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Re: [Protocols] Agenda for March 4th, 2022

From: jake abma <jake.abma@gmail.com>
Date: Fri, 4 Mar 2022 09:15:27 +0100
Message-ID: <CAMpCG4Gz810W8s1nBr73zh=7ToCmQoRm6_aJ+hSM2qV440LUOQ@mail.gmail.com>
To: John Foliot <john@foliot.ca>
Cc: Chuck Adams <charles.adams@oracle.com>, "public-silver@w3.org" <public-silver@w3.org>, "w3c-wai-gl@w3.org" <w3c-wai-gl@w3.org>
see specifically: (where 'the training of employees' can also be the
training of following protocols, or cultivating whatever protocol chosen,
in order to 'grow' in creating accessible products)

(The results are => step-by-step rewarding, rewarding, rewarding, for
people, for teams, for organization so they become, and stay, enthusiastic
for a long time!)

Content of the statement

The statement states to what extent the website or app meets the
accessibility requirements and *what measures the authority is taking* to
further improve accessibility, including planning. *This can concern, for
example, the training of employees*, taking technical measures, but also
the periodic testing of the website. In addition, it must be explained how
inaccessible content can be reported, and how the organization handles
this. Finally, there are also specific situations and exceptions. If you
believe that an exception applies, you must state this in the accessibility


Op vr 4 mrt. 2022 om 09:04 schreef jake abma <jake.abma@gmail.com>:

> Agreed with John, and as I've mentioned before (October / November)
> the approach suggested by John is very similar to how you fill in the
> accessibility statement for all public sector websites and apps in The
> Netherlands...
> Specifically the "Claim:" and "Steps Taken to Implement this Protocol:"
> match the statements maturity claims.
> Have provided information before but for the ones who didn't receive it,
> here again:
> (please translate the pages in English, they are in Dutch...)
> *Accessibility Statement*
> https://www.digitoegankelijk.nl/toegankelijkheidsverklaring
> https://www.toegankelijkheidsverklaring.nl/
> *About the statement* (accessibility requirements *AND WHAT MEASURES HAVE
> https://www.digitoegankelijk.nl/toegankelijkheidsverklaring/over-de-verklaring
>    - Fixed form of statement
>    - Signing by responsible officer or director
>    - Substantiation of the statement
>    - WCAG-EM, ACT RUles, EARL, WCAG 2.1
>    - *Compliance status in the statement !!!****
> *Compliance status in the statement !!!****
> *1. Previously: ONLY PASS / FAIL Approach - *there were only two statuses
> *2. Present Day: *The current approach has *FIVE* compliance statuses !!!
> A: Fully Compliant
> B: Partially compliant (= in control statement)
>               "agency has appointed concrete improvement measures READ:
> C: First measures taken
>               "Agency has taken concrete improvement measures to get that
> D: Doesn't meet
>              " Legal obligation prescribes agencies take the necessary
> measures
>               Agency is urged to appoint concrete measures within a
> certain period of time, including planning. READ: *ASSERTION* / FOLLOWING
> E: No accessibility statement published
> *Control Steps by Digital government Ministry of Internal Affairs *(WCAG-EM,
> WCAG, Techniques, EARL, *Check of measures taken*)
> https://www.digitoegankelijk.nl/toegankelijkheidsverklaring/controle-door-logius
> ==>> !!! If your measure is following a protocol, that is fine and
> acceptable, as long as its goal is to increase accessibility / compliance.
> You need to have evaluation proof of applying the protocol though if asked
> for!!!
> *Central register WITH THOUSANDS of statements*
> https://www.toegankelijkheidsverklaring.nl/register
> Cheers!
> Op do 3 mrt. 2022 om 20:07 schreef John Foliot <john@foliot.ca>:
>> Hi Chuck and team,
>> As I slowly resurface, I wanted to note that I am personally struggling
>> with this approach. Apologies in advance for the longish response, but as I
>> am unable to participate in any other way at this time, I wanted to get my
>> thoughts out there.
>> One of the goals of 'Protocols' (in my mind) was to incorporate user
>> needs into our spec that cannot be 'evaluated' to true or false, because
>> fundamentally the answers would always be subjective. Per your agenda
>> recommendation, let's look at plainlanguage.gov (which is an example I
>> have always thought of as meeting the broad definition of 'Protocol')
>> As I read that document, I note the following under the Guideline heading
>> of "Write for your audience"
>> <https://www.plainlanguage.gov/guidelines/audience/>, where it
>> explicitly states,
>> "*Use language your audience understands and feels comfortable with.
>> Take your audience’s current level of knowledge into account. Don’t write
>> for an 8th-grade class if your audience is composed of PhD candidates,
>> small business owners, working parents, or immigrants. Only write for 8th
>> graders if your audience is, in fact, an 8th-grade class.*"
>> Now, using just that statement, let's apply it to your request:
>> Propose a way to evaluate (pass/fail):
>> i.      Whether the protocol was done
>> ii.      How well the protocol was followed
>> iii.      The quality of the results
>> To answer the first bullet point, "Whether the protocol was done" first
>> requires that a third-party evaluator knows who the audience is, and what
>> their knowledge and reading-skills are. It is unclear to me today how a
>> third-party evaluator could truthfully know the answer to that question -
>> there may be times when it is more obvious (a treatise on Nuclear Physics
>> is likely not targeted to 8th Graders), but what for example is the
>> intended reading level of wikipedia? Facebook or twitter? The W3C website,
>> or educational institutions or government agencies? Banking and Insurance
>> sites? Why, and says who? What of sites like https://www.hhs.gov, which
>> has content targeted to both the broader population (especially in the
>> context of COVID information), but also content intended for a very
>> specific and highly educated audience (doctors) that requires a specialized
>> level of skill and experience? The applicability of "Plain Language" there
>> will vary from page-to-page based on topic and intended audience, but how
>> would that be evaluated or reported more broadly?
>> But let's say that somehow the site owner explicitly claims that their
>> entire site has been authored to a Grade 8 Reading level.
>> Putting aside the fact that COGA has consistently asserted that Reading
>> Levels (Flesch–Kincaid, FOG/Gunning index, etc.) do not solve their needs,
>> which (if any) of those existing test mechanisms is the right one to
>> evaluate whether the content has been authored to the appropriate reading
>> level? Does the use of multi-syllabic words (one of the things that will
>> increase the reading level in Flesch–Kincaid) truly make a document harder
>> to read? Additionally, Flesch–Kincaid is exclusively intended for English -
>> it does not work on, say, French or Spanish content, never-mind languages
>> such as Hebrew (R-to-L reading order), or any of the CJK languages
>> (Chinese/Japanese/Korean), so what tools or mechanisms would be used to
>> address internationalization issues?
>> Next, measuring "How well the protocol was followed", which is another
>> subjective determination.
>> Given that the Guideline requirement is "*Use language your audience
>> understands and feels comfortable with." - *that again is impossible
>> to measure. For example, the statement *"9 out of 10 users can
>> understand this sentence"* would likely be very comfortable for a
>> typical Grade 8 student, but if that student is impacted by dyscalculia
>> issues, that sentence would probably be extremely uncomfortable for them,
>> due to the use of numbers. Changing "9" to "nine" may help some of those
>> users, but not all (if I am to fully understand the impact of dyscalculia
>> <https://www.dyscalculia.org>on individual users). Measuring comfort is
>> subjective and individual in nature, and it cannot be scaled in any way
>> that I can think of.
>> Based on the above, I would then have to fundamentally question bullet 3
>> "The quality of the results", simply because my reading comfort level will
>> be different than yours, or potentially anyone else reading this email.
>> Earlier, one of the key points that I thought the group had agreed-to (Jan.
>> 7th
>> <https://www.w3.org/WAI/GL/task-forces/silver/wiki/Protocols#7_January_2022>)
>> was that Protocols measured inputs, not outputs - which was (I felt) close
>> enough. The goal there would be to look for evidence (I continue to propose
>> formal assertions) that a protocol has been consulted and applied as
>> intended.
>> Plainlanguage.gov Guidelines in-and-of-themselves cannot be measured for
>> successful outcomes, as those outcomes are too varied and too contextual.
>> But documented evidence that the protocol is being consistently referenced
>> as content is being authored, or that the editorial staff have been trained
>> and apply the principles of Plain Language in their day-to-day activities,
>> are all indicators that when content is being written, it is being written
>> with informed guidance applied. It does not claim perfect, nor even
>> close-to-perfect, but it does claim "informed and earnestly applied", which
>> I will assert, is about as good as we can get.
>> Thus the reason why I have always linked 'Assertions' to the larger
>> 'Protocols' discussion: when an entity makes a public statement, especially
>> one that is related to a highly regulated topic (like accessibility/human
>> rights considerations) there is an inherent level of risk: if you say it,
>> you better be able to prove it in court.
>> And so for the conformance piece, I continually suggest that publicly
>> available conformance statements related to protocols used or applied,
>> coupled with the (legal) risk of failing to live up to your public
>> assertion, would be the mechanism for determining successful application
>> (i.e. Input, not output). It involves a level of trust - but I will also
>> assert no more or less trust than expecting that text alternatives are
>> accurate and useful (another subjective determination that will never be
>> able to be measured in a consistent and meaningful way). Broadly speaking
>> however, most experts could (I suggest) recognize whenever a protocol was
>> NOT applied, and so I thus conclude sites won't be making claims they
>> cannot back up in court.
>> Specific to Plainlanguage.gov (and the US Federal requirement to use
>> plain language), this is essentially the approach the US is taking today.
>> From the Law and requirements <https://www.plainlanguage.gov/law/>
>> section of that site:
>> *"By October 13, 2011, agencies must: ... Write annual compliance reports
>> and post these reports on its plain language web page."*That is the
>> accountability piece, and the model I continue to propose for all Protocols.
>> What would an assertion look like in WCAG 3? I believe that is an
>> important part of the larger discussion which we've not yet discussed.
>> Working completely off the top of my head however, I could envision
>> something like the following (this is all straw-man, and will need to be
>> refined if the idea is accepted):
>> ********************
>> Protocol:
>>    - Plain language
>> Reference:
>>    - https://plainlanguage.gov
>> Effective dates:
>>    - This claim is in effect between Jan 1, 2022 - Jan 1, 2023
>>    - (Previous claims can be found at: ___URL___)
>> Claim:
>>    - Content written for this site is authored for users with a Grade 8
>>    reading level or greater.
>>    - Some users may still experience difficulties with some or all of
>>    the content on this site.
>> Steps Taken to Implement this Protocol:
>>    - The principles of plainlanguage.gov have been incorporated into
>>    the XYZ Widget Company's writing guide "The voice of the Consumer".
>>    - Corporate Editorial staff have all taken professional
>>    training/refresh learning exercises within the past 12 months.
>>       - Training provided: The Essentials of Plain Language - a nine
>>       part online training course that covers plain language principles and the
>>       Plain Language Writing Act of 2010. (
>>       https://academy.govloop.com/watch/hDzHyqdB4T7K3fjbvuGk8B)
>>    - Random editorial content is evaluated by the XYZ Widget Company's
>>    Chief Accessibility Officer monthly to verify that the protocol is being
>>    applied correctly.
>> Date of this report:
>>    - January 22, 2022
>> ****************
>> Could this be gamed? Of course it could!
>> Any and all of WCAG - even today - can be gamed by the content owners if
>> that is their goal. I could do a 20 screen, *subjective* analysis of pages
>> from a site today while studiously avoiding a single page with MathML,
>> because I already knew that the MathML on that site was not accessible, so
>> "don't ask, don't tell" ensures my score isn't "too low" because we simply
>> sidestepped the MathML...
>> Additionally today, while not part of WCAG, the Section 508 VPAT
>> templates support the notion of content that "Partially Supports" with
>> regard to WCAG SC, but then leaves defining "partial" to anyone - so gaming
>> the Rec, even today, is very easy to do if that is your intention. While I
>> absolutely believe helping to define conformance is part of our remit, I
>> also strongly believe that enforcing compliance is outside of our
>> deliverable today.
>> JF
>> On Wed, Mar 2, 2022 at 1:41 PM Chuck Adams <charles.adams@oracle.com>
>> wrote:
>>> Hi All,
>>> The Protocols Subgroup will meet again this Friday, March 4th at 9:00 AM
>>> Boston Time (1400 UTC).
>>> The Zoom teleconference data is provided at this link:
>>> https://www.w3.org/events/meetings/bfc72cd9-fdfc-4847-826a-01afb9e3f5e7/20211105T090000
>>> <https://urldefense.com/v3/__https:/www.w3.org/events/meetings/bfc72cd9-fdfc-4847-826a-01afb9e3f5e7/20211105T090000__;!!ACWV5N9M2RV99hQ!ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34yacGIQO4g$>
>>> We will be on IRC using the W3C server at https://irc.w3.org
>>> <https://urldefense.com/v3/__https:/irc.w3.org/__;!!ACWV5N9M2RV99hQ!ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34ybOl3ZsYw$>,
>>> in channel *#wcag3-protocols*
>>> These and additional details of our work, including minutes, current,
>>> and archived draft documents are available on our subgroup wiki page here:
>>> https://www.w3.org/WAI/GL/task-forces/silver/wiki/Protocols
>>> <https://urldefense.com/v3/__https:/www.w3.org/WAI/GL/task-forces/silver/wiki/Protocols__;!!ACWV5N9M2RV99hQ!ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34ya-s3KL6w$>
>>> *** Agenda ***
>>> agenda+ Develop a way for a lay-person to assess whether a protocol was
>>> followed
>>>    1. Pick 2-3 things that are likely protocols (Plainlanguage.gov, BBC
>>>       style guidelines, ?)
>>>       2. Propose a way to evaluate (pass/fail):
>>>                                                                i.      Whether
>>> the protocol was done
>>>                                                              ii.      How
>>> well the protocol was followed
>>>                                                            iii.      The
>>> quality of the results
>>> Regards,
>>> Charles Adams
>> --
>> *John Foliot* |
>> Senior Industry Specialist, Digital Accessibility |
>> W3C Accessibility Standards Contributor |
>> "I made this so long because I did not have time to make it shorter." -
>> Pascal "links go places, buttons do things"
Received on Friday, 4 March 2022 08:15:55 UTC

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