Does Your Company or Organization Have a Web Accessibility Coordinator?
In recent lawsuit settlements the US Department of Justice (DOJ) has required entities that have inaccessible websites or mobile applications to create a position for a Web Accessibility Coordinator (WAC). Does your company or organization have a Web Accessibility Coordinator? Similar to an ADA Coordinator (ADAC), this individual can be an employee or consultant who has the following requirements with respect to the entity website and/or mobile aps.
1. The WAC will be knowledgeable concerning:
accessibility and usability of websites, web content, and mobile applications
testing and evaluation of the accessibility of web pages and mobile applications
and standards published by W3C, including WCAG 2.1 AA.
2. The WAC will serve as the primary contact for web accessibility issues and concerns raised from any source, internal or external.
3. The WAC will develop, implement, and maintain a Web Accessibility Policy (WAP). The WAP will provide for:
equal opportunity for qualified individuals with disabilities to participate in and benefit from the entity services, programs, and activities,
conformance with the requirements of WCAG 2.1 AA for all websites, web content, and mobile applications.
4. The WAC will distribute copies of the WAP to all employees whose work may be affected by the policy.
5. The WAC will develop a Web Accessibility Statement (WAS). The WAS should include at least the following statement, “[Entity Name] is committed to ensuring that its website and mobile applications are accessible to individuals with disabilities. All pages on our website and all mobile applications will meet Web Content Accessibility Guidelines (“WCAG”) 2.1 AA conformance. Please report accessibility issues to [insert name and email address for Website Accessibility Coordinator].”
6. The WAC will be responsible for Web Accessibility Training (WAT). In this role, the WAC will provide mandatory web accessibility training:
to all employees and contractors who design, develop, maintain or otherwise have responsibilities related to the content on the entity website or mobile applications. The training will cover WCAG 2.1 AA. The entity should also comply with future versions of WCAG.
regarding the entity Web Accessibility Policy
regarding common technological accessibility barriers faced by individuals with disabilities
regarding common assistive technologies used by individuals with disabilities in interacting with websites
an overview of accepted accessibility standards, including WCAG 2.1 AA.
Any new employee or contractor covered by the WAP (i.e. one who designs, develops, maintains or otherwise has responsibilities related to the technical operation of the entity website or mobile applications) should receive the training shown above before engaging with the entity website or mobile aps, or within six (6) weeks of hire, whichever occurs first.
If no employees of an entity are willing or able to serve as a WAC, a consultant should be hired who has expertise concerning accessible website and mobile applications development and WCAG 2.1 AA. When first hired, the consultant should complete an evaluation of the entity website and mobile aps for compliance with WCAG 2.1 AA and provide the entity with a written evaluation (“Web Accessibility Evaluation”) regarding:
whether the website is in conformance with the requirements of WCAG 2.1 AA, and recommendations to achieve conformance for any areas of nonconformance,
whether the mobile applications are in conformance with the requirements of WCAG 2.1 AA, and recommendations to achieve conformance for any areas of nonconformance, and
other recommendations to improve the accessibility of the entity website and mobile aps.
Currently there is no legal mandate for a Title II or Title III company or entity to have a WAC. Similarly, there is no legal mandate for a Title III company or entity to have an ADAC, but the DOJ recommends it, and occasionally demands it as part of a lawsuit settlement. To stay ahead of these ADA lawsuits and the DOJ, designating an employee, or hiring a consultant, to act as the WAC and/or ADAC will benefit your company or entity by prioritizing ADA compliance within.
SUMMARY: In recent lawsuit settlements the DOJ has required entities with websites and mobile aps to create a position for a Web Accessibility Coordinator (WAC). If no employees of an entity are willing or able to serve as a WAC, a consultant should be hired to fill that role. Proactive entities should consider adding a WAC to their staff to prevent or avoid lawsuits regarding website and mobile app accessibility.
…………………………………………………………………………………………………………………………………………………………………………