training sessions to ensure clear understanding on the creation of print communication. The Disability Service to engage with CAPSL on identifying support and training avenues, and communicating to new academic staff their responsibilities in relation to the accessible information policy. 2.2 Web accessibility The accessible information policy states: Trinity websites must meet a minimum of W3C Level 2 compliance in line with the Web Accessibility guidelines (WCAG 1.0). (https://www.tcd.ie/about/policies/accessible-infopolicy.php) The Trinity web office own and maintain web accessibility standards across the Trinity domain. This web office provides advice on web design structure and the layout of content to authorised departments/school web authors. The Trinity web accessibility policy sets out a commitment to meet international WCAG standards to level 1, ensuring the below standards are maintained: 6 a. Clear Navigation to ensure that all menu navigation can be read by screen readers and the first link on a Trinity web page is a hidden link called skip to main content. Heading elements (H1, H2, H3) etc. are used extensively throughout the website along with ‘skip links’ and ‘back to top’ links. b. Tables’ attributes – Data tables to include summary attributes and are coded using Row and Column titles. c. Image’s identification - All images to use an ALT attribute or LONGDESC attribute. d. Forms labelling - All forms to use labels and are explicitly linked to relevant input field Action: The Disability Service to communicate the need on increasing WCAG standards to level 2 standard. 2.3 E-learning The accessible information policy states: All course management products such as WebCT, and course delivery mechanisms such as podcasting and I-Tunes should be accessible to all users. Electronic eLearning materials (mainly presented via the web) conform to the World Wide Web Consortium's W3C Web Content Accessibility Guidelines and adhere to the principles of Universal Design. (https://www.tcd.ie/about/policies/accessible-info-policy.php) Activities: In September 2014, Trinity launched their first online course: a postgraduate Diploma in Applied Social Studies from the School of Social work. The course’s content is hosted solely online via Trinity VLE platform – Blackboard. Online courses offer unique opportunities in terms of accessibility, and the Disability Service in consultation with the School of Social Studies, undertook an audit to evaluate the accessibility of the course. 7 The three users who have a visual impairment evaluated the course with a variety of assistive technology (AT): Student A uses assistive technology to invert colours and to perform low level magnification. Student B uses assistive technology to magnify the screen to a high level and uses audio feedback to navigate information. Student C, a blind user, solely uses assistive technology screen-reading software to navigate the site. Each student met separately with the Disability Service assistive technology officer Andrew Costello for 12 hours and asked to interact with the course to complete the below tasks: 1. Login to blackboard - 2. Find the appropriate module 3. Navigate to the introduction information 4. Navigate each session material 5. Interact with blogs 6. Interact with links The WCAG 2.0 Checklist (appendix B) was used to mark the level of interaction and accessibility of the course. The students marked the checklist against four major areas: 1. Perceivable - Web content is available to the senses – sight, hearing and/touch. 2. Operability – Interface controls and navigation are operable. 3. Understandable content i.e. readable 4. Robustness - Content can be used reliably by a wide range of agents including assistive technologies. Overall the feedback from the students on their interaction with the online course was positive. Users with appropriate knowledge of keyboard shortcuts were able to identify the page layout and structure and use the appropriate keystrokes shortcuts to interact in an efficient manner. In the above testing, the Disability Service noted that the student must possess the necessary skill in the use of assistive computer technologies to interact successfully with the container. 8 Actions: The following issues were identified by the participating students via the use of the graded WCAG checklist: 1.2.2 Synchronised caption are provided for no-live, web based video - At present there are no captions available for the multimedia content within this course. Action: Disability Service recommends such content to be made fully accessible with the use of online tools or an external provide at low cost - http://www.3playmedia.com/ 1.2.3 The reading and navigation order is logical and intuitive – Student C commented on the difficulty in identifying a clear and usable pathways to the content. With testing, this was achievable but the student questioned whether a user with poor screen-reader (JAWS/NVDA) ability would be able to navigate in a similar manner. Action: The Disability Service recommends a list of keyboard shortcuts to be made available by the Centre for Academic Practices and eLearning (CAPSL) to the user via the help area 1.4.4 The page is readable and functional when text size is doubled – Student A reported difficulty in visually making out text when it is enlarged. It becomes blurred and difficult to read slowing the user down in their interaction with page. Action: The Disability Service recommends that CAPSL to investigate with Blackboard. 2.1.2 No keyboard trap – Keyboard focus is never locked in one page element. The user can navigate to all navigable pages elements. Student B was unable to move keyboard focus from the side navigation to the main content in a usable manner. With time and support the user was able to accomplish such tasks but needed assistance to identify the page layout. Action: The Disability Service recommends a list of keyboard shortcuts to be made available by CAPSL to the user via the help area. 2.4.1 A link is provided to skip navigation and other page elements that are repeated across the web page - Student C was unable to locate a tag element to enable the student to skip to the main content of the page and avoid the unnecessary Document Object Model (DOM) interaction. 9 Action: The Disability Service recommends a list of keyboard shortcuts to be made available by CAPSL to the user via the help area 2.4.7 It is not visibly apparent which page element has the current keyboard focus (i.e. as you tab through the page) - Students A and C highlighted the issues of been unable to identify keyboard ‘quick links’ and ‘refresh’ functionality. The users were unsure of their location on the course and it caused confusion in the navigation of the site. Action: The Disability Service recommends a list of keyboard shortcuts to be me made available by CAPSL to the user via the help functionality. Inaccessible information – All participants emphasised the need to ensure that material uploaded to the course is accessible. They commented on the poor Pdf and word documentation design, without correct navigation or use of Optical Character Recognition (OCR) the document is inaccessible and unusable to users of AT. Action: The Disability Service recommends that course designers are made aware by CAPSL accessible information guidelines. The Disability Service to work with CAPSL to improve navigation and awareness of designing documents in universal as per the online resources hosted at http://www.tcd.ie/CAPSL/TIC/accessible-info/ . 2.4 Person to person Communication The accessible information policy states: Trinity will ensure that information will be provided in an accessible manner when speaking to a person with a hearing impairment (https://www.tcd.ie/about/policies/accessible-info-policy.php) Activities: In July 2014 all portable loop systems within all administrative areas were serviced and checked for use by the Disability Service. These devices provide a vital link for staff and students who are hard of hearing. 10 Such devices amplify a conversation on a student’s hearing aid. Locations of such devices have been added to the universities online maps at http://www.tcd.ie/Maps/map.php Guidelines for working with Irish Sign Language Interpreters (ISL) continued to be piloted in 2014-15. These guidelines outline how to support deaf staff, students and visitors when they require an ISL interpreter explain how to book this service, and who will cover the costs of such a service http://www.tcd.ie/disability/assets/doc/pdf/ISL%20provision%20document%20-%202012-2015.pdf Action: The Disability Service to monitor and support the use of portable loop system within Trinity. 2.5 Information Technology Procurement The accessible information policy states: To ensure Trinity makes technology accessible to all, the Trinity Procurement procedures states ‘Tenderers are expected to be compliant with all statutory requirements, for example, Disability Act 2005. (https://www.tcd.ie/about/policies/accessible-info-policy.php) Activities: The universities procurement procedure was amended in 2010-11 to ensure that all procured goods are compliant with the Disability Act 2005 (and the Trinity Accessible Information Policy). The Disability Service communicated with the Procurement Office in academic year 2013-14 on a lack of awareness of staff on their responsibilities to ensure goods and services procured via a request for tender process (RTF) were accessible and compliant with the accessible information policy. Good practice guidelines provided by the Disability Service were posted to the procurement website in the academic year 13-14 to advise staff on their responsibilities in relation to ensuring their product or service required is accessible for all. 11 Following on from this work, the Procurement Office engaged in a revised RTF procedure to revise this process in order to ensure all aspects of Trinity policy were accounted for. The Disability Service proposed sample text on the area of accessibility to the Procurement Office under three main headings in-line with good practice and guidelines produced by the National Disability Authority (see appendix C). The Disability Service requested feedback on the above procedure in March 2015. Ben Hartnett (Trinity Procurement officer) replied advising that Trinity had been recently made aware that all such requests for a tendering process will be transferred out of Trinity’s procurement office to a centralised office of Government Procurement ( only capital expenditure would remain with Trinity). The Disability service met with Ben on this matter in April 2015 to request how accessibility and the implementation of the Accessible information policy guidelines would be a part of this new procedure. Actions: Trinity procurement office to advise on the new revised request for Tender process and how the agreed accessible procurement principles will be assessed under a national structure. 2.6 Trinity Organised Events The accessible information policy states: All Trinity events should be accessible to all possible attendees and every effort should be made to ensure accessibility features are considered. . (https://www.Tcd.ie/about/policies/accessible-infopolicy.php). Access to Services (Disability Act - Section 26) (a) "Where practical and appropriate", ensure that the provision of access to the service by persons with disabilities is integrated. 12 (B) "Where practical and appropriate", provide assistance, if requested, to persons with disabilities in assessing the services” (http://www.irishstatutebook.ie/2005/en/act/pub/0014/sec0026.html) The accessible information policy provides clear guidance for all Trinity organizers of events to ensure accessibility is taken into account as part of the planning of such events. These guidelines have been included in the TCD communication office guide on organizing events, see: Communications Office guide on organizing events . Disability Specific guidance has been added to the Disability Service web page to give added information on ensuring event organizers understand all disability requirements. Due to the high number of events (which includes Trinity Committee meetings), and multiple organizers these guidelines are not always adhered to, leading to some complaints from disabled persons that accessibility was not considered. Trinity has a responsibility to ensure organizers of university events are aware of the importance of ensuring accessibility to their event Issues outstanding: The Disability Service notes there is no one central booking system in Trinity for booking rooms and no one central systems. Information on accessibility of venues is publically available but organisers are not being pro-active in ensuring accessibility leaving themselves open to complaints. Actions: The Disability Service recommends that organisers must verify their event location booking meets good practice guidelines for organising university events as outlined in the Accessible Information Policy: https://www.Tcd.ie/about/policies/accessible-info-policy.php#events 13 2.7 Conclusions The Disability Service sets out six different. Listed are areas that the Disability Service will continue to monitor in order for the policy to be successfully implemented in academic year 2015-2016. Print Communication: The Disability Service to support requested site visits, training and remote support on accessibly queries, and on the creation of print communication that ensures compliance with university policy as provided by the Disability Service. The Disability Service to promote the use of the online resources and online self-evaluation TIC tool upon request as they provide a ready-to-use resource on the creation of accessible print content via staff training events. Trinity Websites Trinity web office to ensure that all university websites administrators (Web-authors) adhere to Web Content Accessibility Guidelines (WCAG) and Trinity web accessibility policy as set down by the policy. . E-Learning The Disability to work with CAPSL on the development of training resource embedded into Blackboard to assist in the creation of accessible content for course developers. 14 CAPSL to promote and support the use of alternative formats audio/multimedia for use on Blackboard. The use of such formats allows for a more usable platform and gives alternative methods for students to access information. Person to Person Communication: The Disability Service to continue to train and advise staff in the use and position of portable loops systems available in Trinity administrative offices. Information Technology Procurement The Procurement Office to communicate a clear procurement accessible request for tender process. Trinity Organized Events and activities The Disability recommends a clear campus wide communication to admin/academic areas in Trinity to engage with clear information available on the communication office website ensuring all events are accessible and comply with Trinity guidelines. 15 16 Accessible Information report 2014-2015: Appendices Appendix A- List of Attendees to the accessible information training – January 2015, Berkley Library Training rooms 1 .Sheila Nesbit - Student Counselling 12. Christina Reynolds – Human Res 2. Deirdre Flanagan – Accommodation office 13. Kathleen Reynolds - Exams office 3. Jacinta Jardine - Student Counselling 14. Kevin O Connor – CAPSL 4. Conor Rapple - IS Services 15. Catherine Kane – CAPSL 5. Susan McCormack- Secretaries office 16. Megan Pittman – IS Services 6. Aoife Crawford - Irish language Office 17. Fiona Logan – IADT 7. Yvonne Howell - School of Dental science 18. Helen Farrelly –School of Dental SCi 8. Rosemarie Power - School of Computer Science 19. Aiden Woods – School of Ecumenics 9. Jean Maypother - School of Computer Science 20.Sarah Power – Exams office 10. Julia Whittredge - School of English 11. Gráinne Curistan - Global relations 17 Appendix B WCAG 2.0 Checklist Perceivable Web content is made available to the senses - sight, hearing, and/or touch Guideline 1.1 Text Alternatives: Provide text alternatives for any non-text content Success Criteria Recommendations All images, form image buttons, and image map hot spots have appropriate, equivalent alternative text. Images that do not convey content, are decorative, or with content that is already conveyed in text are given null alt text (alt="") or implemented as CSS backgrounds. All linked images 1.1.1 Nontext Content (Level A) have descriptive alternative text. Equivalent alternatives to complex images are provided in context or on a separate (linked and/or referenced via longdesc) page. Form buttons have a descriptive value. Form inputs have associated text labels. Embedded multimedia is identified via accessible text. Frames are appropriately titl 18 Guideline 1.2 Time-based Media: Provide alternatives for time-based media NOTE: If the audio or video is designated as an alternative to web content (e.g., an audio or sign language version of a web page, for example), then the web content itself serves as the alternative. Success Criteria 1.2.1 Prerecorded Audioonly and Video-only (Level A) 1.2.2 Captions (Prerecorded) (Level A) 1.2.3 Audio Description or Media Alternative (Prerecorded) Recommendations A descriptive text transcript (including all relevant visual and auditory clues and indicators) is provided for non-live, web-based audio (audio podcasts, MP3 files, etc.). A text or audio description is provided for non-live, web-based video-only (e.g., video that has no audio track). Synchronized captions are provided for non-live, web-based video (YouTube videos, etc.) A descriptive text transcript OR audio description audio track is provided for non-live, web-based video (Level A) 1.2.4 Captions (Live) (Level AA) Synchronized captions are provided for all live multimedia that contains audio (audio-only broadcasts, web casts, video conferences, Flash animations, etc.) 1.2.5 Audio Description (Prerecorded) (Level AA) Audio descriptions are provided for all video content NOTE: Only required if the video conveys content visually that is not available in the default audio track. 1.2.6 Sign Language (Prerecorded) (Level AAA) A sign language video is provided for all media content that contains audio. 1.2.7 Extended Audio Description (Prerecorded) (Level AAA) When an audio description track cannot be added to video due to audio timing (e.g., no pauses in the audio), an alternative version of the video with pauses that allow audio descriptions is provided. 1.2.8 Media Alternative (Prerecorded) (Level AAA) 1.2.9 Audio-only (Live) (Level AAA) A descriptive text transcript is provided for all pre-recorded media that has a video track. A descriptive text transcript (e.g., the script of the live audio) is provided for all live content that has audio. 19 Guideline 1.3 Adaptable: Create content that can be presented in different ways (e.g., simpler layout) without losing information or structure Success Criteria Recommendations Semantic markup is used to designate headings (<h1>), lists (<ul>, <ol>, and <dl>), emphasized or special text (<strong>, <code>, <abbr>, <blockquote>, for example), etc. Semantic markup is used appropriately. 1.3.1 Info and Relationships (Level A) 1.3.2 Meaningful Sequence (Level A) 1.3.3 Sensory Characteristics (Level A) Tables are used for tabular data. Headings, where necessary, are used to associate data cells with headers. Data table captions and summaries are used where appropriate. Text labels are associated with form input elements. Related form elements are grouped with fieldset/legend. The reading and navigation order (determined by code order) is logical and intuitive. Instructions do not rely upon shape, size, or visual location (e.g., "Click the square icon to continue" or "Instructions are in the right-hand column"). Instructions do not rely upon sound (e.g., "A beeping sound indicates you may continue."). Guideline 1.4 Distinguishable: Make it easier for users to see and hear content including separating foreground from background Success Criteria 1.4.1 Use of Color (Level A) Recommendations Color is not used as the sole method of conveying content or distinguishing visual elements. Color alone is not used to distinguish links from surrounding text unless the luminance contrast between the link and the surrounding text is at least 3:1 and an additional differentiation (e.g., it becomes underlined) is provided when the link is hovered over or receives focus. 1.4.2 Audio Control (Level A) A mechanism is provided to stop, pause, mute, or adjust volume for audio that automatically plays on a page for more than 3 seconds. 1.4.3 Contrast (Minimum) (Level AA) Text and images of text have a contrast ratio of at least 4.5:1. Large text (over 18 point or 14 point bold) has a contrast ratio of at least 3:1 1.4.4 Resize text (Level AA) The page is readable and functional when the text size is doubled. 1.4.5 Images of Text (Level AA) If the same visual presentation can be made using text alone, an image is not used to present that text. 20 1.4.6 Contrast (Enhanced) (Level AAA) 1.4.7 Low or No Background Audio (Level AAA) 1.4.8 Visual Presentation (Level AAA) 1.4.9 Images of Text (No Exception) (Level AAA) Text and images of text have a contrast ratio of at least 7:1. Large text (over 18 point or 14 point bold) has a contrast ratio of at least 4.5:1 Audio of speech has no or very low background noise so the speech is easily distinguished. Blocks of text over one sentence in length: Are no more than 80 characters wide. Are NOT fully justified (aligned to both the left and the right margins). Have adequate line spacing (at least 1/2 the height of the text) and paragraph spacing (1.5 times line spacing). Have a specified foreground and background color. These can be applied to specific elements or to the page as a whole using CSS (and thus inherited by all. Text is used within an image only for decoration (image does not convey content) OR when the information cannot be presented with text alone. 21 Operable Interface forms, controls, and navigation are operable Guideline 2.1 Keyboard Accessible: Make all functionality available from a keyboard Success Criteria Recommendations 2.1.1 Keyboard (Level A) All page functionality is available using the keyboard, unless the functionality cannot be accomplished in any known way using a keyboard (e.g., free hand drawing). Page-specified shortcut keys and accesskeys (accesskey should typically be avoided) do not conflict with existing browser and screen reader shortcuts. 2.1.2 No Keyboard Trap (Level A) Keyboard focus is never locked or trapped at one particular page element. The user can navigate to and from all navigable page elements. 2.1.3 Keyboard (No Exception) (Level AAA) All page functionality is available using the keyboard. Guideline 2.2 Enough Time: Provide users enough time to read and use content Success Criteria 2.2.1 Timing Adjustable (Level A) 2.2.2 Pause, Stop, Hide (Level A) 2.2.3 No Timing (Level AAA) Recommendations If a page or application has a time limit, the user is given options to turn off, adjust, or extend that time limit. This is not a requirement for real-time events (e.g., an auction), where the time limit is absolutely required, or if the time limit is longer than 20 hours. Automatically moving, blinking, or scrolling content that lasts longer than 5 seconds can be paused, stopped, or hidden by the user. Moving, blinking, or scrolling can be used to draw attention to or highlight content as long as it lasts less than 5 seconds. Automatically updating content (e.g., automatically redirecting or refreshing a page, a news ticker, AJAX updated field, a notification alert, etc.) can be paused, stopped, or hidden by the user or the user can manually control the timing of the updates. The content and functionality has no time limits or constraints. 22 2.2.4 Interruptions (Level AAA) 2.2.5 Reauthenticating (Level AAA) Interruptions (alerts, page updates, etc.) can be postponed or suppressed by the user. If an authentication session expires, the user can re-authenticate and continue the activity without losing any data from the current page. Guideline 2.3 Seizures: Do not design content in a way that is known to cause seizures Success Criteria Recommendations 2.3.1 Three Flashes or Below Threshold (Level A) No page content flashes more than 3 times per second unless that flashing content is sufficiently small and the flashes are of low contrast and do not contain too much red. (See general flash and red flash thresholds) 2.3.2 Three Flashes (Level AAA) No page content flashes more than 3 times per second. Guideline 2.4 Navigable: Provide ways to help users navigate, find content, and determine where they are Success Criteria Recommendations A link is provided to skip navigation and other page elements that are repeated across web pages. 2.4.1 Bypass Blocks (Level A) 2.4.2 Page Titled (Level A) 2.4.3 Focus Order (Level A) 2.4.4 Link Purpose (In Context) (Level A) If a page has a proper heading structure, this may be considered a sufficient technique instead of a "Skip to main content" link. Note that navigating by headings is not yet supported in all browsers. If a page uses frames and the frames are appropriately titled, this is a sufficient technique for bypassing individual frames. The web page has a descriptive and informative page title. The navigation order of links, form elements, etc. is logical and intuitive. The purpose of each link (or form image button or image map hotspot) can be determined from the link text alone, or from the link text and it's context (e.g., surrounding paragraph, list item, table cell, or table headers). Links (or form image buttons) with the same text that go to different locations are readily distinguishable. 2.4.5 Multiple Ways (Level AA) Multiple ways are available to find other web pages on the site - at least two of: a list of related pages, table of contents, site map, site search, or list of all available web pages. 2.4.6 Headings and Labels (Level AA) Page headings and labels for form and interactive controls are informative. Avoid duplicating heading (e.g., "More Details") or label text (e.g., "First Name") unless the structure provides adequate differentiation between them. 2.4.7 Focus Visible (Level AA) It is visually apparent which page element has the current keyboard focus (i.e., as you tab through the page, you can see where you are). 23 2.4.8 Location (Level AAA) If a web page is part of a sequence of pages or within a complex site structure, an indication of the current page location is provided, for example, through breadcrumbs or specifying the current step in a sequence (e.g., "Step 2 of 5 - Shipping Address"). 24 2.4.9 Link Purpose (Link Only) (Level AAA) 2.4.10 Section Headings (Level AAA) The purpose of each link (or form image button or image map hotspot) can be determined from the link text alone. There are no links (or form image buttons) with the same text that go to different locations. Beyond providing an overall document structure, individual sections of content are designated using headings, where appropriate. Understandable Content and interface are understandable Guideline 3.1 Readable: Make text content readable and understandable Success Criteria 3.1.1 Language of Page (Level A) 3.1.2 Language of Parts (Level AA) Recommendations The language of the page is identified using the HTML lang attribute (<html lang="en">, for example). When appropriate, the language of sections of content that are a different language are identified, for example, by using the lang attribute (<blockquote lang="es")> 3.1.3 Unusual Words (Level AAA) Words that may be ambiguous, unknown, or used in a very specific way are defined through adjacent text, a definition list, a glossary, or other suitable method. 3.1.4 Abbreviations (Level AAA) Expansions for abbreviations are provided by expanding or explaining the definition the first time it is used, using the <abbr> element, or linking to a definition or glossary. NOTE: WCAG 2.0 gives no exception for regularly understood abbreviations (e.g., "HTML" on a web design site must always be expanded). 3.1.5 Reading Level (Level AAA) A more understandable alternative is provided for content that is more advanced than can be reasonably read by a person with roughly 9 years of primary education. 3.1.6 Pronunciation (Level AAA) If the pronunciation of a word is vital to understanding that word, its pronunciation is provided immediately following the word or via a link or glossary. Guideline 3.2 Predictable: Make Web pages appear and operate in predictable ways Success Criteria 3.2.1 On Focus (Level A) 3.2.2 On Input (Level A) Recommendations When a page element receives focus, it does not result in a substantial change to the page, the spawning of a pop-up window, an additional change of keyboard focus, or any other change that could confuse or disorient the user. When a user inputs information or interacts with a control, it does not result in a substantial change to the page, the spawning of a pop-up window, an additional change of keyboard focus, or any other change that could confuse or disorient the user unless the user is informed of the change ahead of time. 25 3.2.3 Consistent Navigation (Level AA) Navigation links that are repeated on web pages do not change order when navigating through the site. 26 3.2.4 Consistent Identification (Level AA) Elements that have the same functionality across multiple web pages are consistently identified. For example, a search box at the top of the site should always be labeled the same way. 3.2.5 Change on Request (Level AAA) Substantial changes to the page, the spawning of pop-up windows, uncontrolled changes of keyboard focus, or any other change that could confuse or disorient the user must be initiated by the user. Alternatively, the user is provided an option to disable such changes. Guideline 3.3 Input Assistance: Help users avoid and correct mistakes Success Criteria 3.3.1 Error Identification (Level A) Recommendations Required form elements or form elements that require a specific format, value, or length provide this information within the element's label. If utilized, form validation cues and errors (client-side or server-side) alert users to errors in an efficient, intuitive, and accessible manner. The error is clearly identified, quick access to the problematic element is provided, and user is allowed to easily fix the error and resubmit the form. 3.3.2 Labels or Instructions (Level A) Sufficient labels, cues, and instructions for required interactive elements are provided via instructions, examples, properly positioned form labels, and/or fieldsets/legends. 3.3.3 Error Suggestion (Level AA) If an input error is detected (via client-side or server-side validation), provide suggestions for fixing the input in a timely and accessible manner. 3.3.4 Error Prevention (Legal, Financial, Data) (Level AA) If the user can change or delete legal, financial, or test data, the changes/deletions are reversible, verified, or confirmed. 3.3.5 Help (Level AAA) Provide instructions and cues in context to help in form completion and submission. 3.3.6 Error Prevention (All) (Level AAA) If the user can submit information, the submission is reversible, verified, or confirmed. Robust Content can be used reliably by a wide variety of user agents, including assistive technologies Guideline 4.1 Compatible: Maximize compatibility with current and future user agents, including assistive technologies Success Criteria Recommendations 4.1.1 Parsing (Level A) Significant HTML/XHTML validation/parsing errors are avoided. 4.1.2 Name, Role, Value (Level A) Markup is used in a way that facilitates accessibility. This includes following the HTML/XHTML specifications and using forms, form labels, frame titles, etc. appropriately. 27 Appendix C Procurement Accessible Guidelines – Development on a request for tender (RTF) sample text were proposed to the Procurement Office below, under three main headings, in-line with good practice and guidelines produced by the National Disability Authority: --------------------------------------------------------------------------------------------1. Development process: Design and implementation should be carried out in accordance with an inclusive, usercentred process, based on Universal Design principles. Tenders should outline the main features of this process, such as: • How user requirements including the specific needs of people with disabilities will be gathered and used. • How user needs will be identified and taken into account. • Methods of consultation with users, including people with disabilities or their representatives. 2. Quality assurance of the product or service Prior to delivery of the <procured item> should be tested or otherwise evaluated for usability and accessibility as part of the quality assurance process. Tenders should outline the main evaluation methods to been used, such as: • Accessibility audit carried out by an accessibility expert - Please state the credentials of the expert who will carry out the audit. • User testing by representative users, including users with disabilities - Please describe the test environment, procedures and user group characteristics. 28 3. Training of product or service The successful tenderer will be required to provide any training necessary to enable staff to maintain the accessibility of the product and its information content. If any such training is necessary, tenders should include proposals and plans for this training. --------------------------------------------------------------------------------------------------- Further text was provided for any introductory text: The increasing use of technology presents remarkable opportunities for all people; however information technology presents new accessibility challenges to those who have sensory, mobility, learning, and other disabilities. To ensure a product or service is compliant with both Trinity and national tendering policy the procurement must fulfil the following criteria at the tendering stage: • Be technically accessible, in that it is possible for all users to access all information and functionality; • Be equally usable and universal in design, in that it is not prohibitively difficult or time consuming for users with disabilities to carry out normal tasks; • Be capable were applicable of being adapted or configured by individual users to meet their specific needs and preferences; • Be capable were applicable of interfacing with appropriate, widely available assistive technologies employed by users 29