Re: German Translation WCAG 2.1 - Disapproval

Hello.

On 29 Apr 2022, at 14:17, zimmermann@accesstechnologiesgroup.com wrote:

> Dear W3C,
>
> this is a note regarding the proposed German translation of WCAG 2.1 
> at
> <https://outline-rocks.github.io/wcag/translations/CAT-WCAG21-DE-20211004/>
> https://outline-rocks.github.io/wcag/translations/CAT-WCAG21-DE-20211004/.
>
> We, the undersigning members of the committee "Principles of 
> Accessibility"
> of the German standards institute DIN, hereby disapprove the proposed 
> German
> translation for the following reasons:
>
> 1. Our input sent to the German translation team on 17th July 2021 was
> ignored. It contained about 200 comments included in a translation 
> table
> (see attachments).

The translation proposal was taken under consideration. We did review 
and check all differences to the English translation. Many of the 
translations in the attached documents were inaccurate of interpretative 
of the source material. Indeed we did not ignore it but worked through 
it multiple days, adopting some of the comments, and leaving others 
which we did not felt were an accurate translation.

The translation as attached also apparently abided to non-W3C writing 
standards of documents, because of the environment it was created in. 
This lead at times to harder to understand sentences and 
reinterpretations of SCs that are more restrictive/allow for less 
interpretation than the original.

After reviewing the translation and proposing our translation that is 
much more aligned to the original intent of WCAG as well as to the 
existing practical use of WCAG 2, we asked for further feedback before 
initiating the official review period with W3C.

> 2. The German translation only affected the changes from WCAG 2.0 to
> WCAG 2.1 while obvious translation problems of the German WCAG 2.0
> translation were not touched.

As we have outlined in the process several times: Re-interpreting and 
re-translating wide swaths of WCAG 2.0 after this amount of years will 
be damaging to the resources, learned phrasing, and existing books on 
the topic. We are happy to add comments, but felt very strongly that it 
would be better to wait for introducing different language as part of 
future standards, especially WCAG 3.

 From the many, many positive and approving comments on the translation, 
this is a welcome sentiment. I understand the desire to fix WCAG in the 
German translation, but some of the suggestions from the PDFs would 
re-interpret WCAG and actually harm harmonization with the English 
original.

> 3. The translation team ignored several opportunities to harmonize the
> WCAG 2.1 translation with the German translation of EN 301 549 v3.2.1, 
> and
> vise versa. Both documents are strongly related to each other and a
> consistent wording would be highly appreciated and most beneficial for 
> the
> community. The draft DIN EN 301 549 was out for public comments for 3 
> month
> in summer 2021. It is going to be published in May 2022.  Note: In EN 
> 301
> 549, the WCAG 2.1 success criteria are incorporated as chapter 9.

The first published draft of the WCAG 2.1 translation was [published in 
April 2021](https://github.com/outline-rocks/wcag#readme), there was no 
outreach regarding harmonization from people or organizations involved 
in the EN translation apart from sending PDF documents in a 
take-it-or-leave-it fashion.

In addition, the translation to us was never provided as a complete HTML 
document that would be useful to work with. The translation was also not 
provided to us under an open license.

Surely for W3C, a consensus-based translation, which we have 
demonstrated here by the many approving messages, is more important than 
a unilateral translation.

I do understand the need and desire for harmonization between the German 
translation of WCAG 2.1 and the translation of the EN 301 549, and 
we’re happy for the translators of the EN to adopt to the authorized 
translation once approved.

We are also happy for DIN to provide their translation as a Candidate 
Authorized Translation, go through the process of an authorized 
translation, including working in all the comments from stakeholders, 
and have their translation approved, if they so desire. When setting up 
this effort, there was discussion around that, but it was clear that 
there would be little point in one entity 
defending/explaining/collecting feedback on another entity’s 
translation.

Hence the provided Candidate Authorized Translation, which translates 
WCAG 2.1 to the best of our conscience, while keeping harmonization with 
the existing WCAG 2.0 translation in tact and being true to the English 
original.

It would be detrimental to the adoption of WCAG and accessibility in 
Germany if the publication of an open, re-usable, open licensed, and 
multi-stakeholder approved translation was hampered.

I personally do not want two different versions of the translation of 
WCAG 2.1 around, but considering that they both claim to be faithful 
translations of WCAG 2.1 (and one of them has demonstrated so by wide 
support through a multi-stakeholder process), they should be compatible. 
On the other hand, I feel that having no publicly-available version of 
WCAG 2.1 in an open format (ENs are only published through PDF and 
paper) is also no good outcome.

I’ll check-in with my colleagues here as part of the W3C-approved 
translators and see what our next steps are.

Yours respectfully,
Eric Eggert

> Background:
>
> * The DIN committee on accessibility is responsible for the German
> translation of EN 301 549.  Our proposed translation for WCAG 2.1 
> resulted
> from this work.
> * Please find attached our about 200 comments which we provided to the
> translation team last year. The only changes in the documents are the
> insertion of comment numbers, which we added for better referencing.
>
>
>
> Best regards,
>
> * Klaus-Peter Wegge, Siemens Accessibility Competence Center
> * Constanze Weiland, Siemens Accessibility Competence Center
> * Thorsten Katzmann, IBM Germany
> * Friederike Saxe, DIN
> * Gottfried Zimmermann, Invited Expert of W3C APA



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