Re: [EXTERNAL] Re: question regarding printed PDF documents

I'm still interested while reading through the replies if there is
consensus that a form which cannot be digitally filled out or signed (i.e.
requiring printing of the form) is a legal compliance risk or issue due to
accessibility concerns. (It's obviously a usability concern in my mind).
Has anybody come across this?


On Tue, Jan 16, 2024 at 3:41 PM Deborah Dinzes <Deborah.Dinzes@becu.org>
wrote:

> Thank you for the clarification.
>
>
>
> I was referring to the option within Adobe Acrobat forms to add a
> Signature field. This is what is being suggesting by the Accessibility
> team. To use that field, a signer has to pre-register with Adobe, which is
> a confusing process. Then, if there is a signature field added to the form,
> they can “sign” the form digitally. It’s not an option for us because our
> Legal department won’t accept it.  As a financial institution, we require a
> verifiable signature – one we can compare to the signature on file, or one
> that is validated via DocuSign’s validation process.
>
>
>
> We have been adding all our forms to DocuSign to make our forms accessible
> to more people – not just people with disabilities, but also people who
> find it difficult to come in to a branch office. Print forms clearly don’t
> work for some people.
>
>
>
> The issue was that someone on the Accessibility team, which works with our
> website dev team, was insisting that our PDF forms are out of compliance
> because there’s no field on the signature line, thus necessitating that the
> signer print the form. As our PDF ADA SME, it was my view that we had an
> ADA-compliant solution for members via our eSign option. I didn’t think
> WCAG applied to print documents, but I’m not the expert on that so I wanted
> to confirm with this group.
>
>
>
> It's really helpful to take all these scenarios and concerns in to the
> meeting with Accessibility, Legal and Compliance, so we can all be better
> informed when making a decision.
>
>
>
> Thanks very much!
>
> Deborah
>
>
>
>
>
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>
>
>
> *Deborah Dinzes*
>
> *Sr Technical Writer, Knowledge Management*
>
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> *From:* Guy Hickling <guy.hickling@gmail.com>
> *Sent:* Tuesday, January 16, 2024 2:49 PM
> *To:* WAI Interest Group discussion list <w3c-wai-ig@w3.org>
> *Subject:* [EXTERNAL] Re: question regarding printed PDF documents
>
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>
> Deborah, by my option (1), I meant the simple process of printing out the
> form, then signing the paper form by hand - the method I understand your
> organisation currently uses. Usually after the user has completed the
> fields on screen first (though hand completion is also valid but more prone
> to error later).
>
>
>
> But I wasn't clear when you said "We have the options of adding a
> signature field – I believe users have to set up a signature to use it. I
> found that process confusing, and Legal won’t accept it." Do you mean
> that you allow users to use both methods (digital signing or printing the
> form), but only accept the latter? That seems very strange.
>
>
>
> So to repeat, all methods, whether digital signing or signing a signature
> by hand, all present problems for some disabled people (and also for others
> due to their equipment or their circumstances). They are all inaccessible
> to some people.
>
>
>
> Take your current method of printing off the form before signing. That is
> obviously no good for blind people. It has two issues particularly:
>
> a) printers frequently give problems; they can print a blank page due to
> the ink running out, or they corrupt the text for whatever reason, or print
> out of position due to wrong printer settings so that much of the text
> (including some of the data the user might have entered) is missing off the
> edge of the paper. And it can also happen that some other document was
> stored in the print queue and gets printed off first, so the user signs a
> wrong document entirely. A blind person has no way of knowing if any of
> those happen, and may not have a sighted person available to tell them. And
> b), a blind person cannot see where to sign. The solution you mention of
> allowing the signature to be anywhere on the page solves (b), but doesn't
> solve (a). I imagine a blind person would probably prefer a WCAG compliant
> digital signing, though I've never asked anyone about that.
>
>
>
> But replacing that manual method by digital signing also fails for some
> people as I explained. Offering the user a choice of all the options is the
> best way to be accessible to almost everyone.
>
>
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-- 
Jerra Strong
Web Accessibility Specialist
UNLV|Web & Digital Strategy
Jerra.Strong@unlv.edu
*Pronouns: He/Him/His*