Re: [External] Re: [Protocols] Minutes for March 4th, 2022

Juanita wrote:

> I believe an objective observer can determine whether someone’s met most
standards – including descriptive alt text. There’s currently plenty of
guidance published by the W3C that demonstrates what that means.
Plain/clear language can also be similarly defined and assessed. There will
always be edge cases, but an objective observer can make a determination.

Hi Juanita,

The three key terms in your statement above are (at least to me) *defined*,
*assessed* and *determination*.

   - A protocol provides the *definition*, and provides guidance on *how to
   assess*.
   (Using your example of alt text, the EO alt-text decision tree fits the
   broader definition of a protocol here)

   - A *determination* however is a *subjective response*. It is never
   binary, it is always 'opinion' - but now (hopefully) opinion informed by
   the definition and guidance provided in the protocol


   - The goal of a protocol then is to provide sufficient definition and
   assessment guidance so that "an objective observer" (or rather multiple
   objective observers) can all generally agree that the needs are being met.
   Like alt text, the experts need not agree on the specific choice of
   language, they just have to agree that the alt text meets the overall need.
      - In the compliance realm, the public assertion that *"Our company is
      using the XYZ protocol"* is the potential "risk point" should they
      fail to do what they claim they are doing they are exposed to legal risk
      (again, W3C/WCAG does not define compliance, they establish conformance
      levels).
      - In the legislative/judicial arena, the Judge assumes the role of
      "objective observer" - and the Protocol is his/her "roadmap"


You also stated:

> I feel like this would undo a lot of good work that’s taking place to
hold organizations accountable if we try to make this a compliance standard
or alternative to actually meeting the requirements.

Protocols (at least as I have envisioned them) do not replace standards, **they
augment them**.

(Actually, to go all pedantic - as I often do - Protocols would augment
Normative Requirements: "Success Criteria" in WCAG 2.x parlance, "Outcomes"
in WCAG 3. "Standard" isn't actually a formal term we use at the W3C, we
use "Recommendation" [which is used as a synonym for Standard], which is a
collection of Normative Requirements. But I digress...)

Looking at WCAG 2.1, SC 1.1.1, the current 'standard'
(requirement/normative text) is for "*All non-text content that is
presented to the user has a text alternative that serves the equivalent
purpose, except for the situations listed below...*"

However, if we are to be honest, we did a lousy job of defining "*serves
the equivalent purpose*" (in fact we normatively did not define what that
means), and so today a content author *could* seriously and accurately
provide *alt="automobile"* and it would (one could argue) serve the
equivalent purpose. From a pure-play 'compliance' perspective, the standard
asks for a text alternative, and one has been provided. However,
*subjectively* most experts will state that the text alternative, while
meeting the absolute minimum bar, is not good enough.

A Protocol however (and here let's pretend that the alt-text decision tree
is a protocol) seeks to help evaluators and regulators arrive at a "shared"
understanding of what *we* mean by equivalent (and "good enough"), as it
walks the content author through a series of questions that helps drive to
a better text alternative. Again, two different content creators could
start with the same image and still arrive at completely different text
alternatives, but by walking the 'tree' we (I would hope) would stand a far
greater chance that whatever alt text they wrote would be closer to *our*
(expert) understanding (and expectation) of what makes a sufficient text
alternative.

> It also would make someone “compliant” if they show they’re trying to
implement processes – which I feel is just going to result in lower
accessibility across the board.

There has been much discussion (elsewhere) over the terms 'compliant' and
'conformant'. Please do not quote me, but I believe overall the
working group are arriving at "You comply to laws, you conform to
standards" (ref: Gregg Vanderheiden), and so it would be up to the
legislators to define compliance (based on our conformance model).

But still (and more importantly), Protocols will augment the normative
standards, and if/when adopted would (the current argument goes) improve
the overall accessibility because the entity is publicly claiming to meet
not only the minimum standard, but are (again publicly committed to)
seeking to go beyond the minimum conformance by also adopting "protocols"
(guidance on how to do it right!).

I struggle to see how that would result in lower accessibility.

Respectfully,

JF

On Fri, Mar 4, 2022 at 2:07 PM Jaunita George <
jaunita_george@navyfederal.org> wrote:

> Hi again,
>
>
>
> I wish we had something like EN 301 549 for the private sector. If this
> goes above and beyond current standards, I’m fine with that – but if it’s
> used to meet a standard, then we really need to make the standards that
> this would apply to extremely narrow. I believe an objective observer can
> determine whether someone’s met most standards – including descriptive alt
> text. There’s currently plenty of guidance published by the W3C that
> demonstrates what that means. Plain/clear language can also be similarly
> defined and assessed. There will always be edge cases, but an objective
> observer can make a determination. If a new standard doesn’t meet that
> level of specificity, maybe we need to take that back to the drawing board
> and define what we mean.
>
>
>
> We want to encourage trying – but not at the expense of people, if we can
> help it.
>
>
>
>
>
> *Jaunita George, JD, PMP, WAS (she/her)*
>
> *QA-ADA Analyst III, **Product Engineering & Delivery Services (ISD)*
>
> *DHS Certified Trusted Tester (TTV5)*
>
> [image: IAAP WAS circular badge and horizontal name logo for International
> Association of Accessibility Professionals (IAAP) Web Accessibility
> Specialist (WAS) credential. To the left is a dark blue circle with three
> lines of centered white text that read: IAAP Certified WAS. There is a
> smaller light blue circle that surrounds the dark blue inner circle that
> designates the WAS credential color scheme. To the right, two lines of dark
> blue text. Top text reads Web Accessibility Specialist, second line reads
> International Association of Accessibility Professionals.]
> <https://www.accessibilityassociation.org/s/wascertification>
>
> Navy Federal Credit Union, 820 Follin Lane, Vienna VA 22180
>
> W: 571-391-0356 | C: 206-778-1882
>
>
>
> [image: Navy Federal Credit Union. Our members are the mission.]
>
>
>
> *From:* jake abma <jake.abma@gmail.com>
> *Sent:* Friday, March 4, 2022 2:00 PM
> *To:* Jaunita George <jaunita_george@navyfederal.org>
> *Cc:* Bradley-Montgomery, Rachael <rmontgomery@loc.gov>;
> public-silver@w3.org; w3c-wai-gl@w3.org
> *Subject:* Re: [External] Re: [Protocols] Minutes for March 4th, 2022
>
>
>
> Hey Jaunita,
>
>
>
> Please also see this page (translate into English):
> https://www.digitoegankelijk.nl/wetgeving/wat-verplicht
> <https://secure-web.cisco.com/1c6E3vauBLOEXXTYGEVscPrIiBOtrOPhXTANQ9PsFh_qj1nnou_0ZEy8S96qbzcs07-4QiG12hZfRjPxm8viUeCk_AH_RMwQP2HQL-KxxfH2ex5aePx2oVCOJoH1q-N-BPzkBdgS51J9KhBc3OiIG9WtXaD_fWU4SRwo4MVgRVTIiVufaPysY-6S3FBPDRhvIahbaj5-8UeVLNDpkaM0P4fU3P1oEzx6qvRVArpwagCfjKf5r8L2WLS8CMAdiM-zeKrRhqGkTFZh30JLRGtnCjp6tJD3RxjwxjadAueUZNHrJSbLMv_J-ClDw_JUb7m1bP94jhxDnUG9jX_wl_WyzRI1Vsqvwk8E9r98_ANJlJ40_XcONAStpnGiFI-BXXOI1Uv7jJrxzxMBNuwEK7n_vrn1RTiSNkaFnFSoYfc1oXfsFWI9jyOkwBgqJd9RN6yCiXpBinWvOaR7E_6RPZsdPZg/https%3A%2F%2Fwww.digitoegankelijk.nl%2Fwetgeving%2Fwat-verplicht>
>
>
>
> *Requirements*
>
>
>
> *Nr1.* requirement: Make websites more accessible based on the
> requirements of chapter 9 of the European standard EN 301 549. These
> requirements are identical to accessibility standard WCAG 2.1, level A + AA.
>
>
>
> *Nr2. *Publish an accessibility statement.
>
>
>
> *Nr3.* Continuing to work on either staying or fully complying with the
> accessibility statement.
>
>
>
> So, if not 100% compliant yet (as probably 99% of all websites worldwide)
> you MUST prove your path towards this goal.
>
> It has already been proven for thousands of sites and apps that this
> approach works better because there is a reward / grow factor build in
> (indeed a "maturity / change your processes / apply and use protocol like
> documentation)
>
>
>
> Cheers!
>
>
>
> Op vr 4 mrt. 2022 om 19:36 schreef Jaunita George <
> jaunita_george@navyfederal.org>:
>
> Hi all,
>
>
>
> I’m a little concerned with having this be something that could be used to
> meet standards.
>
>
>
> I feel like this would undo a lot of good work that’s taking place to hold
> organizations accountable if we try to make this a compliance standard or
> alternative to actually meeting the requirements. It also would make
> someone “compliant” if they show they’re trying to implement processes –
> which I feel is just going to result in lower accessibility across the
> board. Organizations everywhere have wonderful accessibility statements,
> but inaccessible products – and I think this could continue that worrying
> trend and lead to accessibility in name only.
>
>
>
> If we go this route, then we should just make it part of the maturity
> model and not tie it to standards compliance. It’s important if
> organizations try, but far more important if they achieve results and
> results should always be easily measurable.
>
>
>
> *Jaunita George, JD, PMP, WAS (she/her)*
>
> *QA-ADA Analyst III, **Product Engineering & Delivery Services (ISD)*
>
> *DHS Certified Trusted Tester (TTV5)*
>
> [image: IAAP WAS circular badge and horizontal name logo for International
> Association of Accessibility Professionals (IAAP) Web Accessibility
> Specialist (WAS) credential. To the left is a dark blue circle with three
> lines of centered white text that read: IAAP Certified WAS. There is a
> smaller light blue circle that surrounds the dark blue inner circle that
> designates the WAS credential color scheme. To the right, two lines of dark
> blue text. Top text reads Web Accessibility Specialist, second line reads
> International Association of Accessibility Professionals.]
> <https://secure-web.cisco.com/1xhp5ColvYuE1A7CsdZBcZ8SDTZNpgBYtPUyWMmVGp-HxIyReeCXP0MU6LT0louwRZoHqEUJxUDN-BnIsCNjKNIbJnbwQqisAqDgzJbuVzM43d-JFOQRggMV92dqyizpySN4pAaSkwKkHU-U0nxOIeQqy3PQRqVTvNXbYW_m1k7GCuoJ9lR0FZ6cfxD0kFzvx6RxXjgZalKd2ILi5nDtEmbrl75n-ZFKHpxS9Iy9ZI80fkMsx7gSUd-ZIGpsTqX5b3PHQq1r3tVcCIIlaC15A4GpL-X51_TiTrI1D4QCLwEf96-14OA2X-3VT1sm7g5Kjq2q5L6GyIvHm0rZfogerArmp6qlddbHkZzDcsN6pWuNlN3uZqyVfitVxxWj8i7PUBss0O1n9wVlVIArDTmGbyiV9Y5GHafDEqV6WMTYoQmEKT7ZZAQkYHq3-WFV9SfY2gy6Wybt4qmh0TVlrmsctLw/https%3A%2F%2Fwww.accessibilityassociation.org%2Fs%2Fwascertification>
>
> Navy Federal Credit Union, 820 Follin Lane, Vienna VA 22180
>
> W: 571-391-0356 | C: 206-778-1882
>
>
>
> [image: Navy Federal Credit Union. Our members are the mission.]
>
>
>
> *From:* jake abma <jake.abma@gmail.com>
> *Sent:* Friday, March 4, 2022 1:28 PM
> *To:* Bradley-Montgomery, Rachael <rmontgomery@loc.gov>
> *Cc:* public-silver@w3.org; w3c-wai-gl@w3.org
> *Subject:* [External] Re: [Protocols] Minutes for March 4th, 2022
>
>
>
> Please note the approach from Dutch government as mailed before, this was
> mentioned / used as a proposed starting point for "Possible ways to
> evaluate whether a protocol was done" derived from
> https://www.digitoegankelijk.nl/toegankelijkheidsverklaring/over-de-verklaring
> <https://secure-web.cisco.com/1bksw5hQXg9PYfUbtvrgUY0SeOxLJv2nVMRihu-4saz5ni8i0lcbUxbIx0qNe8zBLb__wriTFKMLyuVqvLwApBhCQ9K32hl0ct9yhLY2QFTReg-EjOBmimAuLYz9dBcM1qDLPIS11ZZEs8styO8bv8lciyhSRm9BasIzTJHzuJX_C2KgnLBTDMLD0D3WEd6RmXp3O_vCC_yoBeR_Q9g8GZPZFnXs5vgqSzDFWtIUsL1VU_ugA1wYqzbxsMsPz8rhgtD0Hn6szzml9SkCV8Gyz4b4xaQtdbT0RjRQXxZHngT5lHIb-zOFi6-tSU51R87DVcGdsMhzECW6zIhM4FMC8SdjbqRWqwqrKBgxPOzA2NwUT8YrV61Y7cetZ7Jega9rdoVRTl5fTHHcTJX-oMyA4nQ_mrABs78UMEsVrDEzpK4Yo0skZSyqRJngKEqsAXrwepPEc8zV9N8w4nf6pNXNzNA/https%3A%2F%2Fwww.digitoegankelijk.nl%2Ftoegankelijkheidsverklaring%2Fover-de-verklaring>
>
>
>
> *1. Previously (before 2020): ONLY 100% PASS / FAIL Compliancy Approach - *there
> were only two statuses (WCAG driven)
>
>
>
> *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
>
>
>
> Op vr 4 mrt. 2022 om 16:11 schreef Bradley-Montgomery, Rachael <
> rmontgomery@loc.gov>:
>
> The minutes from the protocols subgroup
> <https://www.w3.org/2022/03/04-wcag3-protocols-minutes.html> are
> available.
>
>
>
> Summary:
>
>    - We will be going through an exercise for  the next few weeks to
>    evaluate:
>
>
>    - How to evaluate whether the protocol was done
>       - How well the protocol was followed
>       - How to evaluate the quality of the results (if possible)
>
>
>    - We will be using the following (possible) protocols as examples to
>    help with discussion:
>
>
>    - Plain Language, Visma UX, (BBC Gel A11y section if 3rd is needed)
>
>
>    - Possible ways to evaluate whether a protocol was done (Discussion
>    still ongoing)
>
>
>    - Require the organization to publicly state:
>
>
>    - What protocol/part of protocol was done
>          - How the protocol was embedded in content or organization?
>          - How can the public see that the protocol was embedded?
>          - Date statement was made
>
>
>    - Key questions that need to be addressed later:
>
>
>    - Definition of a protocol?
>       - Is a protocol a document or part of a document?
>       - How will we handle overlap with WCAG? The overlap will shift
>
>
>
> *From: *Chuck Adams <charles.adams@oracle.com>
> *Date: *Wednesday, March 2, 2022 at 1:42 PM
> *To: *"public-silver@w3.org" <public-silver@w3.org>, "w3c-wai-gl@w3.org" <
> w3c-wai-gl@w3.org>
> *Subject: *[Protocols] Agenda for March 4th, 2022
> *Resent-From: *<w3c-wai-gl@w3.org>
> *Resent-Date: *Wednesday, March 2, 2022 at 1:41 PM
>
>
>
> 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://secure-web.cisco.com/1bBc-AeZLPPKOVvCExG0BbLyFYdagfVfi6hAuN7_FBdtZXh4Z-IDZQa11Uz5jnHurh-zQnEXFrU1PHmx0R7fK6XS-HoQLHIWyNdJXfTdBtc14_avFRLdaUczIaPPxQyTTNzok7P6cZuwwAP92oRfXqTX6DMFj_gnxyw6oMipmRtghaY8xXKoXcpIljDpqUy4soN38I3MvWyC5xosKGPRIJkKj3Js3DqWUeeq07_t5qtzGldc6Floe03VjydOTmwFybDeD-aw2EmyVKpI4A1kwGxDKgP3V1-_qZP1oxDokd0CrOKKRVZxN42-LOfekXZdm4uRmT1CRtyybc4sGJzRh7su1wxhrGnLgHAJr0AldhNVBQKloDmO9AOGHvxNAcRhTU0Ei4UB3aqXuz39egwtE0QxBpUuYchFWMZ45TAYabiOOBrAzZJFK6ib45TM0gi96JHEEoxvmuI7CV9EOno3gyQ/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.w3.org%2Fevents%2Fmeetings%2Fbfc72cd9-fdfc-4847-826a-01afb9e3f5e7%2F20211105T090000__%3B%21%21ACWV5N9M2RV99hQ%21ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34yacGIQO4g%24>
>
> We will be on IRC using the W3C server at https://irc.w3.org
> <https://secure-web.cisco.com/1rI9UW3alosWZho6nVCm-E_dZkJ0BlrVmIyuglWkoUjfWBgRWm6nN35lmjZjFKf-INfhP42jq-fWcgnZi4RUDVZyTd_xV9MBOBw49_JX1_pme_MDZBZhjydUT4RaZ6RhKo0spYxpnqM39mlm1Lf_CG5Iu0Z9m9zjglM_9EkIVHROMeoDmfyAoOBMdLQRgmaYZ8IY_XcLmdZq4RO5Inf1p92eduUVe8o3W2peMTIyf-LVHNx3lugwhx5nr5v6d6gwGPBHRnntIKr1-FEnDe6A6OXihyqBL_vKW_vnHsF6e8sw-cLeuFeoZDWi7zaa5-jmzMTx3WcNZ_HZlwI2s6wh68dVVnRiVDH39gAi9MfLyJnYS7w9apy0GMFDaO9OHmJR0lTpKchQAqiUBvEj-mYvNwPpsMqsEU2IJFsprPrTeO2HSyb3JpM4ETuPgGnOxpzFjcFo2Lwo99TWCkAQDBMISHg/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Firc.w3.org%2F__%3B%21%21ACWV5N9M2RV99hQ%21ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34ybOl3ZsYw%24>,
> 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://secure-web.cisco.com/1tjim_fOcxm_qDZXrWClV8REdYA-GUtSZbZl_fRtKIrUFR4njzqvyNYSuAc7Xt_z9cn5ms3Sjt80esOl0OKBBv0TXcn8KiNRzh1hRVN1_SUm2gAYvqsZRug-VWDmK9K_UdFhBk1M6LXyskr-8fKqgelQVFptVtkudhNLxizoUUtmhcEQcQJVHmE11FQSn1eUiy1ioZ__ISn5ZXS7eK4HK2twbyRpxCrsizjlg9l24mGO9WRpi6ku0TJgOU5hMfwZE_bWRRevB7sZoeCoEacO8oje3QzDpoHtjX0mDZs0-9qd7aTJL3eNpmIgHu1w0dysTvGbfBLY2tufQdmh2EgSEmt_nGS2DzGikOxxSJlSJqPsePi4-ngHgiVZfj-qZuAIaBVT11nYM70RJrUhEts5Xfk9C_96nnhG_Ic-lgRU3mVmcBZ0OULXfHqr0qJrd3pNwnkJm25EaJUz0DcCM-c9wFA/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.w3.org%2FWAI%2FGL%2Ftask-forces%2Fsilver%2Fwiki%2FProtocols__%3B%21%21ACWV5N9M2RV99hQ%21ZvVx1wh89EAXhBiorHpgvdpQRlEtQPxaEsJbJ7_Q3MrxtnQGs5lwbIC34ya-s3KL6w%24>
>
> *** 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"