IT950 TN07 Website and Digital Media Accessibility.pdf

Technical Note: IT-950-TN07 Effective: 3/11/2025 Last Reviewed/Revised: N/A Next Review: 3/11/2028

WEBSITE AND DIGITAL MEDIA ACCESSIBILITY (2018+)

PURPOSE

This technical note establishes Smithsonian website and digital media accessibility policy and standards to make all existing, revised, and new Smithsonian web and digital resources accessible to all people including those with disabilities. Units must incorporate accessibility validation into their on-going website and other digital media creation and maintenance processes. Regular accessibility reviews will be scheduled to assist digital media owners in remediation and IT governance. Proactively managing digital media accessibility involves:

• Identifying accessibility issues and obstacles against a target

• Evaluating the significance

• Remediation

Accessibility management enables Smithsonian to broaden access to Smithsonian resources and meet or exceed prevailing conformance standards, while reducing risk to the Institution.

Smithsonian Directive (SD) 215 “Accessibility for People with Disabilities” requires that all Smithsonian public programs, including digital media, be accessible to people with disabilities to the fullest extent possible and practicable. Third-party vendors that provide websites and digital media platforms and services on behalf of the Smithsonian are also required to follow SD 215. SD 214 “Equal Opportunity Handbook” affirms the Smithsonian commitment to providing equal employment opportunities, including access to information, to staff with disabilities.

Section 508 of the Rehabilitation Act, as amended, is a federal law that requires agencies to provide individuals with any form of disability equal access to electronic information and data comparable to those who do not have disabilities. The World Wide Web Consortium (W3C), the main international standards organization for the Internet, has provided Web Content Accessibility Guidelines (WCAG) since 1999. These guidelines specify requirements for digital media and web content to be accessible to people with disabilities and to comply with Section 508 of the Rehabilitation Act. WCAG standards cover all aspects of making digital media accessible, such as color, format, structure, images, and more. The guidelines, and resources supporting use of the guidelines, have been continuously updated under the curation of the W3C Web Accessibility Initiative (WAI). W3C WAI is continuing to develop support materials for WCAG and, years hence, there will likely be a WCAG 3, and beyond.

WCAG 2.0 is already applicable to all Smithsonian digital media published prior to January 1, 2018, including mobile apps. Digital media published or redesigned after January 1, 2018, must adhere to the WCAG 2.1 AA guidelines as a minimum requirement. WCAG 2.0 was published in December 2008, became an ISO standard in October 2012, and was formally incorporated by reference into the U.S.

Section 508 regulation in 2017 by the Architectural and Transportation Barriers Compliance Board (“Access Board”). WCAG 2.1 was published in 2018 and has since been integrated into EN 301 549 “Accessibility Requirements for ICT Products and Services” (including 2021 V3.2.1).

https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD215.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214-HB1.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214-HB1.pdf

Website and Digital Media Accessibility (2018+)

Following accessibility techniques developed by private and government organizations makes even complex web pages accessible for and usable by everyone. For most digital media, implementing accessibility features is not difficult and will seldom change the layout or appearance of web pages.

These techniques also optimize web pages for use both by people using older computers and by people using the latest technologies.

Many people use assistive technology to enable them to use computers and access the Internet. This includes technology such as screen reader software, voice interactive software, and Braille output devices. New and innovative assistive technologies are being introduced regularly. Well-structured digital media facilitates these technologies, whereas poorly designed digital media often creates unnecessary barriers for people who use assistive technologies, just as poorly designed buildings diminish functionality for a broad range of users.

SCOPE AND APPLICABILITY

This technical note applies to all Smithsonian staff and affiliated persons who own or manage Smithsonian digital media published after January 1, 2018, both publicly accessible and internal-only, whether hosted by the Institution within its data center or externally on behalf of the Institution. All personnel must follow its contents and the procedures specified herein to maintain adherence to SD 950 “Management of the Smithsonian Web” and SD 215 “Accessibility for People with Disabilities”.

Websites and other digital media created before January 1, 2018, must adhere to the policy enumerated in IT-950-TN06 Website Accessibility, which covers WCAG 2.0 AA minimum accessibility requirements.

RESPONSIBLE OFFICE(S) OR GROUP(S)

• Office of Visitor Accessibility: Establishes and supports the Institution’s strategic vision regarding visitor accessibility. Establishes and provides guidance and interpretation on Smithsonian accessibility policy.

• Chief Information Officer (CIO): Establishes and supports the Institution’s IT strategic vision.

Supports the Institution’s web presence by providing IT and communication infrastructure, hosting infrastructure, standards, and development support and guidance.

• Office of Digital Transformation (ODT) Head of Web Development: Oversees the Web Accessibility Governance. Reviews website accessibility scan reports, determines risk and associated remediation plans. Provides input and recommendations to the Director of Digital Platforms, the CIO, and the Office of Visitor Accessibility.

• ODT Web Development Staff (WebDev): Perform and respond to requests for central accessibility scanning, manual testing, and report generation. Notify appropriate staff of any identified issues or actions required for compliance. Track enterprise-level digital media accessibility issue resolution progress via plan of action and milestones (POAM) documentation and provide assistance to units on mitigating issues. Maintain a list of SI websites with owner/contact information for site-related communication.

• Unit Project Manager or Representative: Reviews accessibility reports and ensures that the appropriate unit support staff promptly mitigate accessibility issues to achieve and maintain compliance. Ensures external vendors are made aware of SI requirements & holds vendors accountable for delivering products that comply with SI standards. Budgets for accessibility https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD950.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD950.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD215.pdf https://smithsonianprod.servicenowservices.com/si?id=kb_article_view&sysparm_article=KB0011362 activities across the unit’s web-based and digital media products. Submits remediated media for final testing and remediation plan closure.

• Website or Digital Media Owners/Business Sponsors: Validate that digital media is fully accessible and compliant with WCAG 2.1. Review accessibility validation results / reports and work with site managers and/or application developers to authorize, prioritize, and schedule changes to their systems. Ensure remediation is performed successfully.

• Website or Web Application Managers/Developers: Ensure that websites and digital media are fully accessible and compliant with WCAG 2.1. Perform accessibility validation of their digital media, including generating and reviewing accessibility reports for media they manage using their own tool suite(s) whenever changes are made. Remediate issues found as part of the site development and maintenance/management process. Work with Unit IT Director, Website or Web Application Owner/Business Sponsor, and ODT in responding to central accessibility audits/reports. Responsible for managing and patching websites and web applications at the content and code level. Verify that all remediation is successful.

DEFINITIONS

Digital Media. Digital Media refers to any form of perceivable content that relies on an electronic device for its creation, distribution, viewing, and/or storage. Examples include exhibitions, video, audio, images, artworks or time-based media, electronic documents, virtual tours, mobile applications, gallery interactives, simulators, online games, live streaming, or recorded events, and other installations of digital media experiences. Digital media can be stand-alone or be integrated into a website or exhibit.

Archer. Integrated risk management system which provides tracking of various Smithsonian IT governance functions including accessibility and role-based security requirements and completions, approval workflows, dashboards and reporting, and links to training resources.

Accessibility Remediation. The process of identifying and correcting barriers that prevent people with disabilities from fully accessing and using digital content, products, or physical environments.

POLICY AUTHORITY

Carmen Iannacone, Chief Information Officer (Acting)

POLICY

Smithsonian Accessibility Target

Smithsonian Institution websites and digital media published after January 1, 2018, including website refresh and maintenance projects, shall meet or exceed the W3C WCAG 2.1 Level AA guidelines. The WCAG 2.1 guidelines include accessibility for linked content such as Adobe PDF and Microsoft Office Files, as well as audio and video content developed for or on the behalf of the Smithsonian Institution.

All Smithsonian Institution websites and digital media published before January 1, 2018, are expected to meet or exceed the W3C WCAG 2.0 Level AA accessibility guidelines. All Smithsonian websites and digital media should strive for higher than Level AA conformance to promote and facilitate greater inclusion.

SI units can specify a higher level of WCAG conformance standards (e.g., 2.2 AAA, 2.2 AA) within the contract language for any project to achieve a greater standard for digital accessibility and inclusive design.

Accessibility Review Policy

The Smithsonian Office of the Chief Information Officer (OCIO) and the Office of Digital Transformation (ODT) use a variety of tools and services for the purposes of scanning, testing, and reporting on network assets, digital media, and websites. OCIO and ODT scans and tests all public and private Smithsonian network segments as well as externally hosted websites. This includes website accessibility scanning and reporting.

Unit IT managers, developers, and content authors are responsible for ensuring their websites and digital media are accessible and for validating and maintaining accessibility. They should procure their own website testing tool(s) as a standard component of their site development, quality assurance, and on-going maintenance/management processes. Testing tools generally include processes for testing for broken links, spelling errors, accessibility issues, browser compatibility, and HTML and CSS checks/validation, in addition to other features. The tools provide the ability for website managers and developers to run their own scans, filter results, and drill down to individual issues with the associated HTML code and remediation steps displayed, none of which can be done with the reports alone. Manual reviews are required since automatic scanning tools do not detect all accessibility issues. Screen readers and color contrast checkers enable the site manager/developer to look at and hear a site as someone with a sight or hearing disability would. The tools used to test compatibility with assistive technologies, such as screen reader software, should be the same as or comparable to the products commonly used by individuals with disabilities. OCIO can provide product recommendations. Where applicable, Managers and developers should also test their digital media’s functionality using only a keyboard only to identify and remediate any issues that would affect someone with a physical disability that prevents them from using a mouse or other point-and-click technology.

Accessibility Review and Report Schedule

OCIO scans all Smithsonian websites and digital media products and conducts manual reviews against the accessibility standards before launch, on a scheduled basis, on request, and as needed. Accessibility reports are generated and sent to the owner/designated contact for action.

New and Redesigned Websites and Digital Media

Developers of new websites (including user interface and technology refreshes of existing websites) and digital media shall conduct accessibility validation using their own tools as part of the design, development, and testing process. Additionally, developers shall request an accessibility review from OCIO as part of the pre-launch Life-Cycle Management/Technical Review Board (LCM/TRB) review and approval process. The digital media must be deemed to have passed an accessibility review before approval to launch will be granted. There are no waivers issued by any internal SI department or entity for accessibility of any digital media.

Existing Websites

Existing websites are centrally scanned on a semi-annual basis (twice a year) to ensure they remain compliant with either WCAG 2.0 or 2.1 (depending on year of initial build or major update). When changes are made, units should independently validate their sites for accessibility conformance and other issues using their own tools, resolving any problems that arise as part of their own site management and maintenance processes.

Existing Digital Media

Existing digital media products must be regularly tested and maintained (quarterly) to ensure that built-in accessibility features such as captioning, audio description, keypad navigation, audio output, and others are compliant with WCAG guidelines (2.0 or 2.1 depending on year of initial build or major update). Units should independently validate their digital media products and platforms for accessibility conformance and other issues using their own tools and resources resolving any problems that arise as part of their own site management, exhibition development, and maintenance processes.

Remediation and Policy

To ensure that remediation is given sufficient priority, a remediation timeframe is set based on the number and criticality of accessibility issues detected.

The following table provides a guideline on remediation timeframe.

Media Type Remediation / Compensating Control Timeframe

Actions Taken if No Approved Remediation Plan

New websites Before site launch Launch approval not granted

Existing websites Within 4 weeks from receipt of scan report

If remediation is to take more than 4 weeks, a remediation POAM must be submitted to OCIO

New digital media Before exhibition opening Launch approval not granted

Existing digital media Within 4 weeks of quarterly evaluation

Media may be subject to removal or discontinuation if remediation cannot be completed within 4 weeks; consultation with the Office of Visitor Accessibility is encouraged

Remediation plans must be documented as a Plan of Action and Milestones (POAM). In this context, the POAM functions as a risk management tool specifically designed for documenting, tracking, and remediating accessibility compliance issues. Each POAM is required to adhere to the following structure:

• Identification Information: Clearly identify the website or digital product under consideration and include its URL, if available.

• Owning Unit and Site Manager: Name the organizational unit that owns the website or digital product and identify the site manager responsible for its operations.

• Brief Description: Provide a succinct, one paragraph summary that describes the function or purpose of the website or design element under review.

• Accessibility Issues Table: Compile a table categorizing accessibility issues by their type and level of impact on disabled users. Impact levels should be categorized as high, medium, or low.

The table should account for variables like page, file, and visitor traffic and must include findings from both automatic scanning and manual review reports.

• Remediation Steps: Outline the specific actions required to address each identified accessibility issue, along with their corresponding timeframes.

• Completion Date: State the date by which all remediation activities will be finalized.

The milestones specified in the POAM will be entered directly into the Enterprise Risk Management System and Archer, by the owning Unit's designated project owner. Detailed Remediation POAM must be attached to the Archer record as a separate document, along with any supporting accessibility testing reports.

Remediation must begin promptly and move forward within a reasonable timeframe. Remediation should be planned and performed so that those digital elements with the most significant issues, impacting the largest number of visitors, are addressed first, while at the same time addressing issues that are either relatively easy to fix or impact large numbers of features/pages.

To ensure that accessibility issues are remediated properly, another review is centrally performed to verify the issue(s) is/are no longer detected.

Digital media and features that fail to provide and act upon an Approved Remediation Plan may be shut down until the identified accessibility issues are resolved.

RELATED POLICY AND PROCEDURES

SD 214 Equal Employment Opportunity Program

SD 214 Equal Opportunity Handbook

SD 215 Accessibility for People with Disabilities

SD 920 IT Life Cycle Management

SD 950 Management of the Smithsonian Web

IT-950-TN04 Public Website & Web-Based Application Development

IT-950-TN06 Website Accessibility

Web Content Accessibility Guidelines (WCAG) 2.1 (w3.org)

TECHNICAL NOTE CHANGE LOG

Date of Revision Description of Changes

3/4/2025 • Standardization on ‘digital media’ as preferred term throughout document

• Accessibility remediation added to Definitions

• SD 214 Equal Employment Opportunity Program, SD 214 Equal Opportunity Handbook, and IT-950-TN06 added to Related Policy and Procedures

• Minor grammatical revisions https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214-HB1.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD214-HB1.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD215.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD215.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD920.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD920.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD950.pdf https://sinet.sharepoint.com/sites/Prism-OPMB/SD/SD950.pdf https://smithsonianprod.servicenowservices.com/it?id=kb_article_view&sysparm_article=KB0011360 https://smithsonianprod.servicenowservices.com/it?id=kb_article_view&sysparm_article=KB0011360 https://smithsonianprod.servicenowservices.com/si?id=kb_article_view&sysparm_article=KB0011362 https://smithsonianprod.servicenowservices.com/si?id=kb_article_view&sysparm_article=KB0011362 https://www.w3.org/TR/WCAG21/ https://www.w3.org/TR/WCAG21/

Date of Revision Description of Changes

2/3/2025 • Split policy for WCAG 2.0 and WCAG 2.1 Accessibility Guidelines into two separate TNs

• Moved document into tech note template

• Added '(2018+)' to title

• Added language throughout document to distinguish what digital media must be WCAG 2.0 and 2.1 compliant

• Deleted paragraph about background information on WCAG 2.0

• Changed Policy Authority to Carmen Iannacone, Chief Information Officer (Acting)

• Added link to WCAG 2.1 under Related Policy and Procedures

• Minor grammatical revisions

3/23/2023 • Extensive rewrite of most sections

• Suggested revisions and comments added by the Office of Visitor Accessibility and the Office of the Chief Information Officer

7/7/2016 Initial release