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

Thank you for your reply. It is helpful to spell out the many challenges associated with printed PDF forms. 

Our solution has been to provide an ADA compliant electronic method of completing, signing, and submitting forms, via DocuSign. 

The question is, especially given the difficulty of printing, signing, and sending a paper form, is it necessary or even possible to make this approach ADA compliant? The question was raised by someone on the ADA Compliance team that the printed forms had to be printed and signed and that is not compliant with WCAG rules. I couldn't find any WCAG rules around this, as it's my understanding that this applies to digital/website experiences, and I wanted to confirm this understanding with this community. 

Most of our members prefer the electronic method of completing and signing forms, regardless of disability. It's faster, safer, and cheaper than printing and sending a document. Some people, however, prefer printing forms, so we provide this method as well. We are attempting to make this experience ADA compliant by conforming to WCAG rules for PDF forms. The problem, as you note, is in signing them. Legal won't accept a PDF signature device because it's not verifiable, but this means people are stuck with the barriers you outline. 

If there's no WCAG or ADA requirement to make the print PDF experience itself compliant when we provide an alternative compliant method of completing a task digitally, which doesn't require any software other than a web browser, then it sounds like we have met the requirements. 

I was being told there was a WCAG requirement to make the print form compliant, but as you note, there are many obstacles with print forms for people with disabilities, not just the challenge of physically signing a document. It seems the best way to achieve parity is by providing a compliant alternative. 

If you have time, I would appreciate your thoughts on this approach. 

Thank you very much,
Deborah



Deborah Dinzes
Sr Technical Writer, Knowledge Management
Offsite |  m (425) 443-9524
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-----Original Message-----
From: Karen Lewellen <klewellen@shellworld.net> 
Sent: Monday, January 15, 2024 3:35 PM
To: Deborah Dinzes <Deborah.Dinzes@becu.org>
Cc: w3c-wai-ig@w3.org
Subject: [EXTERNAL] Re: question regarding printed PDF documents

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Hi Deborah,
Thank you for the opportunity your question presents.
Speaking personally, it creates a fine moment to underscore a few critical factors.
First, as many remind us often wcag are guidelines and standards, the laws which  include not only the ada, but human rights laws in jurisdictions include  elements that, would not likely? be incorporated in standards if that resonates.
I have no idea what state you are operating in, or if your organization falls  under federal mandate only.
Still, I invite you to remember the role equality, the ability to access goods & services equal to others plays in those laws.
Let's therefore explore all the barriers your process might present to any number  of populations living with a disability experience.
to your mind it is the simple process of printing signing and returning this file.
That requires a computer that can be controlled, by voice if paraplegic, by programs that modify presentation if experiencing a learning or reading related challenge.  That computer must likewise have access to adobe software  to print your file.  Recently adobe has made changes to their software, many older editions no longer work.
Next there must be a printer, that can produce a legally acceptable copy of this form, which must be read to even locate the place for a signature.
What does that mean if again you are managing by voice, cannot hold a pen, cannot locate a signature line without the presence of someone who does not live with said comparative disability.
You have likely  now added the need..for someone sighted, or with fully functional hands who must be found to complete this task.
And I have not even started on the  process of getting this form back to your office.
Speaking profoundly personally the often automatic assumption, no matter how  intended, that living with a disability experience means that you
will have   uniformly someone else able to work around such common
barriers is frankly reprehensible.
Again, its a bias born of many factors and stereotypes, but in short it says.
you live with a disability experience, therefore someone must be taking
care   of you.
Someone exists to read for you, sign for you or facilitate your signing, manage documents for you, use your computers in place of you etc.
is  the issue more clear?
Are you going to find a wcag or ada  rule that says  creating a process that  automatically requires a person living with any number of
disabilities   to find someone not  living with the same disabilities to
complete the task is discriminatory?  Perhaps not, but common sense and respect of human dignity says you should.
Does that help?
Kare


On Mon, 15 Jan 2024, Deborah Dinzes wrote:

> Hello,
>
> We have a question regarding printing PDF documents. We currently publish PDF forms, which people can download and fill out electronically. They then have to print the form, sign it, and send it to us (or fax it or scan and email it). They have the option of completing the form electronically in DocuSign, electronically signing the document, and submitting it electronically.
>
> It's been asserted that printing the form and signing it makes it inherently inaccessible to some users. Our credit union requires us to meet the WCAG 2.0 standard for our website, and as our PDFs are published there, we are making sure they are also WCAG - compliant. Is there anything in WCAG that states that printing and signing a PDF document is a violation of WCAG or ADA requirements?
>
> The signature area on the PDF is currently blank - no form field, just a box to sign in - because we cannot accept digital PDF signatures as they are not verified. We currently add expansion text to the "Signature" label that reads out loud: "Borrower's Signature. Please print, sign, and submit this form by email, fax, or mail."  This contact information is provided on the form.
>
> Thank you for your advice.
>
> Deborah Dinzes
>
>
> <https://becu.org/>
>
> Deborah Dinzes
> Sr Technical Writer, Knowledge Management Offsite | Our 
> vision<https://becu1.sharepoint.com/sites/km/SitePages/_KM-at-BECU.aspx> is a BECU community empowered with the information they need, when they need it.
>
>
> Please consider the environment before printing this email.
>
>
>
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Received on Tuesday, 16 January 2024 18:00:00 UTC