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In my last Accessibility Policy Series post, I identified at a high level a four phase approach to establishing accessibility policies in an organization, the accessibility policy documents that must be created, and some existing organizational policies that might need accessibility components added to them.  In this blog, I will look in more detail at the types of policy documents that must be created during the first phase – the Accessibility Policy Development Phase.  These include the:

  • Accessibility Policy
  • Accessibility Statement
  • Accessibility Issue Resolution Plan
  • Gap Analysis
  • Accessibility Compliance Program

Accessibility Policy

The Accessibility Policy is an internal document which describes the standards which the organization intends to meet with respect to accessibility, and any implementation deadlines.  It is also the document from which all technical standards, implementation guidelines, and other internal documents are developed from.  Content for Accessibility Policies can vary widely, depending on policy structure rules for the organization.  Most Accessibility Policies include:

  • The purpose of the policy
  • Definitions of terms used in the policy
  • The scope of the policy
  • The policy statement
  • Contact information for the individual in charge of the policy
  • Any mandatory training resulting from implementation of the policy
  • Policy exceptions
  • Ongoing policy maintenance procedure
  • Policy effective date
  • Signatures of all authorities necessary to implement the policy

Accessibility Statement

The Accessibility Statement should be based on the Accessibility Policy and be publicly available on an organization’s web site.  One good place to locate the Accessibility Statement is in a link in the footer section of the site.  Accessibility Statement content should include:

  • The organization’s general non-discrimination statement
  • A summary of the organization’s level of compliance and standards it is meeting as defined in the Accessibility Policy
  • Means of contacting the organization for filing complaints – at a minimum, this includes:
    • Title of the person resolving complaints (a name is not required)
    • Phone number
    • TTY number
    • E-mail address
    • Optionally, an accessible form for submitting complaints. If this is implemented, the complaint should go directly to the individual handling accessibility complaints and not to the general help desk.

Accessibility Issue Resolution Plan

The Accessibility Issue Resolution Plan is the document that describes in detail how formal accessibility violation complaints are resolved, including initial resolution, and generally, an appeals process.  Accessibility Issue Resolution Plans can cover accessibility complaints filed by employees, the public, or both.  However, employees that are under Collective Bargaining Agreements may have different paths for resolving accessibility complaints with their employers.

Gap Analysis

A Gap Analysis describes a set of specific deviations or patterns of deviations between high risk digital properties owned or controlled by the organization, and the desired behavior identified in the Accessibility Policy.  This helps the organization estimate the Level of Effort necessary to remediate their digital properties to be in full compliance with the Accessibility Policy.  While a Gap Analysis can be performed at any stage of policy development, it is a good idea to look at this as soon as possible for budgeting purposes for later stages.

Accessibility Compliance Program

The Accessibility Compliance Program contains all information regarding monitoring, quality control, and auditing of Accessibility Policy implementation.  The content of this document can vary widely depending on whether the organization:

  • Is doing automated testing only, manual testing, or both
  • Already has a corporate compliance program that the accessibility compliance program will integrate with
  • Is implementing a centralized accessibility program office, or is distributing accessibility responsibilities throughout the organization

Coming Up

In my next post in this series I’ll be discussing the types of Accessibility Plans that must be built during the second phase of accessibility policy/plan establishment – the Accessibility Policy Operationalization Phase.  These plans rely on data established during the Accessibility Policy Development Phase and include the Accessibility Communications Plan and the Accessibility Training Plan.