RE: 1.3.4, autocomplete and esignatures

Whenever there’s an accessibility-supported metadata arrangement available so that the semantics of form field purposes can be decoupled from the HTML5 autocomplete feature, this won’t be a problem. I agree, however, that there’s at least an interesting legal and policy question in the meantime and acknowledge James’s point.

From: James Nurthen [mailto:james.nurthen@oracle.com]
Sent: Friday, January 19, 2018 12:57 PM
To: w3c-wai-gl@w3.org
Subject: Re: 1.3.4, autocomplete and esignatures




On 1/19/2018 8:22 AM, Andrew Kirkpatrick wrote:
James,
I wouldn’t think that a drawn signature would need a “name” value, but if the prompt is “Indicate that you accept this contract by typing your name” then it seems that there is reasonable room for confusion, but I think that that too is being used as a “signature” rather than a name, so believe that we can clarify this in the understanding document.
Maybe we can. The purpose is a signature not the user's name (for example). This definitely needs pointing out as an example were autocomplete MUST NOT be used in the understanding document so there is no confusion by those reading the guidelines.

The definition below was actually taken from an Adobe document which gives an overview of the US law - https://acrobat.adobe.com/content/dam/doc-cloud/en/pdfs/dc_esignatures_us_overview_ue.pdf<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Facrobat.adobe.com%2Fcontent%2Fdam%2Fdoc-cloud%2Fen%2Fpdfs%2Fdc_esignatures_us_overview_ue.pdf&data=02%7C01%7Cjjwhite%40ets.org%7C32a65df788d041e6c52f08d55f662fa1%7C0ba6e9b760b34fae92f37e6ddd9e9b65%7C0%7C1%7C636519814843966056&sdata=js%2BRP9ZMWXrdzfVzDUx%2B1jzlJuByH4FdYC2O6r1fK%2FA%3D&reserved=0>


You can see what the Adobe Sign process is by looking at this: https://www.adobesigndemo.com/en/demo/send<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.proofpoint.com%2Fv2%2Furl%3Fu%3Dhttps-3A__www.adobesigndemo.com_en_demo_send%26d%3DDwMGaQ%26c%3DRoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE%26r%3DCIHu8rc_0wRTTC_7DvWtiGNKjpA-3oTgbu_6ve6hP0I%26m%3DYotSMKppd9ZfQccpICwuPI-IY3X1HIKZfvxl257mt6M%26s%3DWhJ8z77I7KaLAnyIztzL3zImbdouxLY_J3xWruowGp4%26e%3D&data=02%7C01%7Cjjwhite%40ets.org%7C32a65df788d041e6c52f08d55f662fa1%7C0ba6e9b760b34fae92f37e6ddd9e9b65%7C0%7C0%7C636519814843966056&sdata=TxPpcnaNfewRJQWWRH7Ny48n5bPLSwSh%2BFNX%2FDF7m4g%3D&reserved=0>
That may be the Adobe process but the law allows different things. If the user typing their name is used as an esignature this must not have autocomplete on it or it could fail the intent to sign provision.


Thanks,
AWK

Andrew Kirkpatrick
Group Product Manager, Accessibility
Adobe

akirkpat@adobe.com<mailto:akirkpat@adobe.com>
http://twitter.com/awkawk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Ftwitter.com%2Fawkawk&data=02%7C01%7Cjjwhite%40ets.org%7C32a65df788d041e6c52f08d55f662fa1%7C0ba6e9b760b34fae92f37e6ddd9e9b65%7C0%7C0%7C636519814843966056&sdata=KE%2BYebiLk%2BpbudSnwv0V8beeRwl8TsLFNUQ5xT9IbNo%3D&reserved=0>

From: James Nurthen <james.nurthen@oracle.com><mailto:james.nurthen@oracle.com>
Date: Friday, January 19, 2018 at 11:05
To: WCAG <w3c-wai-gl@w3.org><mailto:w3c-wai-gl@w3.org>
Subject: 1.3.4, autocomplete and esignatures
Resent-From: WCAG <w3c-wai-gl@w3.org><mailto:w3c-wai-gl@w3.org>
Resent-Date: Friday, January 19, 2018 at 11:04

I’m concerned that the current 1.3.4 could interfere with esignatures.
One of the requirements is:
Intent to sign.
Just as with a handwritten signature, a signer must show clear intention to electronically sign an agreement. is is usually an easy requirement to satisfy. For example, signers can show intention by using a mouse to draw their signature, typing their name or clicking a button clearly labeled “I Accept” or something similar.

Use of autocomplete on a name field would mean that we could not be sure that the user intended to sign. I think we need a “unless cannot be done due to regulatory requirements” statement.

Regards,
James

--
Regards, James

James Nurthen | Accessibility Architect
Phone: +1 650 506 6781<tel:+1%20650%20506%206781> | Mobile: +1 415 987 1918<tel:+1%20415%20987%201918> | Video: james.nurthen@oracle.com<sip:james.nurthen@oracle.com>
Oracle Corporate Architecture
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