The Americans with Disabilities Act (ADA) is a core piece of civil rights legislation banning discrimination on the basis of disability. Title III of the ADA mandates that businesses remove structural barriers and other impediments that curb access to an establishment including website access and usage by visitors with disabilities. This post will present key factors influencing an effective website accessibility strategy for credit unions.
Why It’s Important
In 2010, the US Department of Justice’s Advanced Notice of Proposed Rulemaking announced that the department aspires to update Title III of the act to cover website accessibility. A final ruling is expected to be delivered in 2018, defining the official standard for website accessibility and detailing specifically what businesses will need to do to comply with the law.
Because of the sensitive nature of their data, credit unions will fall under a higher degree of scrutiny than less regulated businesses, so it is critically important that credit unions comply with a law that will be more tightly interpreted going forward.
Preparing for the inevitable
In August 2016 the Department of Justice ruled against the University of California at Berkeley in a lawsuit because the college’s YouTube channel did not utilize captions that would assist the hearing impaired. The DOJ recommended that UCB and other companies who serve the public adopt the second generation of the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG), a fact that leads web accessibility experts to believe that the 2018 ADA amendment will be based on the WCAG 2.0 AA standard.
The WCAG Standard
Comprised of four overarching principles and 12 guidelines that include acceptance rules, the WCAG 2.0 framework comprises a set of testable criteria and technical benchmarks that align with the charge to design high-quality web and mobile experiences for people with disabilities. To achieve WCAG compliance, a business’s applications must adhere to the following principles.
Governing Principles
- Perceivable: Information and user interface components must be provided to users in ways they can discern (applies to visual and hearing impaired)
- Operable: User interface components and navigation tools must be clearly workable (applies to keyboard, mouse and other reasonable assistive technologies)
- Understandable: Data presented including instructions along with the operation of the user interface must be clear and coherent.
- Robust: Content must be comprehensive to the extent that it can be understood with certainty by a wide variety of the most common assistive technologies
WCAG Guidelines
The full detail of the standard can be found by reading the WCAG documentation, but below is a brief overview of the guiding rule set.
Perceivable
- 1.1 Present text alternatives for images, videos or any non-text content so that it can be converted into an articulation people with disabilities can interpret, including large print, braille, speech, symbols or simpler language.
- 1.2 Provide alternatives for time-based media (text and audio transcripts, captions, alternative text, etc.)
- 1.3 Create content that can be presented in different ways (for example simpler layout) without losing information or structure.
- 1.4 Make it simpler for users to see and hear content (separating foreground and background contrast)
Operable
- 2.1 Make all UI components accessible from a console (keyboard or related assistive tool)
- 2.2 Give users adequate time to consume and use the material presented
- 2.3 Avoid presenting content in a way known to result in seizure
- 2.4 Include navigational support so the user always knows where they are
Understandable
- 3.1 Ensure text content is clear and reasonably understandable
- 3.2 Certify that web pages use clear and predictable functional patterns
- 3.3 Assist users with error correction
Robust
- 4.1 Make sure content and components are accessible to commonly used assistive technologies.
Credit union website accessibility compliance will become a fundamental part of the regulatory environment in the months to come. Consider a website accessibility strategy as part of the new website basics framework.
Forward-thinking credit union leaders would be wise to immediately retrofit their websites, update mobile applications, and retool digital design workflows to meet the WCAG 2.0 AA standard. These steps alone will help mitigate risk and provide an optimal experience for customers including those with disabilities.
