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

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
BEEN TAKEN / READ "**ASSERTION / **PROTOCOLS APPLIED"*)
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:
*ASSERTION* / FOLLOWING PROTOCOLS"
C: First measures taken
              "Agency has taken concrete improvement measures to get that
picture. READ: *ASSERTION* / FOLLOWING PROTOCOLS"
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 PROTOCOLS"
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"
>