WebAIM - Web Accessibility In Mind

The WebAIM Strategic Accessibility Framework
Indicator 2: Planning and Implementation

Introduction to Indicator 2

Digital accessibility requires strategic planning. Organizations realize many benefits when they establish policies defining shared expectations for accessibility across the enterprise. They also benefit from developing a comprehensive plan that maps out the work ahead. Such plans may necessarily span several years. Organizational leadership should plan to communicate their personal commitment to the organization's accessibility goals. They should also pave the way to communicate the organization's progress with all stakeholders. This is the very heart of attaining and sustaining digital accessibility across the organization.

Strategic Accessibility Training & Consultation

WebAIM has helped hundreds of clients at different stages of their accessibility journey to use strategic thinking and build a sustainable accessibility program. Our comprehensive strategic accessibility training provides a detailed look at components of successful accessibility initiatives. Our customized consulting can help your organization create policies, plans, and processes to support this framework.

Learn more about WebAIM Strategic Services

Benchmark 1: Inclusion of Key Personnel and Stakeholders

Identifying and involving personnel who represent key constituent groups at the organization is essential. These key personnel are vital to advancing accessibility and may come from various parts of the organization. They will often, collectively, be the core of an accessibility task force or committee.

A broad group of stakeholders should also be included to provide feedback on accessibility plans and efforts over time. Stakeholders include the people that use the organization's technology, those who implement the organization's accessibility program, people who influence the organization's technology design and adoption, and disability advocates. Staff whose work will change because of accessibility will also have input into that process. This benchmark is different from Indicator 1 - Leadership Vision and Commitment for Accessibility. The leadership vision to include a variety of stakeholders is different from ensuring their actual participation and contribution throughout the process.

In this Framework, key personnel are those who directly draft policy language for the organization, initiate implementation planning, and ensure that other stakeholders are appropriately engaged over time.

The broader group of stakeholders is there to provide feedback on different tasks and deliverables. Stakeholders will change based on the task at hand. For example, if key personnel work to fold accessibility into technology procurement and acquisition, then stakeholders will include those involved in crafting procurement language, managing the procurement process, and selecting product owners. As the scope and details of the plan become more clear, this group of stakeholders will involve different units, departments, and individuals.

Note on each Benchmark's statements of evidence:

These statements of evidence are examples and are not all required to reach a benchmark. There are many ways to align these benchmarks to an organization's culture. Understanding the general idea of the benchmark itself will support determination if it is present or not.

1. Involvement of key personnel in creating digital accessibility policy and involvement of stakeholder groups in the development of an organization-wide plan for digital accessibility

While the development of the policy and the plan represent two separate activities, when discussing if key personnel are involved, the questions are the same. The information below applies to both policy and plan.

Ways to determine if this is present
  • There is documentation that a diverse set of key personnel and stakeholders are involved in the development of both the accessibility policy and plan. Key personnel who draft policy are usually a subset of the stakeholders identified in Indicator 1, Benchmark 2. Other key personnel for this may include:
    • Accessibility subject matter experts
    • Leadership, particularly technology and web
    • Personnel from departments or units that influence the organization's technology environment
      • Key product owners
      • Technology procurement and contracting staff
    • Disability advocates
    • Policy experts
    • Staff in roles that are not primarily technology-focused
    • Stakeholders who have disabilities that are impacted by web use
  • There is documentation that implementation planning includes a broader group of stakeholders that fully represents the various units, departments, and individuals that create and influence technology in the organization.
  • There are meeting notes that indicate active, ongoing participation by key personnel and stakeholders responsible for both policy and planning.
  • There is evidence that key personnel work to promote buy-in from the broader stakeholder group from which they come.

2. Involvement of key personnel and stakeholders in the implementation of an organization-wide digital accessibility plan

Ways to determine if this is present
  • There is documentation that a representative digital accessibility committee led and monitored implementation efforts.
  • There is evidence that the digital accessibility committee is given the necessary authority and support to guide the implementation of the plan.
  • If there is an accessibility coordinator or similar role, then there is evidence that this role is given the necessary authority and support to coordinate activities across the organization.
  • There is evidence that key personnel are assigned to ensure that the plan is on track and that the work being done conforms to the targeted scope and digital accessibility standards as intended.
  • There is evidence of efforts made by the committee or coordinator to help departments and personnel meet the requirements set forth in the policy.

Benchmark 2: A Comprehensive Accessibility Policy

A policy that provides specific guidelines and standards for digital accessibility ensures that everyone understands what is required of them. The policy essentially sets the foundation for a sustainable accessibility program. It should appear in the same set of governing documents as other organization-wide policies. Once established, the policy should be promoted and enforced.

1. The digital accessibility policy is presented in similar ways, styles, and levels as other policies that affect the entire organization (e.g., Equal Opportunity, Sexual Harassment)

Creation of organization-wide policy is heavily influenced by the culture of the organization. So, determining the form and reach of the policy needs to be done with other policies of the organization in mind. A red flag could be that the organization does have a set of policies, but the digital accessibility requirements reside as a guidance document nestled in only one unit of the organization. For digital accessibility to be taken seriously, it should be elevated to a level where nobody can simply decide that they will not support it or do what is required.

Ways to determine if this is present
  • The policy is administered by leadership who have a similar position within the organization as other policy owners.
  • The policy has the reach and authority to effectively carry the policy forward.
  • The policy is consistent with other policies in style, structure, and tone.

2. The digital accessibility policy includes relevant elements

All stakeholders understand their unique roles and responsibilities with respect to developing, acquiring, and maintaining an accessible web presence and are empowered to fulfill those responsibilities. Those in leadership set clear expectations regarding how relevant roles will fulfill their responsibilities. Leadership also spearheads and supports training efforts. This can be documented through position descriptions, evidence of training, annual performance evaluations, and mechanisms for accessibility feedback from staff and those with disabilities.

Ways to determine if this is present
  • A summary statement of the policy:
    • Explicitly states the rationale for the policy.
    • Describes expected outcomes.
    • Establishes when key steps are to be completed.
    • Outlines how these steps will be achieved.
  • The date the policy becomes effective is stated.
  • If the implementation is phased, all critical dates are listed.
  • The policy explicitly identifies which technology the policy applies to. Examples include:
    • All pages under the organization's ownership, whether they are part of the primary organization's domain, or external to it. Examples include:
      • Public facing web pages (e.g., the organization's home page and informational pages).
      • Organizational Systems (e.g., HR, financial systems).
      • Unit or department pages or material.
      • Product pages.
      • Legacy pages.
      • Community activity pages (e.g., Corporate Social Responsibility).
    • Relevant 3rd party or external web pages not under the organization's domain.
  • The policy outlines accessibility requirements for 3rd party or external pages (e.g., ticket purchases, employee health programs, individual staff pages outside express business purpose).
  • The policy explicitly identifies web content that is exempt from the policy.
    • Does it identify those who can authorize exemptions?
    • Does it describe the process for obtaining exemptions?
  • The policy identifies the technical standard to which all included web content must conform (e.g., Section 508 or WCAG 2.1 AA).
    • Is the technical standard recognized and sufficiently stringent to ensure functional digital accessibility?
  • The policy includes a provision for procurement, contracting, development and use of third party tools. The policy:
    • Affirms that accessibility will be a deciding factor in purchases, licensing agreements, or other contracts.
    • Includes provisions for the procurement of accessible technologies that will impact:
      • Content creation and delivery tools.
      • Authoring tools.
      • Course or learning management systems.
      • Financial, HR, and administrative tools.
      • Third-party resources that are not subject to formal procurement processes, including things like website plug-ins.
    • Covers products developed by the organization, such as content authoring tools.
    • Requires the creation of proactive accommodation planning when accessibility is not technically feasible or when it would present a fundamental alteration of content.
  • The policy defines consequences for non-conformance.
    • The policy includes or refers to statements detailing the consequences when the policy is not followed.
  • The policy contains mechanisms for ongoing review. Examples include:
    • Mechanisms to review and assess the appropriateness of current measures and adjust as necessary.
    • The frequency of this review process.
    • A system for review and revision.
    • Identification of those responsible for the review and revision of the policy.
    • Determination of whether or not proactive accommodations plans are being created.

Benchmark 3: A Comprehensive Written Implementation Plan

An organization's effort requires a plan of action. This plan includes strategies for all aspects of implementation, including goals, timelines, budgeting, materials, personnel, ongoing assessment, and, when necessary, revision of the plan. It is important to consider existing enterprise-wide plans at the organization as these may set the bar for what should be contained in the implementation plan. The overall culture around organizational change must also be considered.

1. The implementation plan is comprehensive

It is important to gauge the completeness of the organization's written plan against other similar organization-wide efforts. While any given plan may not contain all the elements listed below, each adds strength to the plan.

Ways to determine if this is present
  • An executive summary of the plan. This might contain:
    • A clear overview.
    • Summary of benefits or market advantages.
    • Key points of the plan.
    • Important dates and milestones.
    • Stakeholder responsibilities.
    • Expected outcomes.
  • A provision for assessment and market evaluation. This might include:
    • Provisions for evaluating websites of peers or competitors and other relevant sites.
    • Strategies for comparing against best practice.
    • Methods of highlighting exemplars of good accessibility strategies.
    • Systems for identifying and avoiding accessibility pitfalls.
  • A provision to gather baseline accessibility information. This may include guidance for:
    • How much data will be collected (e.g., select a representative sample of pages or workflows).
    • The scope of the baseline (e.g., from the organization's entire web presence, or from specific websites or tools).
    • What data will be collected (e.g., pass/fail per page or detailed by standards and criteria used).
    • How data will be gathered and analyzed (e.g., automated tools, manually, blended).
    • Who is responsible for creating the baseline and on what timeline.
    • How the baseline data will be used in the future so that progress can be evaluated in an ongoing way (i.e., comparison) and so these data can aid in improvements of the plan.
  • Identification of existing challenges and risks. This may include strategies for:
    • Assessing challenges and risks to implementing accessibility across the organization.
    • Overcoming the challenges and risks that are identified.
    • Identifying and mitigating unforeseen challenges and risks as they are discovered.
  • Identification of existing organizational priorities. This may include:
    • Ways that digital accessibility can fit into existing priorities of the organization (e.g., the redesign of the organizational web site, professional development initiatives for staff, broadening diversity and inclusion, hiring exceptional employees, strategic planning initiatives, and any certification, accreditation, or reaffirmation process).
    • Ways to leverage existing initiatives that can promote successful accessibility implementation.
    • Provisions to assess any emerging organizational priorities for potential synergy with digital accessibility efforts.
  • A provision for budget items appropriate to accomplish the plan. This may include:
    • A budget adequate to accomplish the goals outlined in the plan.
    • Provisions for the funding of all aspects of the plan. These can include:
      • Start-up costs
      • Personnel
      • Training
      • Evaluation
      • Messaging
      • Remediation
      • Equipment and software
      • Consultants
    • A plan for assessing the adequacy of the budget.
      • If the budget is not sufficient, is there a strategy to help supplement or augment it?
    • Guidelines for responding to any significant budgetary changes.
  • Metrics, milestones, and measurable steps. This may include:
    • Short term activities.
    • Long term objectives.
    • Explicit expectations for personnel and stakeholder groups.
    • Detailed descriptions of the metrics to be used to measure progress.
  • A timeline for rollout of the milestones and measurable steps. This may provide:
    • Specific dates (or date ranges) for all significant milestones and goals to be achieved across the project.
      • These dates should be realistic and achievable for the given milestones.
    • Target dates that work in conjunction with the dates for conformance specified in the organization's digital accessibility policy.
    • Guidance about reporting and adjusting to delays or changes to deadlines.
  • The assignment of specific responsibilities. This may include:
    • The names or positions of those responsible for carrying out different aspects of the plan.
      • Are critical elements of the plan assigned to individuals with the expertise to carry out those responsibilities?
      • Are sufficient time and resources allocated for these personnel to accomplish assigned responsibilities, including additional duties such as meetings with the accessibility team, inter-disciplinary coordination, training, and changes to workflow?
  • A training plan. This might outline:
    • Mechanisms for, training, and supporting those who will be involved in elements of the implementation plan.
      • Those who will develop and oversee accessibility initiatives.
      • Content contributors.
      • Web designers and developers.
      • Project managers.
      • Product managers.
      • Quality assurance staff.
      • Procurement officers and product owners.
      • Users of tools such as Microsoft Word, PowerPoint, and Excel.
      • Human resources and hiring managers
      • Others who will engage in accessibility work of the organization or with specialized roles or responsibilities.
    • Training formats.
      • Will it be embedded in existing training events?
      • Will it be new specialized training programs?
      • Will it be a hybrid of new and existing?
  • An enterprise-wide plan to obtain and consider feedback. This may include:
    • Mechanisms to gather feedback on outcomes of accessibility efforts.
    • Mechanisms to gather feedback from those who are expected to implement the implementation plan and may have to alter their workflow (e.g., staff, technology staff, procurement officers, and human resource staff).
    • A specification that all feedback will be used in a timely manner to improve digital accessibility outcomes and processes.
    • Provisions for utilizing and publicizing feedback data in an ongoing and dynamic way.
  • A plan to monitor the progress of the implementation plan itself. This may specify:
    • Details concerning how the plan will be monitored, such as evaluation of progress towards objectives in the plan over a set duration.
    • Who will do the monitoring.
    • A schedule for when the monitoring will take place.
    • What will be monitored.
  • An explicit strategy to evaluate and revise the plan in an ongoing way. This may include:
    • A stipulation that evaluation and monitoring will continue once initial objectives have been achieved.
    • A strategy for ongoing evaluation at regular intervals to ensure that the organization sustains its accessibility program.
    • Provisions to address changes in technology, standards, and procedures in the future.
    • A plan to use data from regular assessments to revise the current plan and address emerging needs.
    • The personnel who will be responsible for this ongoing evaluation and monitoring.

Benchmark 4: A Comprehensive Communication Plan

When implementing change, organizations must communicate their process, their successes, and continuing challenges to individuals inside and outside the organization. Communication plans should be part of the implementation plan. This way the organization can know when detailed messages should go out, or the best time to send out communications to help motivate staff or award early adopters.

1. An initial plan to communicate that the organization will build an organization-wide accessibility program

Ways to determine if this is present
  • The organization clearly states its rationale for this activity.
  • The organization states the business case for building a program.
  • The organization communicates initial timelines and start-up activities.
  • The organization shares messages with staff to help to foster motivation (i.e., why staff would care at a personal and/or professional level).

2. Ongoing plans to announce the details the effort will take in the organization

Ways to determine if this is present
  • Communicate initial plans over several years.
  • Communicate activities or milestones of the coming year.
  • Share plans for providing role-based training.
  • Share plans to create supports for staff.
  • Communicate ongoing invitations for feedback on the effort.

3. Ongoing plans to provide tips, tricks, and efficiencies for those whose workflow now includes accessibility

Ways to determine if this is present
  • Create and share the how and where staff can stay connected to the initiative and get updates. This might include newsletters, emails, and Slack channel messages on the accessibility initiative.
  • Provide brown-bag or Lunch N Learn experiences where staff can get tips.
  • Create a discussion forum for ongoing issues.

4. Ongoing plans to acknowledge the work of staff as the organization works toward accessibility

Ways to determine if this is present
  • Acknowledgements (e.g., awards, prizes) for the work on accessibility in the organization.
  • Praise by leadership is communicated broadly for activities or tasks completed on accessibility.
  • Badging, micro-credentialing, or other professional acknowledgment for performance (e.g., after completion of training or after submission of accessible content).
  • Inclusion of the work of accessibility as part of annual staff performance evaluations and consideration for promotion.

5. Invitation for feedback

Ways to determine if this is present
  • Presence of emails sent asking for feedback. This could be seeking feedback on the accessibility workflow within the organization, or the accessibility outcomes.
  • Posting of forums (virtual or face to face) to discuss the organization's accessibility program and technical aptitude.
  • Prominent posting of solicitations for feedback on accessibility.

6. Annual reporting on how the effort is going

Ways to determine if this is present
  • A report is submitted and available for review each year.
  • The report contains successes and challenges in both the organizational process for accessibility and the outcome of accessibility (e.g., the outcome of technical website evaluation). It includes any alterations for the coming year.

Benchmark 5: Execute the Written Plans

Once the accessibility policy and plans are in place, leadership and others put that plan into action, ensuring it stays on track by continually monitoring and assessing its progress.

1. Details and documentation that the plan is being implemented

It should be noted that the plan may not contain all the elements below, so all of them may not need to be implemented. All elements presented below provide added support to organizations that have extensive planning documents.

Ways to determine if this is present
  • Meeting minutes of the accessibility team/task force.
  • Documentation of baseline information or reference points.
    • Does collection of the baseline documentation follow (or exceed) what was included in the implementation plan? Information may include:
      • An accessibility audit of a sample of an organization's web pages.
      • An assessment of personnel training in digital accessibility.
      • Reports from human resources or disability support offices on the number of requests from people who need digital accommodations or access.
      • Information on how the organization's work on digital accessibility may relate to broader strategies/challenges/priorities of the organization.
    • Are baseline information or reference points available?
    • Do reports or evaluations provide enough information to be able to measure progress from the baseline?
  • A budget sufficient to support accessibility efforts.
    • Does the allocated budget meet the needs outlined in the implementation plan?
      • Does it cover personnel?
      • Does it cover tools and training?
    • Will this budget help the organization engage in their current phase of digital accessibility efforts (e.g., plan, implement, or sustain)?
  • Committed efforts by leadership and staff to sustain the accessibility program.
    • Are there records or reports on the activities of leadership and staff to show current support for digital accessibility?
    • Are accessibility activities in line with the various responsibilities outlined in the implementation plan or elsewhere?
    • Is there documentation that those tasked with responsibilities are performing their required assignments?
    • Is there information on the effectiveness of these activities?
  • Communication and marketing of the implementation plan across the organization and beyond.
    • If communication and marketing are included in a formal plan, do actions match (or exceed) what is covered in the written plan?
    • Other issues to consider whether communication is included in the written plan or not:
      • Is the implementation plan published and easy to find?
      • Is there evidence that information about the plan is widely disseminated to all relevant parties?
        • Those who will develop and oversee accessibility initiatives.
        • Content developers (i.e., staff).
        • Web designers and developers.
        • Others who will engage in the organization's accessibility work.
        • Consumers of the end product (i.e., those with disabilities).
        • Client-facing personnel, such as those in sales or support, share information with clients, prospective clients.
      • Is information customized for different audiences?
      • Are multiple information streams used to get the communication and marketing messages out (email, newsletters, reports, webpages, social media platforms, etc.)?
      • Is there documentation that the information provided helps the different audiences understand and perform their required tasks?
  • Data on digital accessibility training for personnel.
    • Is the training in line with (or better than) what is prescribed in the implementation plan?
    • Is there evidence (through training dates, personnel involved, or evaluations) that training was offered to differing groups of relevant personnel in line with the plan?
    • Are there measures of the outcome of training efforts? This can include any direct assessment results, earning badges or micro-credentials, or direct evaluation of products created by training participants.
  • Documentation of implementation progress.
    • There is evidence that progress of the implementation plan is tracked. This could be found in reports or other documents including:
      • Implementation reports
      • Metrics and milestone achievements
      • Results from benchmarking tools
      • Adherence to the timeline
      • Marketing and educational communications
      • Improved accessibility in digital products
    • Does it provide an understandable picture of the organization's progress with the plan?
    • Is progress in line with that laid out in the organization's implementation plan?
  • Documentation on the feedback from different levels of implementation.
    • Do feedback collection systems follow (or exceed) those outlined in the implementation plan?
    • Are there feedback systems available for the different stakeholders?
    • Is there documentation that feedback systems are publicized to the appropriate stakeholders?
    • Are these systems effective? Do the users know about the systems?
    • Is there evidence that the systems are used by their stakeholder groups?
    • Is there documentation that the feedback is used to make changes to the plan and to address issues?
  • Indications of actions taken for nonconforming digital products
    • Are there consequences for non-conformance published as part of the policy or plan? Are they widely known?
    • Is there evidence that the organization's digital accessibility policy is enforced?
    • Is non-conformance identified across the organization's web presence?
    • Is there evidence that consequences for non-conformance are consistently upheld and enforced?
      • Are there records of assessments and actions taken?
      • Are assessments and actions taken in line with the implementation plan?
  • Digital accessibility outcome data
    • Is there documentation that outcome data (i.e., the functional accessibility of web properties) has been collected?
      • Is data collection ongoing?
    • Does the collection of data meet (or exceed) that prescribed by the implementation plan?
    • Is the collected data compared to the expected outcomes?
      • Of the organization's policy?
      • Of the technical standard?
      • Of plan milestones?
  • Are the results of the outcome data used to make changes and alleviate issues?