Web Content Accessibility Guidelines Policy
ELECTRONIC COMMUNICATIONS POLICY
OVERVIEW
Title III of the Americans with Disabilities Act (ADA) addresses “Public Accommodations and Services Operated by Private Entities.” Title III is regulated and enforced by the U.S. Department of Justice (DOJ). In September 2018, the DOJ sent a letter to Congress stating its belief that websites should be considered “places of public accommodation.” The DOJ has referenced the Web Content Accessibility Guidelines as the standard to follow to become ADA compliant.
Web Content Accessibility Guidelines (WCAG) 2.1 defines how to make Web content more accessible to people with disabilities. Accessibility involves a wide range of disabilities, including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities. Although these guidelines cover a wide range of issues, they are not able to address the needs of people with all types, degrees, and combinations of disability. WCAG 2.1 is developed through the W3C process in cooperation with individuals and organizations around the world, with a goal of providing a shared standard for Web content accessibility that meets the needs of individuals, organizations, and governments internationally. WCAG 2.1 builds on WCAG 2.0, which in turn built on WCAG 1.0 and is designed to apply broadly to different Web technologies now and in the future, and to be testable with a combination of automated testing and human evaluation.
WCAG LAYERS OF GUIDANCE
The individuals and organizations that use WCAG vary widely and include Web designers and developers, policy makers, purchasing agents, teachers, and students. In order to meet the varying needs of this audience, several layers of guidance are provided including overall principles, general guidelines, testable success criteria and a rich collection of sufficient techniques, advisory techniques, and documented common failures with examples, resource links and code.
Principles - At the top are four principles that provide the foundation for Web accessibility: perceivable, operable, understandable, and robust.
Perceivable: Information and user interface components must be presentable to users in a way that they can perceive.
Operable: User interface components and navigation must be operable.
Understandable: Information and operation of the user interface must be understandable.
Robust: Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies.
Guidelines - Under the principles are guidelines. The guidelines are not testable but provide the framework and overall objectives to help authors understand the success criteria and better implement the techniques.
Success Criteria - For each guideline, testable success criteria are provided to allow WCAG to be used where requirements and conformance testing are necessary such as in design specification, purchasing, regulation, and contractual agreements. In order to meet the needs of different groups and different situations, three levels of conformance are defined: A (lowest), AA, and AAA (highest).
Sufficient and Advisory Techniques - Advisory techniques are informative and fall into two categories: those that are sufficient for meeting the success criteria and those that are advisory. The advisory techniques go beyond what is required by the individual success criteria and allow authors to better address the guidelines. Some advisory techniques address accessibility barriers that are not covered by the testable success criteria. Where common failures are known, these are also documented. All of these layers of guidance (principles, guidelines, success criteria, and sufficient and advisory techniques) work together to provide guidance on how to make content more accessible. Authors are encouraged to view and apply all layers that they are able to, including the advisory techniques, in order to best address the needs of the widest possible range of users.
PURPOSE
This Policy has been created to define the process that Kredit Financial Inc. (Kredit) utilizes to provide a website that is accessible for all site visitors.
POLICY
It is the policy of Kredit to provide a fully accessible and optimized experience for all website visitors.
SCOPE
This Policy applies to all content on the Kredit website.
ROLES AND RESPONSIBILITIES
Kredit’s Chief Compliance Officer (CCO) is responsible for coordinating efforts with the Product Designer to ensure Kredit’s website visual content satisfies all the Level A and Level AA Success Criteria (i.e., Level AA conformance). The CCO is also responsible for reviewing this Policy on an annual basis.
Kredit’s Product Designer is responsible for ensuring each iteration of the Kredit website is evaluated using an accepted WCAG tool, as well as implementing suggested changes to meet Kredit’s stated conformance level.
PROCEDURE
Kredit utilizes the WAVE Web Accessibility Evaluation Tool (WAVE) to perform WCAG scans on its website. The WAVE tool aides in the identification of many accessibility and WCAG version 2.1 errors, and also facilitates human evaluation of web content. In terms of success criteria (set at Levels A, AA and AAA), Kredit has elected to conform to Level AA of these guidelines, to the greatest extent feasible.
After each implementation of changes to Kredit’s website, the Product Designer utilizes the WAVE tool and/or any other industry accepted tool to identify suggested updates or enhancements. As issues are identified, care will be taken to address each suggested update or enhancement in order to consistently improve the website user experience and ensure the site is user friendly for everyone.
COMMUNICATION
This Policy shall be communicated to all affected employees via email and maintained in the Policies folder, sub-folder Regulatory Policies, on Google Drive for reference purposes.
VIOLATIONS
Failure to follow the above stated procedures may result in the inability of certain populations of consumers with disabilities to utilize the Kredit website.
CHANGE SUMMARY
Purpose: Internal Policy
Category: Regulatory
Policy Name: Web Content Accessibility Guidelines Policy
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