Kathy Keller is a fierce advocate of disability rights. She has worked on accessibility issues in the public, non-profit and private sectors.
She was the Accessibility Coordinator at the Department of Family and Protective Services. Kathy is a “policy wonk” now, but began her career in accessibility in 2001 as a web developer/web administrator at Texas Parks and Wildlife. For 3 years, she was the Accessibility and Disability Rights Coordinator for the Texas Governor’s Committee on People with Disabilities, and served as a commissioner on the Austin Mayor’s Committee for People with Disabilities.
We are pleased to have a chance to discuss the practical implementation of accessibility in an organization with Kathy.
Breaking down the accessibility policy journey
Editor: Kathy, How to implement accessibility in a large organization is a big topic, how would you break it down?
Kathy Keller: There are a number of components, because it is a big topic. A good place to start is getting support from leadership–getting executive sponsorship.
Next, you must find someone to lead the project–an accessibility lead or accessibility coordinator. To keep executives involved and available throughout the project, the accessibility coordinator should form a steering committee that consists of key executives with authority and budgetary access.
When your coordinator is in place and you have support from executive leadership for this program, the coordinator can begin to identify people in different departments with some knowledge of accessibility, and form an accessibility workgroup. Department managers can help identify key players to act as department liaisons in the workgroup.
I’m a big proponent of workgroups because when you have people from different departments coming together on a regular basis, they bring the knowledge from their area, as well as awareness of the issues or challenges that staff are experiencing. Identifying the problems is a necessary component of accessibility implementation.
And so those workgroup meetings are where it all happens. That’s the kind of data that an accessibility coordinator will gather and bring to a steering committee or executive leadership to let them know where the pain points are, where the agency or organization needs support for the program.
The accessibility coordinator, with help from executives and workgroups, must assess where the organization currently stands before creating the roadmap to implement accessibility.
Editor: How do you go about getting executive sponsorship for accessibility?
Kathy Keller: Sometimes something triggers the interest in accessibility, such as a letter from the Department of Justice or a new staff member or student with disabilities having trouble with inaccessible content and requesting an accommodation. Perhaps accessibility is part of a wider disability, equity, and inclusion (DEI) initiative.
Once an interest is triggered, someone is given the responsibility for looking into the specific issue. As they learn about accessibility and the complexity of the issues involved with it, that can drive a need to identify someone to develop and coordinate an accessibility program.
Often the webmaster or web manager is assigned the task of making online content accessible, and they frequently become the first accessibility coordinator in an organization.
The accessibility coordinator role
Editor: So you end up with a non-experienced person who has to lead accessibility initiatives in an organization. What would you tell that person about how to grow into the role of being an accessibility coordinator?
Kathy Keller: If an organization has a newly appointed accessibility coordinator that steps into the role, the next steps have a lot to do with what skillset the coordinator brings to the table.
Frequently, someone who is employed under another job is appointed as the accessibility coordinator. They may not have the skills that they need so, it’s important that they start on a learning journey right away. If someone comes in with some web accessibility experience or experience with accessible communications, that can be helpful in making a quick start.
I’m happy to say there’s a lot of information online now about digital accessibility. So, when you Google “What is accessibility?” and “How do we incorporate accessibility at our organization?” you’re going to find a lot of information.
Some of it will refer to the Web Content Accessibility Guidelines, or WCAG. That is the standard we use to build accessible content and test content for accessibility. Web Content Accessibility Guidelines are international standards.
When you start investigating accessibility, you realize there is a technical component. Then you realize you need to know more about people with disabilities and how they access information. There’s also a legal component. You need to understand the laws relating to accessibility and how to interpret those laws.
Another step to take might be to download tools and start testing things and doing assessments. If you do that without some basic knowledge of accessibility principles, you may have difficulty understanding the results or how to use them.
This is where you might consider identifying or developing a training program that offers staff a broad knowledge of accessibility principles and techniques. A good training program works alongside the governance structure you’ve implemented, and creates a strong foundation for an accessibility program.
Training, policy, and governance
Editor: And the training program is a great place to start. What are some components of a training program? I assume there’s both a policy and technology component.
Kathy Keller: You need some understanding of disabilities and how people with disabilities use assistive technology to access information. You need to know how to make accessible web content such as web pages, applications, documents and multimedia.
It helps to have some technical background and understanding of programming languages, because the web is dynamic and interactive. So, you would want some training in accessible application development.
You need to know how to assess software for accessibility before you buy it. If you’re buying things that aren’t accessible, then you’re going to have issues achieving accessibility goals. Buying inaccessible products creates a tremendous remediation burden. Sometimes making a purchased product accessible is not an option.
Understanding purchasing processes is important. Asking a vendor for a Voluntary Product Accessibility Template (VPAT) so that you can see how the vendor has assessed their product for accessibility is important. Most people in purchasing have never heard of that so that’s going to be new information for them.
Some background in communications, such as social media can be very helpful. There are lots of other types of communication besides just the website. An accessibility coordinator needs a bag of tricks with a lot of different information. If you don’t have it, you can learn it and grow your skills.
Editor: I would guess an accessibility coordinator also needs to understand policy and governance.
Kathy Keller: Yes, you absolutely do need that understanding to develop an accessibility policy and internal governance structure that supports an accessibility program. And policy and governance information online is not necessarily user-friendly. Because there are multiple laws related to accessibility, the information can be difficult to untangle. But it is a critical component of the job as accessibility coordinator to get comfortable with the rules and be able to help others in the organization understand how those rules impact business day to day.
In Texas, we have the Texas Administrative Code, specifically TAC 206 and TAC 213, that helps us understand how we are expected to implement accessibility. As you become familiar with it over time, it becomes easier to understand and to write an accessibility policy that works well for your organization.
Editor: It’s actually an area we have other interviews coming up. So, we can definitely dig into that deeper. How often does an accessibility coordinator work with legal matters and work with general counsel?
Kathy Keller: In my experience, it has been rare, honestly. I worked for Texas state agencies for most of my accessibility experience. There was very little interaction with legal. I encouraged representation from the legal department on the workgroup, but most often legal counsel was just too busy. When there were legal issues around accessibility, such as vendor compliance, then legal would become involved if it was necessary to resolve the issue.
Editor: Interesting, I would’ve thought differently. That’s eye-opening for me.
The role of a steering committee
Editor: So now you have an accessibility coordinator on board, hopefully, one with experience or one trained up, and they are working to get executive buy-in. Talk about establishing a steering committee. What’s the function of a steering committee, in an accessibility program?
Kathy Keller: A steering committee is made up of executive leadership, generally, people that have authority and have access to a budget. The coordinator is the liaison between the workgroup and all the people in the organization and the executive leadership. The coordinator is going to gather information and bring it to the steering committee to give them a good overview of accessibility compliance for the organization, as well as organizational needs. Do we need to spend money on training and development? Do we need to hire people with accessibility skills? Do we need people in the IT department who can do accessibility testing for other people in the agency, or are we going to try to train everybody to do their own testing? What are we going to do?
There are a lot of questions that must be answered. These are conversations the accessibility coordinator will have with the steering committee, and with their support, will develop and implement a policy and a program to address accessibility compliance.
Developing and implementing an accessibility policy is one of the first steps to drive accessibility in a large organization. The process of developing policy helps you understand the laws and how the organization will address accessibility compliance. How will the organization enforce accessibility? How’s the accessibility policy relate to the organization’s work? What processes and procedures are needed to ensure accessibility compliance? So, you put the policy in place, and then everything else goes from there.
Editor: And I assume the accessibility coordinator typically leads that effort,
Kathy Keller: You know, I would think so, but it’s not always that way. Sometimes the steering committee does it.
Editor: Okay. Fair and the policy establishes governance in the organization and gives the accessibility coordinator authority to deal with accessibility issues.
Kathy Keller: Yes. The policy should do exactly that. It should define the governance structure and significant roles and responsibilities, the role of the steering committee, who’s going to be on the steering committee, the roles and responsibilities of the coordinator. If you’re going to have a workgroup, who’s going to be on the workgroup, what areas are represented, and what are the roles and responsibilities of the workgroup members. All of that should be defined in the policy.
The policy should also define the standards your organization is going to adhere to—in most organizations, that is WCAG 2.0 AA or WCAG 2.1 AA.
There are different kinds of policies. Some policies are a very simple accessibility statement that says that the organization is going to adhere to WCAG 2.1 AA. And it just leaves it at that. All the other components are in other policies and procedures that call out the accessibility policy. That’s one way to do it
Other policies are more complex. They pull all components into the accessibility policy and have it all in one place. Components include purchasing criteria, how to handle non-compliance like exceptions, exception requests, justifications for an exception, those kinds of things.
For someone to put a policy together, you should have some knowledge of accessibility and be able to make valid decisions.
Organizing accessibility policy workgroups
Editor: So we’ve talked about putting a policy together, we’ve talked about the role of the steering committee, the role of the accessibility coordinator. Can you talk about the workgroups a bit? How are the workgroups typically organized? What roles are typically involved in the workgroup? I mean, what departments?
Kathy Keller: In my experience, a successful workgroup has a liaison or representative from most every department. The specific department depends on how the business is organized. Critical departments might include:
- IT department that manages your technology infrastructure.
- The communications department that handles the web and all the outgoing communications for the organization.
- The purchasing department that handles purchasing, and as we have discussed, purchasing accessible technology is critical.
- The training department is critical in helping provide accessibility awareness, policy, and technology training.
You’ll also have departments that are just related to whatever the business of the organization is. You want to have a representative from all these different departments, because each department may implement accessibility differently based on time and resource limitations. A successful accessibility program must take into account the constraints of the organization. A smart accessibility coordinator knows that accessibility is a journey, not a destination. Short-term and long-term planning is key.
Workgroups typically have monthly meetings to discuss how accessibility is being implemented within each department. Problems with implementation and resources needed for implementation are good agenda items for the meetings. You will have conversations about the needs of the staff, like what resources are needed? When a problem is identified, the workgroup researches and develops a solution. Sometimes an outside consultant or trainer is needed, sometimes there is a financial component.
Findings from workgroup meetings are relayed to the steering committee at the steering committee meeting. Generally, workgroups will meet monthly and the steering committee meets quarterly. The steering committee prioritizes the needs and assigns resources.
Dealing with resistance
Editor: For rolling out accessibility in a large organization, how do you deal with resistance to accessibility across the organization?
Kathy Keller: I think it’s important to understand it’s going to be difficult on both sides of the table. A lot of times resistance comes because people are already under pressure, having difficulty just doing the job or getting the job done that they need to do. You’re talking to them about another component that you want them to add to their already busy day, and they may not have much understanding of what that entails.
You are going to be working on accessibility continuously, making improvements all the time. So, it is just a matter of prioritization. You prioritize based on a number of components, such as your budget, your resources, the risk. You make the effort; you make steps every day to get better.
You’re not expected to stop what you’re doing and do something different right now. We’re expecting you to add this to what you’re already doing over time. And let’s just plan for implementation. That was my job as the coordinator, to help people to include accessibility and plan for it. What I found is that if you can identify the low-hanging fruit early in the program, and have some easy success, it really helps to kickstart a program. And it helps people who have anxiety over accessibility to just relax because they see, oh, okay, well, that wasn’t so difficult.
There are tools out there that help you do an overall accessibility assessment of your website, all your web pages and web documents. It’ll give you an assessment of the present state and highlight problem states. Sometimes there can be just an easy fix for some issues.
For example, you can identify content that’s old that nobody is using. Old and inaccessible content is simple to remove. You can archive it, and right away, things are a little bit better. That’s a super simple thing to do and helps build momentum.
Accessibility is an ongoing process
Editor: That’s one of the things we do when we get large remediation projects is go through the content and prioritize it and remove content that’s not being used at all. Focusing resources on content that hasn’t been used for years, it is just too costly.
Kathy Keller: Another thing that can help build momentum is to fix errors that are repeated because of a faulty template. You repair it in one place, and it impacts many pages. When we show people that there are some simple things we can do in the very beginning and make significant progress, it builds momentum.
It is important to realize this is a continuous process. Initially, there may be a few things that are on fire and we have to deal with those right away. After you have addressed the high priority items, you are not done with accessibility. This is a program that you’ll be working on consistently. You’ll always be improving, because technology keeps changing and new content is always being created.
Editor: Well, and that was a question from your comment about this being a journey, how do you make accessibility part of the processes of an organization so that as people and tools change, accessibility keeps being realized.
Kathy Keller: I would say, this is where the workgroup is really important, because the representatives from the different departments know their departments. They know what’s going on in their area. And they’re the ones who will have the most information about where the pain points are so that we can identify where to put accessibility processes in place to deal with those pain points. And it’s processes that keep accessibility going. Because as you know, if accessibility depends on a person that you train, and they’re your expert, and they leave, if you don’t have a process in place, then you end up starting over.
You need representation on the workgroup and ongoing communication to identify where and how to insert accessibility into business processes. When you have this, an accessibility program has a life of its own, and it grows.
Editor: And a process that’s documented.
Kathy Keller: Yes. And you document and track what you’re doing. That’s right.
Accessibility and the purchasing process
Editor: In a large organization, how do you drive accessibility during the purchasing process?
Kathy Keller: In the past, in a large organization that makes a lot of purchases, we made a lot of accommodations for software that was not accessible. Today, accessible products are more prevalent. Also, accessibility requirements are more stringent. Today, many vendors are already testing their products and they’re creating VPATs that describe the accessibility of their products. VPATs aren’t always accurate.
The TAC requires state agencies and education to make accessible purchases, so we have a responsibility to verify VPATs and the products before purchase. To evaluate and test all these purchases can be a big challenge, so it’s useful to bring in outside help, to contract with a vendor to review VPATs and verify the accessibility of products.
Editor: Have you also gotten outside help for developing policy, or have you used templates for that?
Kathy Keller: I haven’t been employed by an organization that went outside for policy help, but I have been employed as a consultant by organizations to work on policy.
Editor: That makes sense. You bring a lot of experience from the past and help them shortcut the process a bit.
Kathy Keller: I’m very familiar with it. I’ve worked in the area for 22 years and my heart is there. So it’s something that I really love to do, to see interest in accessibility and be involved in helping organizations develop their own programs.
Editor: What we do a lot at Microassist is help organizations get a jump start on the backlog they have on accessibility by auditing their existing digital content, whether it’s a website, whether it’s e-learning, whether it’s documents, and helping them prioritize it and help them remediate, because upfront it’s often overwhelming to take care of all that simultaneously. And we help them get a jumpstart and create processes so that they can keep things accessible in the future.
Kathy Keller: Yes. I love what we’re doing. I love working with these large organizations to help them to get a picture of where they are with their digital content, by just what you’re saying, doing these assessments, and then sitting down with them and working on their policy and prioritizing their efforts, helping them to get the components of a program in place.
Editor: Kathy, Thank you for your time today and the wonderful information you shared. I’m sure we will continue this discussion soon.
Related Reading
- 8 Key Elements for Creating a Culture of Accessibility
- Understanding Digital Accessibility in the Procurement Process
- Accessibility Consulting for Colleges and Universities
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