This message is a follow-up to the September 26 communication, sent from the Centre of Human Rights, Equity and Diversity and the AODA session presented at the Communications Leads Meeting, held on October 22.
For any questions or support required for AODA Web compliance matters please contact: AODA-web-compliance@humber.ca
These resources and information are being shared to Humber departments and faculties in order to support them in their assessment of the websites and web-based applications they maintain and actions required to meet the AODA requirements and deadline of January 1, 2021 (less than 90 days from now).
For more information, you can also visit the Government of Ontario’s website at https://www.ontario.ca/page/how-make-websites-accessible.
Background
The purpose of the Accessibility for Ontarians with Disabilities Act (AODA) is to benefit all Ontarians by developing, implementing and enforcing accessibility standards in order to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January 1, 2025.
The Information and Communication Standard regulates how organizations will be required to provide, create, and receive information and communications that are accessible to persons with disabilities. Humber should note that as per 14 (4) of the ONTARIO REGULATION 191/11, Integrated Accessibility Standards, designated public sector organizations must “meet the requirements of this section in accordance with the following schedule”:
By January 1, 2021, all internet websites and web content of public sector organizations like Humber must conform with to WCAG* 2.0 Level AA standards, with exceptions for the following instances:
- success criteria 1.2.4 Captions (Live), and
- success criteria 1.2.5 Audio Descriptions (Pre-recorded). O. Reg. 191/11, s. 14 (4).
This includes all websites and web content (including web-based applications) that an organization controls, directly or indirectly and where the organization has overall control over the functionality, content and appearance of the website. This requirement does not extend to a large organization’s internal websites.
*WCAG stands for the Web Content Accessibility Guidelines, the metric used to measure the accessibility of web content. WCAG has a few different levels of accessibility, and on January 2021 in order to be AODA compliant your web content must meet the WCAG Level AA standards (was previously WCAG Level A).
Actions taken by Humber College
Since 2014, a number of Humber departments have been working to support the college to meet the new AODA requirements. These Humber departments include Government Relations, Marketing and Communications, Information Technology Services and the Centre for Human Rights, Equity & Diversity.
There has been a considerable amount of time and work put into preparing Humber for the January 2021 deadline.
The following are areas that have been addressed, and have been deemed AODA- compliant:
- Websites managed by “Blackcat”
- Websites managed by the Government Relations, Marketing and Communications department
- Public facing software and applications that do not require a login that are managed on Humber servers by ITS
Non-Compliant Humber websites
Further action may be required by your department or faculty.
Websites that have been developed and maintained directly by a department or faculty must also be AODA WCAG 2.0 Level AA compliant by January 2021. Please check with the web developer that is maintaining the website(s) for you.
For software and applications that do not require login and are not managed on Humber servers by ITS please review the following next steps.
Next steps for you:
- Review: Updated “Humber interim web guidelines, accessed at http://humber.ca/brand/sites/default/files/web-guidelines/interim-web-guidelines.pdf
Note the details starting on p. 10: “Accessibility Compliance (AODA)”
- Review: Humber Web Accessibility Compliance Resources page
https://humber.ca/tutorial/web-accessibility-compliance.html
- For your reference: Official WCAG 2.0 AA Quick Reference can be accessed at: https://www.w3.org/WAI/WCAG21/quickref/?currentsidebar=%23col_customize&versions=2.0&levels=aaa
- Follow up with any vendors providing public facing software and applications to ask them:
- Are they compliant with AODA?
- What WCAG level of compliance do they have?
You are looking to hear from your vendors that they are compliant with AODA. Note: a number of vendors who are U.S. based will advise you they are compliant with the U.S. based ADA Section 508 accessibility legislation. The Ontario AODA legislation and U.S. based ADA Section 508 legislation both require the web content meet the WCAG Level AA guidelines, so software that is compliant with ADA Section 508 should be compliant with AODA.
- Please note that for software or website content that is student facing, you can ask the vendor to share their ADA Section 508 Voluntary Product Accessibility Template (VPAT) and any exclusions they have been granted. Reviewing the VPAT will provide you with additional information on any areas of the software application that are not fully compliant with the accessibility standards. For example, any areas of the software application that do not support keyboard based navigation will be identified as non-compliant. For large software applications, they is usually some functionality that is not fully accessible / compliant.
Some commonly overlooked requirements include1:
- Ensuring all images have descriptive alt text
- Minimum contrast ratio between text and background
- Text captioning of recorded audio/video content
- Use actual text vs images of text
- Ensuring that PDFs are AODA compliant
For any questions related to AODA and WCAG web compliance, please contact: AODA-web-compliance@humber.ca
1 Humber College. (2020). Interim Web Guidelines. Accessed at: <http://humber.ca/brand/sites/default/files/web-guidelines/interim-web-guidelines.pdf>
