IS YOUR WEBSITE ADA COMPLIANT? STAND APART SCALE SMART GROW BEYOND EMPOWER RELATIONSHIPS

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1 IS YOUR WEBSITE ADA COMPLIANT? STAND APART SCALE SMART GROW BEYOND EMPOWER RELATIONSHIPS

2 QUICK INTRO

3 ANTHONY IANNICIELLO VP, PRODUCT DESIGN

4 WILL RODGERS DIRECTOR OF WEB SERVICES

5 CUNA Mutual Group Risk Management 02/2016 ABA Analysis 09/2016 Legal Letters (3 Waves)

6 Is my site ADA compliant?

7 Yes.

8 THANK YOU FOR JOINING US CONTACT ANTHONY IANNICIELLO VP, PRODUCT DESIGN (512) WILL RODGERS DIRECTOR OF WEB SERVICES (512)

9 Is my site accessible? And if so, what level?

10 What level of ADA compliance does my application meet? We think our goal is to meet WCAG 2.0 level AA. If you don't meet this level of compliance, when do you plan to?

11 Is our application compliant with Section 508? WCAG? Level AA?

12 Probably not.

13 Do we have to be compliant?

14 There is still no official guidance in place from the DOJ as to the practice of Title III of the ADA in regards to Web Information and Services.

15 Will I get sued?

16 Maybe.

17 AGENDA WHAT IS WEB ACCESSIBILITY? ADA AND THE LAW WCAG AND WHAT IT MEANS YOUR OPTIONS

18 WHAT IS WEB ACCESSIBILITY? Web accessibility refers to the inclusive practice of removing barriers that prevent interaction with, or access to websites, by people with disabilities. When sites are correctly designed, developed and edited, all users have equal access to information and functionality. * Between 0.5-2% of American adults require some form of assistive technology to use a website. * Source Wikipedia -

19 think screen readers on MAC turn on VOICE OVER on WINDOWS go to EASE OF USE now tab through the site Most users use JAWS and NVDA

20 ACCESSIBILITY APIS Windows Windows Linux Linux OSX ios Android Introduced in the last 10 yrs MSAA/UIAutomation IAccessible2 AT-SPI NSAccesibility UIAccesibility AccessibilityFramework

21 ACCESSIBILITY APIS Introduced in the last 3 yrs Assistive Technology Browser Operating System Accessibility APIs Accessible Rich Internet Applications

22 ADA AND THE LAW

23 THE ADA Americans with Disabilities Act 1991 ADA created for Title II (state and local government) and Title III (public accommodations) 2010 Amended with specific requirements around ATMs which went into effect in 2012

24 ADA SPECIFIC TO WEBSITES Title II & Title III timelines TITLE II Nondiscrimination on the Basis of Disability: Accessibility of Web Information and Services of State and Local Governments JULY 2010 JULY 2014 APRIL 2016 JULY 2017 ANPRM 1 NPRM 1 SANPRM 1 NPRM 2 TITLE III Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of Public Accommodations JULY 2010??? 2018 ANPRM 1 NPRM 3 1 Office of Information and Regulatory Affairs ( RIN 1190-AA61 & RIN 1190-AA65) 2 DOJ Fall 2016 Statement of Regulatory Priorities ( 3 DOJ Fall 2015 Statement of Regulatory Priorities (

25 THE ADA The deadline Estimated compliance date (2020 for Title II, at least 2020 for Title III) Effective two years from the publication of this rule in final form, a public entity shall ensure that the web sites and web content it makes available to members of the public comply with level A and level AA success criteria and conformance requirements specified in 2008 WCAG 2.0, except for success criterion on live-audio content in synchronized media, 3 unless the public entity can demonstrate that compliance with this section would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens. SANPRM -

26 THE ADA Deadline schmedline A growing number of lawsuit settlements are already happening and the frequency is accelerating.

27 THE ADA The threat In late 2016 multiple waves of threatening letters from a law firm in Pennsylvania were sent to financial institutions, seeking a quick private settlement.

28 Legal Letters (3 Waves) March 2017

29

30

31 The ADA Compliance As of today settlements reached between providers and the DOJ have conditioned acceptance upon compliance with WCAG 2.0 Level AA success criteria. (and that means everything)

32 THE WCAG AND WHAT IT MEANS

33 WCAG? WCAG = Web Content Accessibility Guidelines Developed by a private consortium of experts called the Worldwide Web Consortium (W3C), and is the website access standard in all U.S. Department of Justice (DOJ) settlement agreements. W3.org/WAI/WCAG20/quickref

34 The most recent set of guidelines (WCAG 2.0) were published in 2008 and are organized under 4 central principles with testable "success criteria": Perceivable, Operable, Understandable, & Robust. Each principle offers 3 levels of conformance: A, AA, and AAA.

35 WHAT ARE THE WCAG 2.0 GUIDELINES? They fall under four central principles 1. PERCEIVABLE 2. OPERABLE 3. UNDERSTANDABLE 4. ROBUST Perceivable to text readers by embedding text into each visual feature on the website. Maneuverable without the use of a mouse (i.e., keyboard only). Easily understandable and predictable. Robust in compatibility with various tools used by disabled consumers to access website content.

36 1.1 TEXT ALTERNATIVES: provide alternatives for non-text content (e.g., images) so that it can be accessed by impaired individuals 1.2 TIME-BASED MEDIA: make it easy for authors to quickly determine which success criteria apply to their content, the type of media each success criterion applies to is included in its short name 1.3 ADAPTABLE: create content that can be presented in different ways without losing information or structure 1.4 DISTINGUISHABLE: Make it easy for users to see and hear content, including separating foreground and background, by using readable fonts, larger font sizes, and highlighted link styling for example 2.1 KEYBOARD ACCESSIBLE: Make all functionality available from a keyboard without requiring specific timings 2.2 TIMING: Provide enough time for users to read and use content 2.3 Seizures: Do not design content in a way that is known to cause seizures 2.4 NAVIGABLE: Provide multiple ways to allow users to navigate content including obvious/prominent links and other techniques 3.1 READABLE: Make text content readable and understandable via styling and other techniques 3.2 PREDICTABLE: Make web pages appear and operate in predictable ways 3.3 INPUT ASSISTANCE: Assist users with web experience, correct mistakes and describe errors in text 4.1 COMPATIBLE: Maximize compatibility with current and future user agents, including assistive technologies

37 1.1 TEXT ALTERNATIVES: provide alternatives for non-text content (e.g., images) so that it can be accessed by impaired individuals 1.2 TIME-BASED MEDIA: make it easy for authors to quickly determine which success criteria apply to their content, the type of media each success criterion applies to is included in its short name 1.3 ADAPTABLE: create content that can be presented in different ways without losing information or structure 1.4 DISTINGUISHABLE: Make it easy for users to see and hear content, including separating foreground and background, by using readable fonts, larger font sizes, and highlighted link styling for example 2.1 KEYBOARD ACCESSIBLE: Make all functionality available from a keyboard without requiring specific timings 2.2 TIMING: Provide enough time for users to read and use content 2.3 Seizures: Do not design content in a way that is known to cause seizures 2.4 NAVIGABLE: Provide multiple ways to allow users to navigate content including obvious/prominent links and other techniques 3.1 READABLE: Make text content readable and understandable via styling and other techniques 3.2 PREDICTABLE: Make web pages appear and operate in predictable ways 3.3 INPUT ASSISTANCE: Assist users with web experience, correct mistakes and describe errors in text 4.1 COMPATIBLE: Maximize compatibility with current and future user agents, including assistive technologies

38 THE WCAG Video Compliance According to WCAG 2.0 AA all video must have captions for people with hearing disabilities AND audio descriptions for people with visual disabilities.

39 YOUR OPTIONS

40 You should reach out to your 3 rd party vendors and understand their plan to make their web based applications conform to WCAG 2.0 AA. YOUR OPTIONS Third-Party Compliance

41 THIRD PARTIES Jobscore Google search results Mortgagebot Account opening Locations Jobscore Mortgagebot

42 YOUR MARKETING WEBSITE You have a choice Sit and wait for the regulations to be updated in ~2018 with compliance due in ~2020 and hope a threatening letter doesn't come your way Make your website accessible quickly to avoid a letter

43 WAIT. A BUDGET? What it takes time to make a website accessible Modern websites are complex. Accessibility takes work. Work takes time. Your site will need additional code and, probably, visual design. Making your current site accessible may not be more cost effective than a redesign.

44 WEB ACCESSIBILITY Three possible compromises COST COMPROMISE WEBSITE MANAGABILITY COMPROMISE USER-EXPERIENCE COMPROMISE

45 BUT FIRST WHAT IS A PAYPHONE?

46 PAYPHONE ACCESSIBILITY Accessibility in a nutshell The owners of this property were required to provide a payphone that was accessible to those in wheelchairs. They could also have provided a payphone for those without physical needs, but were not required to do so by law.

47 UPKEEP You re compliant, but Once your site fully conforms to WCAG it can easily begin to have non-conforming items as you continue to make changes to the site

48 ONE MORE THING You want to be compliant There are hundreds of thousands of business websites in the United States that will be required to be accessible in the next few years, many of which are beginning the process now.

49 WHEN DO YOU PLAN ON BEING COMPLIANT? 59% said they plan on starting within the next 12 months 3% 2% 59% 36% Within 12 months More than 12 months Already compliant Unsure

50 QUESTIONS?

51 THANK YOU FOR JOINING US CONTACT ANTHONY IANNICIELLO VP, PRODUCT DESIGN (512) WILL RODGERS DIRECTOR OF WEB SERVICES (512)

52 FOR MORE INFORMATION UNDERSTAND TESTING TOOLS LEARNING Web Content Accessibility Guidelines (WCAG) U.S. Section 508 of the Rehabilitation Act Free Udacity Web Accessibility course by Google -accessibility--ud891 Inclusive Design at Microsoft axe / axe-cli / FireEyes WAVE Tota11y Lighthouse for progressive web apps ls/lighthouse/ Accessibility tools in Chrome DevTools JZsp5LsOE Google Developers - Web Fundamentals b/fundamentals/accessibility/ A11ycasts =g9qff0blhk&list=plnykxof6rcicwx0c9l VWWVqvHlYJyqw7g WebAIM and its mailing list Web Accessibility Slack

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