Re: Task testing structure

In compliance with the standard required by a law does mean that they are
making a WCAG Conformance Claim.

** katie **

*Katie Haritos-Shea*
*Principal ICT Accessibility Architect*


*Senior Product Manager/Compliance/Accessibility **SME*
*, **Core Merchant Framework UX, Clover*


*W3C Advisory Committee Member and Representative for Knowbility *


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On Fri, May 1, 2020 at 1:15 PM Shawn Lauriat <lauriat@google.com> wrote:

> John wrote:
>
>> If we really are moving away from page-level conformance to 'site-level'
>> conformance "score" (no longer just pass/fail), then I assert our spec
>> needs to be very clear with any exclusion criteria, as well as how the
>> conformance is scoped - in the conformance statement itself.
>
>
> I've proposed a model that wouldn't allow exclusion, as it wouldn't have a
> concept of a whole "site-level" to exclude from, just as WCAG today defines
> conformance claims. Would that model work?
>
> Not every site is 'task' or 'interaction' driven - they may also be 100%
>> 'push' content (Joe's Blog, with commenting turned off)
>
>
> The task: read Joe's Blog posts or a specific post. Maybe find out how to
> get in touch with Joe via email. Tasks don't necessarily require
> interactive controls.
>
> Katie wrote:
>
>> Please if you are aware of any government regulations that are requiring
>> WCAG Conformance Claims, I'd love to hear about them.
>
>
> I only know of one off the top of my head, The State of California
> requires "compliance" with WCAG
> <https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180AB434> (at
> about the level of readable as John notes for conformance claims, so I've
> bolded the most applicable bit):
>
> 11546.7. (a) Before July 1, 2019, and before July 1 biennially thereafter,
> the director of each state agency or state entity, as defined in
> subdivision (e) of Section 11546.1, and each chief information officer
> appointed under Section 11546.1, shall post on the home page of the state
> agency’s or state entity’s Internet Web site a signed certification from
> the state agency’s or state entity’s director and chief information officer
> that they have determined that *the Internet Web site is in compliance
> with Sections 7405 and 11135, and the Web Content Accessibility Guidelines
> 2.0, or a subsequent version, published by the Web Accessibility Initiative
> of the World Wide Web Consortium at a minimum Level AA success criteria.*
> (b) The Director of Technology shall create a standard form that each
> state agency’s or state entity’s chief information officer shall use to
> determine whether the state agency’s or state entity’s Internet Web site is
> in compliance with the accessibility standards specified in subdivision (a).
>
>
> -Shawn
>
> On Tue, Apr 28, 2020 at 8:12 PM Katie Haritos-Shea <ryladog@gmail.com>
> wrote:
>
>> I'll just note that there are no regulators that I know of who are using
>> or requiring WCAG Conformance Claims.
>>
>> Please if you are aware of any government regulations that are requiring
>> WCAG Conformance Claims, I'd love to hear about them.
>>
>> On Tue, Apr 28, 2020, 6:12 PM John Foliot <john.foliot@deque.com> wrote:
>>
>>> Shawn writes:
>>>
>>> Potential adapting to:
>>>
>>> Conformance Claims (Optional)
>>> Conformance is defined only for tasks. However, a conformance claim may
>>> be made to cover one task, a series of tasks, or multiple related tasks.
>>>
>>>
>>> I think (if I better understand your concern, John) this should address
>>> the case of someone having their conformance claim imply that it covers all
>>> of example.com or MyAwesomeApp, while only defining and testing a
>>> subset of tasks wiithin that conformance claim?
>>>
>>> Thoughts?
>>>
>>> Well, putting aside the fact that I understand you aren't 'happy' with
>>> the term Task here either... (perhaps "interaction"?) my thoughts are still:
>>>
>>>    - Not every site is 'task' or 'interaction' driven - they may also
>>>    be 100% 'push' content (Joe's Blog, with commenting turned off)
>>>
>>>    - The language still feels kind of slippery - it still lets the
>>>    owner decide what is more critical or important for all end users, but also
>>>    empowers them to exclude some content from some users without even making
>>>    an effort. It's akin to me establishing my own speed limit on the highway
>>>    (which I understand is actually a thing on the Autobans of Germany
>>>    <https://en.wikipedia.org/wiki/Autobahn>). This will benefit
>>>    site-owners at the cost to site users I fear.
>>>
>>>    - If we really are moving away from page-level conformance to
>>>    'site-level' conformance "score" (no longer just pass/fail), then I assert
>>>    our spec needs to be very clear with any exclusion criteria, as well as how
>>>    the conformance is scoped - in the conformance statement itself.
>>>
>>>    - Any "exemption rules" need a real grounding in logic and
>>>    feasibility - it cannot just be because the site owner doesn't think it's
>>>    in scope. (I mean, they can think anything they want, but then there is the
>>>    law...) As I noted on today's call, we're going to need regulators to pick
>>>    up our specification if we *really* want it to be effective (beyond a
>>>    collection of Best Practices), and so we need to ensure we are as
>>>    unambiguous as possible in this regard.
>>>
>>> However Shawn, yes, this is my concern: "*...having their conformance
>>> claim imply that it covers all of example.com <http://example.com/> or
>>> MyAwesomeApp, while only defining and testing a subset of tasks within that
>>> conformance claim?*"
>>>
>>> Part of the problem is that 'conformance statements' are about as dry to
>>> read as click-through EULA's, and most site visitors won't know what is or
>>> isn't in or out of scope. And I cannot think of a more frustrating scenario
>>> for a PwD than to be told that the section of the site *they* want to
>>> access - Chuck's Pizza Game(TM) - is out of scope for the accessibility
>>> conformance thing, so "too bad".
>>>
>>> Additionally, as we transition away from black or white (aka Pass/Fail)
>>> to a more realistic long-tail score (the million shades of gray between
>>> black and white), the scoring *should* allow for partially but not fully
>>> conformant content to exist on the site - but at a cost to the overall
>>> score (i.e. "you're losing points there bud..."). Allowing site owners to
>>> self-exempt will drive up scores, but do little for end users.
>>>
>>> JF
>>>
>>> On Tue, Apr 28, 2020 at 4:32 PM Shawn Lauriat <lauriat@google.com>
>>> wrote:
>>>
>>>> Should the standard be defining coverage? Or would it be better to make
>>>>> the same sort of assumptions as 2.x and leave it to regulators to say
>>>>> whether a site should cover all tasks, or what the sampling is?
>>>>
>>>>
>>>> Exactly, we could instead define conformance scope as purely per-task
>>>> and discard the notion of a collection of tasks as a definition of a
>>>> complete thing. That'd follow the WCAG 2.x per-page model, while allowing
>>>> people to optionally put several together to declare a larger scope, just
>>>> like WCAG 2.x does today. It wouldn't have any aspect of conformance itself
>>>> implying declaration of a full scope of an "entire" thing, but merely a
>>>> collection of small things. To write it out for comparison:
>>>>
>>>> WCAG: 5.3 Conformance Claims (Optional)
>>>> <https://www.w3.org/TR/WCAG21/#conformance-claims>
>>>> Conformance is defined only for Web pages. However, a conformance claim
>>>> may be made to cover one page, a series of pages, or multiple related Web
>>>> pages.
>>>>
>>>>
>>>> Potential adapting to:
>>>>
>>>> Conformance Claims (Optional)
>>>> Conformance is defined only for tasks. However, a conformance claim may
>>>> be made to cover one task, a series of tasks, or multiple related tasks.
>>>>
>>>>
>>>> I think (if I better understand your concern, John) this should address
>>>> the case of someone having their conformance claim imply that it covers all
>>>> of example.com or MyAwesomeApp, while only defining and testing a
>>>> subset of tasks wiithin that conformance claim?
>>>>
>>>> Thoughts?
>>>>
>>>> (Chuck wrote, as I had this drafted:)
>>>>
>>>> Shawn mentioned something in the W3C call that didn't get a lot of
>>>>> attention in call, was some system whereby the author defines the scope,
>>>>> and that scoping exercise (or process or determination) is open to the
>>>>> public (or I forget the words...) fully disclosable?  Discoverable?  He
>>>>> used a word or phrase...
>>>>
>>>>
>>>> "Transparent", which came to mind from the Silver requirement for
>>>> providing broad support to the regulatory environment
>>>> <https://w3c.github.io/silver/requirements/index.html#regulatory-environment>.
>>>> Not necessarily public, but if someone says their thing conforms and then
>>>> needs to show their conformance claim,
>>>>
>>>> -Shawn
>>>>
>>>> P.S. Separately from scope itself, we'll definitely need to work out
>>>> non-interference, what does "task" mean and can we have a better word, etc.
>>>> The agenda item we didn't get to in today's call.
>>>>
>>>> On Tue, Apr 28, 2020 at 4:11 PM Charles Adams <charles.adams@oracle.com>
>>>> wrote:
>>>>
>>>>> Shawn mentioned something in the W3C call that didn't get a lot of
>>>>> attention in call, was some system whereby the author defines the scope,
>>>>> and that scoping exercise (or process or determination) is open to the
>>>>> public (or I forget the words...) fully disclosable?  Discoverable?  He
>>>>> used a word or phrase...
>>>>>
>>>>> I'm going to extend the use case of "Corner Pizza", and the game
>>>>> that's been mentioned.  I'm going to extend it to two games.
>>>>>
>>>>> Game One:  Guess which celebrity most recently visited our shop and
>>>>> get $1 off your pizza order.
>>>>>
>>>>> Game Two:  Web based Pizza Party!  Cook needs to create a series of
>>>>> pizzas correctly as orders speed up.  This web based game exists only to
>>>>> generate traffic, and is not necessary to order a pizza or to utilize any
>>>>> other "Corner Pizza" service.
>>>>>
>>>>> In the case of Game One I think it should be scoped in, as there's a
>>>>> purpose with consumer impact for playing and "winning" the game.
>>>>>
>>>>> If the business case for Game Two was just to attract web traffic to
>>>>> the site, I could see a case for the author wanting to scope that out.  The
>>>>> second game isn't a required step for ordering a pizza or any other
>>>>> service.  The author just wants to attract traffic in the hopes that the
>>>>> players decide to use the accessible ordering app to order something.
>>>>>
>>>>> In the extended use case of "Corner Pizza", I would think that Game
>>>>> One's accessibility SHOULD impact the final score, and I would think that
>>>>> Game Two's accessibility could be argued to be irrelevant to the final
>>>>> score.  I also think that if there was some public facing information which
>>>>> documented that Game Two was scoped out of the score, reviewers would be
>>>>> able to determine that this "scope exclusion" was not intended to abuse any
>>>>> conformance model.  IF the content author also tried to scope out Game One,
>>>>> that could be perceived as an attempt to abuse the conformance model.
>>>>>
>>>>> Regards,
>>>>>
>>>>> Chuck
>>>>>
>>>>>
>>>>> On 4/28/2020 7:42 AM, Alastair Campbell wrote:
>>>>>
>>>>> > I also was under the presumption that we were moving from a
>>>>> "per-page" conformance model to a "site-wide" conformance "score".
>>>>>
>>>>>
>>>>>
>>>>> I’m not sure about that, but I thought there was a move from page to
>>>>> task.
>>>>>
>>>>>
>>>>>
>>>>> Given a move from page to task:
>>>>>
>>>>> Should the standard be defining coverage? Or would it be better to
>>>>> make the same sort of assumptions as 2.x and leave it to regulators to say
>>>>> whether a site should cover all tasks, or what the sampling is?
>>>>>
>>>>> -Alastair
>>>>>
>>>>>
>>>>>
>>>>>
>>>
>>> --
>>> *​John Foliot* | Principal Accessibility Strategist | W3C AC
>>> Representative
>>> Deque Systems - Accessibility for Good
>>> deque.com
>>>
>>>
>>>