Web Accessibility

Information Technology Policy 1210, Revision 1
State of Kansas Web Accessibility Requirements

1.0 TITLE: State of Kansas Web Accessibility Requirements

1.1 EFFECTIVE DATE: October 26, 2000

Revised: October 26, 2006

1.2 TYPE OF ACTION: Update

2.0 PURPOSE: To establish a State of Kansas policy regarding accessibility requirements for all web based services, applications, and information available on state internet/intranet/extranet servers, including services that are developed internally, developed via contract, provided by third parties on behalf of state organizations, or purchased products.

3.0 ORGANIZATIONS AFFECTED: All branches, boards, commissions, divisions, departments and agencies of the state, hereafter referred to as Entities.

4.0 REFERENCES:

4.1 K.S.A. 44-1001, et. seq. Kansas Acts Against Discrimination.

4.2 Americans with Disabilities Act, 42 U.S.C.A., Section 12101, et.seq. See also 28CFR 35.160.

4.3 TTILE IV - REHABILITATION ACT AMENDMENTS OF 1998 SECTION 508: ELECTRONIC AND INFORMATION TECHNOLOGY (http://www.usdoj.gov/crt/508/508law.html)

4.4 United State Architectural and Transportation Barriers Compliance Board’s Electronic and Information Technology Access Advisory Committee Final Report (http://www.access-board.gov/sec508/commrept/eitaacrpt.htm)

4.5 World Wide Web Consortium's (W3C) Web Content Accessibility Guidelines (http://www.w3.org/TR/WAI-WEBCONTENT/)

4.6 K.S.A. 1998 Supp. 75-7203 authorizes the ITEC to: Adopt information resource policies and procedures and provide direction and coordination for the application of the state's information technology resources for all state entities.

4.6 State of Kansas Web Content Accessibility Guidelines Implementation Guidance (http://da.ks.gov/itec/WASGuidelines.htm)

5.0 DEFINITIONS:

5.1 Kansas State Government: The executive, judicial, and legislative branches of State government.

5.2 Internet: The global network of servers or server computers, based on the Transmission Control Protocol/Internet Protocol (TCP/IP).

5.3 World Wide Web: A subset of the Internet – a collection of interlinked documents that work together using a specific Internet protocol called Hypertext Transfer Protocol (HTTP).

5.4 Intranet: A TCP/IP network belonging to an organization, that can be accessed only by the organization’s members, employees, or others with authorization from such organization.

5.5 Extranet: An intranet that can be accessed only to authorized users outside the formal boundaries of the organization, such as business partners or key stakeholders.

5.6 World Wide Web Consortium (W3C): An international consortium of private and public organizations whose purpose is to develop vendor-neutral, open standards for the World Wide Web.

5.7 Section 508: 1998 Amendment to the Rehabilitation Act requiring that Federal agencies to make their electronic and information technology accessible to people with disabilities.

5.8 ITEC: Information Technology Executive Council, duties defined in K. S. A. 1998 Supp. 75-7202, 75-7203. (http://da.ks.gov/itec/).

5.9 Web Implementer: Any individual responsible for the design, development and maintenance of the state websites, web services, or web applications.

5.10 WAI: The W3C Web Accessibility Initiative – Written as the guidance document for compliance with the 1990 American’s with Disabilities Act amendment requiring equal access to technology for people with disabilities.

5.11 ITAB – Information Technology Advisory Board (http://da.ks.gov/itab).

5.12 WAS – The Web Accessibility Sub-Committee (http://www.da.ks.gov/itab/was) Includes information about validation tools, training, and other relevant resources.

5.13 Financial or Administrative Undue Burden: Is a significant difficulty or expense. In determining whether an action would result in a financial or administrative undue burden, an entity shall consider all entity resources available for use in the funding and operation of the program or component for which the web site, web application, or web service is being developed, procured, maintained, or used. Also see K.S.A. §58-1301b and 28 CFR 35.164.

5.14 Best Practices: Refers to those practices that are compliant with the guidelines outlined in Section 7.1 and have been demonstrated as most efficient/effective in implementing web pages, applications and services.

6.0 POLICY:

6.1 All web-based information and services provided on Inter/Intra/Extranet sites by or on behalf of Kansas State Government organizations (as defined in Section 3.0) shall be accessible and usable in accordance with federal and state law.

7.0 PROCEDURES:

7.1 All web applications and web based services provided by entities covered under this policy as described in Section 6.0 must , at a minimum, comply with the W3C Web Accessibility Initiative, Web Content Accessibility Guidelines 1.0 (http://www.w3.org/TR/WCAG10) Priority 1 and 2 Checkpoints; and Federal Section 508 Guidelines, Subpart B - 1194.22 Web-based intranet and internet information and applications. (http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Web)

7.2 A report on the accessibility status of State of Kansas websites will be provided by the State ADA Coordinator with input from the WAS subcommittee. It will be distributed annually to the ITEC and copies sent to the individual entities.

7.3 Entities and web implementers should incorporate the use of accessibility tools (see 7.3.1) and best practices as part of the development process and require their use and compliance with this policy as part of contracting for development services or services provided on behalf of the State by third parties. These include but are not limited to:

7.3.1 Utilization of some type of accessibility and validation/compliance tool is recommended for all state web content and services. Examples are available on the WAS website.

7.3.2 Testing with various adaptive technologies is recommended for all state web content and services. Examples are available on the WAS website.

7.3.3 Verification of the web implementer’s skills and knowledge of how to apply WAI and Federal Section 508 Guidelines. A list of recommended skills and knowledge is available on the WAS website. If the web implementer needs training, a list of available training resources are available on the WAS website.

7.3.4 Web sites and web applications should be developed to be platform independent where feasible. If there are platform dependencies, entities should develop procedures and processes to evaluate the technical needs of their user audience and the proposed target platforms and adjust development practices as needed.

7.4 As of completion of the 18-month rollout period of the State of Kansas guidelines in March 2002, state organizations are prohibited from deploying web pages, applications or services that do not comply with these guidelines. In cases where a page, application, or service cannot be made compliant as required and without an undue burden, an exception may be obtained. The request for an exception shall be in writing and state the reason(s) that compliance will create a financial or administrative undue burden. The exception should be obtained in advance of deployment. The procedure for obtaining an Undue Burden exception follows:

7.4.1 The documentation required in 7.4.2 – 7.4.5 shall be submitted to and approved by the State ADA Coordinator prior to the deployment of any web-based information or service that does not meet the standards outlined in Section 7.1. In cases where an agency receives notice that an existing page or application is deficient, such documentation should be submitted to the State ADA Coordinator within 30 days from the date the compliance problem becomes known.

7.4.2 Entities will provide an electronic version of the document (or, in the case of more complex applications, appropriate documentation as requested) for which a temporary Undue Burden exception is requested, to the State ADA Coordinator.

7.4.3 Entities shall describe in detail the challenges faced in making this document, collection of documents, or application accessible, including an estimate of hard and soft costs that would be incurred in doing so.

7.4.4 Entities shall describe their short term and long term solution for making this document or documents accessible.

7.4.5 Entities shall submit a timeline in which the document(s) or applications will be made accessible, and provide progress updates as requested by the State ADA Coordinator.

7.5 Unresolved issues or complaints regarding the accessibility of state web sites or web services, whether identified within the organization or on the annual report, should be brought to the attention of the State ADA Coordinator.

8.0 RESPONSIBILITIES:

8.1 Heads of entities are responsible to establish procedures for their organizations to comply with the requirements of this policy.

8.2 The Information Technology Advisory Board (ITAB) will, via the WAS, review this policy annually; to insure both its currency and compliance with emerging regulations and standards.

8.3 Heads of entities are responsible for developing a process of handling and processing accessibility complaints. (See Section 7.5)

8.4 Heads of entities are responsible for submitting, in writing,exception requests for undue burden (see Section 7.4)

9.0 CANCELLATION: Replaces ITEC Policy #1210 titled, "Web Accessibility Requirements".