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From: Christopher Phillips
Date: Wed, Mar 30 2022 2:03PM
Subject: Accessibility a external content
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Hello everyone -“
I am stuck in a discussion around some accessibility policy that we are working and would be grateful for any feedback any of you might have around accessibility standards for external content.

Clearly any links or embeds need to be provided in an accessible way, but my question is more around the accessibility of that external content and considerations around linking to or embedding content that isn't accessible. Sometimes we can impact external content to make it more accessible (e.g. we can wrap our own captions around an uncaptioned video), but my question is around content where doing so isn't possible.

Generally we are more concerned about the content/experiences we manage and less concerned with external content that we link to or share, but there are some nuances that we are wrestling with:


1. Is there a meaningful difference between linking to external content (website, document or video) or embedding external content? For example, consider 3 uncaptioned YouTube videos on a page you own – a) a link, b) an embedded video on a channel you own, or c) an embedded video on a channel you don't own. Would treat any of those differently from others from a compliance perspective?
2. Or perhaps the way something is shared (embedded or linked) is less relevantand we should be looking more at how important or essential the content is to determine of it can be linked to or embedded?

We are also aware that policy decisions may impact some behavior – for example, if we were to require captions on embedded videos but not linked videos – people may decide to link to an uncaptioned 3rd party video rather than embed it even if embedding it would provide a better user experience.

Any feedback or experience is appreciated!

--
Christopher Phillips
Electronic and Information Technology Accessibility Coordinator
Center for Innovative Design and Instruction
Utah State University
https://www.usu.edu/accessibility/
435-797-5535

From: Cyndi Rowland
Date: Wed, Mar 30 2022 2:24PM
Subject: Re: Accessibility a external content
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Hi Christopher,
My experience is that from a compliance perspective it is all covered, as I assume your question to be on instructional content. If there is instructional content that is not needed, why would it be provided? Even if it were not instructional in nature, you probably do not have to go far to realize those videos may be covered because their use would be covered as a Place of Public Accommodation under ADA.
Certainly, there are solutions to this, including skins that can be used. But I think the best by far is to reach out to the author and ask them if they might caption it so that all can enjoy their content. I do assume that searches for captioned videos of the same content would have already occurred in case there are multiple instances of the same content, some with captions. If you do end up creating the captions, hopefully, you extend the text file to the author so they have an easier time making a captioned instance of their own content, and hopefully, they are a bit more aware of their need to do so in the future.
Cyndi

----------------------------------
[Utah State University]
Cyndi Rowland, Ph.D.
(she/her/hers)
Executive Director
WebAIM; National Center on Disability and Access to Education;
Institute on Disability Research, Policy, and Practice
Office: (435) 797-3381 | Mobile: (435) 760-2691
WebAIM at Utah State University<https://WebAIM.org>

From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Christopher Phillips < = EMAIL ADDRESS REMOVED = >
Sent: Wednesday, March 30, 2022 1:03 PM
To: = EMAIL ADDRESS REMOVED = < = EMAIL ADDRESS REMOVED = >
Subject: [WebAIM] Accessibility a external content

Hello everyone –
I am stuck in a discussion around some accessibility policy that we are working and would be grateful for any feedback any of you might have around accessibility standards for external content.

Clearly any links or embeds need to be provided in an accessible way, but my question is more around the accessibility of that external content and considerations around linking to or embedding content that isn't accessible. Sometimes we can impact external content to make it more accessible (e.g. we can wrap our own captions around an uncaptioned video), but my question is around content where doing so isn't possible.

Generally we are more concerned about the content/experiences we manage and less concerned with external content that we link to or share, but there are some nuances that we are wrestling with:


1. Is there a meaningful difference between linking to external content (website, document or video) or embedding external content? For example, consider 3 uncaptioned YouTube videos on a page you own – a) a link, b) an embedded video on a channel you own, or c) an embedded video on a channel you don't own. Would treat any of those differently from others from a compliance perspective?
2. Or perhaps the way something is shared (embedded or linked) is less relevantand we should be looking more at how important or essential the content is to determine of it can be linked to or embedded?

We are also aware that policy decisions may impact some behavior – for example, if we were to require captions on embedded videos but not linked videos – people may decide to link to an uncaptioned 3rd party video rather than embed it even if embedding it would provide a better user experience.

Any feedback or experience is appreciated!

--
Christopher Phillips
Electronic and Information Technology Accessibility Coordinator
Center for Innovative Design and Instruction
Utah State University
https://www.usu.edu/accessibility/
435-797-5535

From: glen walker
Date: Wed, Mar 30 2022 2:55PM
Subject: Re: Accessibility a external content
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From a CYA perspective, I've seen lots of companies link to external
content and have a confirmation dialog popup that says "you are leaving our
site, we don't know how accessible the site you're going to is", or
something like that.

It gets tricky when you embed content. Technically, the entire page must
conform, including embedded content, in order to say the page conforms.
There's a note about embedded content in the conformance section of WCAG.

https://www.w3.org/TR/WCAG21/#h-note-31

It essentially says you can claim "partial" conformance if embedded content
is not accessible. I'm not sure what "partial" conformance means when it
comes to the legal aspect. If you have a 100% conformant site except for
the embedded content, can you be sued? Given that anyone can be sued at
any time for any reason, the answer is likely "yes". Would the lawsuit
hold up in court or would it be dismissed. I think only a judge could
answer that.

From a VPAT perspective, you can claim "supports" for any content that you
create that is conformant and "partially supports" or "does not support"
for content that is not conformant. So, for example, if you have videos
that you create yourself and they are captioned and transcripted, but you
also have embedded video content from others that is not captioned, you'd
claim "partially supports" in the VPAT (because some videos conform and
some do not). If you don't have any videos that you create yourself and
the only videos come from embedded content and they're not captioned, then
it would be "does not support" because there aren't any videos that have
captioning.

From a UX perspective, embedded content is usually a better experience.
From a conformance or legal perspective, whether you should have embedded
content is a hard question to answer. Lots of factors come into play. How
risk averse are you? How accessible is the content? Is the content
provider amenable to accessibility concerns/suggestions. Is the content
totally out of the content providers control such as author driven
content? Does the content provider follow ATAG for the authoring content?

From: Jeff Kline
Date: Wed, Mar 30 2022 2:56PM
Subject: Re: Accessibility a external content
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So, I have a slightly different perspective. If you are linking out to something that is considered “official business“ related to your agency or company, then you would have some responsibility, or may be a lot of responsibility to be sure it is accessible. Linking out to more random or suggested content that is not considered “official business“ should not make your agency or company accountable for the Accessibility of the Content. The platform being linked to, also has some responsibility, such as captioning. A lot of media has auto caption which is an always great



Jeff

> On Mar 30, 2022, at 3:24 PM, Cyndi Rowland < = EMAIL ADDRESS REMOVED = > wrote:
>
> Hi Christopher,
> My experience is that from a compliance perspective it is all covered, as I assume your question to be on instructional content. If there is instructional content that is not needed, why would it be provided? Even if it were not instructional in nature, you probably do not have to go far to realize those videos may be covered because their use would be covered as a Place of Public Accommodation under ADA.
> Certainly, there are solutions to this, including skins that can be used. But I think the best by far is to reach out to the author and ask them if they might caption it so that all can enjoy their content. I do assume that searches for captioned videos of the same content would have already occurred in case there are multiple instances of the same content, some with captions. If you do end up creating the captions, hopefully, you extend the text file to the author so they have an easier time making a captioned instance of their own content, and hopefully, they are a bit more aware of their need to do so in the future.
> Cyndi
>
> ----------------------------------
> [Utah State University]
> Cyndi Rowland, Ph.D.
> (she/her/hers)
> Executive Director
> WebAIM; National Center on Disability and Access to Education;
> Institute on Disability Research, Policy, and Practice
> Office: (435) 797-3381 | Mobile: (435) 760-2691
> WebAIM at Utah State University<https://WebAIM.org>
>
> > From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Christopher Phillips < = EMAIL ADDRESS REMOVED = >
> Sent: Wednesday, March 30, 2022 1:03 PM
> To: = EMAIL ADDRESS REMOVED = < = EMAIL ADDRESS REMOVED = >
> Subject: [WebAIM] Accessibility a external content
>
> Hello everyone –
> I am stuck in a discussion around some accessibility policy that we are working and would be grateful for any feedback any of you might have around accessibility standards for external content.
>
> Clearly any links or embeds need to be provided in an accessible way, but my question is more around the accessibility of that external content and considerations around linking to or embedding content that isn't accessible. Sometimes we can impact external content to make it more accessible (e.g. we can wrap our own captions around an uncaptioned video), but my question is around content where doing so isn't possible.
>
> Generally we are more concerned about the content/experiences we manage and less concerned with external content that we link to or share, but there are some nuances that we are wrestling with:
>
>
> 1. Is there a meaningful difference between linking to external content (website, document or video) or embedding external content? For example, consider 3 uncaptioned YouTube videos on a page you own – a) a link, b) an embedded video on a channel you own, or c) an embedded video on a channel you don't own. Would treat any of those differently from others from a compliance perspective?
> 2. Or perhaps the way something is shared (embedded or linked) is less relevantand we should be looking more at how important or essential the content is to determine of it can be linked to or embedded?
>
> We are also aware that policy decisions may impact some behavior – for example, if we were to require captions on embedded videos but not linked videos – people may decide to link to an uncaptioned 3rd party video rather than embed it even if embedding it would provide a better user experience.
>
> Any feedback or experience is appreciated!
>
> --
> Christopher Phillips
> Electronic and Information Technology Accessibility Coordinator
> Center for Innovative Design and Instruction
> Utah State University
> https://www.usu.edu/accessibility/
> 435-797-5535
>
> > > > > > > >

From: Christopher Phillips
Date: Wed, Mar 30 2022 3:26PM
Subject: Re: Accessibility a external content
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Thank you for the responses -

Cyndi-“ I am actually referring more to public content in this case. For instructional content behind a login, I feel like we have a little more liberty to creatively "reuse" the content to make it more accessible. When you say "it is all covered" are you saying that all external websites, files or videos external content that we link to or a website has to be accessible in order for that site to be considered accessible?

We have attempted to reach out to the owners of YouTube channels after we have captioned their content, but the response rate we have received is very low. While the wrapper option works for videos on some platforms, that option isn't available for some videos. So the discussion for video at least would be what to do about uncaptioned video content that is important to a department to post where we don't have the ability to caption the content and the owner is nonresponsive.

Glen – thank you for that link. While CYA is a factor, the primary concern is around encouraging accessible experiences and figuring out where to draw the line to acknowledge that something is outside of our control and what we do in those situations. I hadn't noted the definition of a Web page on that page (https://www.w3.org/TR/WCAG21/#dfn-web-page-s ) that says "A Web resource including all embedded images and media" that I read as draw a distinction of considering content embedded on a page being different from external content linked to on a page. Your comments on the UX perspective and questions you asked are super helpful - we don't want to setup a standard that would encourage people to use a less usable experience (link to a video instead of embedding a video) to avoid a requirement of embedded videos requiring captions.

Jeff - I agree that consider the importance of the content should be considered as well - figuring out a way to have more stringent requirements for more essential information makes sense.

Much appreciated,

--
Christopher Phillips
Electronic and Information Technology Accessibility Coordinator
Center for Innovative Design and Instruction
Utah State University
435-797-5535

From: Hayman, Douglass
Date: Wed, Mar 30 2022 4:24PM
Subject: Re: - Accessibility a external content
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Christopher,

I too have had little success with reaching out to the owners of other YouTube channels for the same goals.

In my ideal accessibility world, once professional captions had been made for a video hosted on YouTube there should be a mechanism to get those associated with the video. I can see no good reason why captions done by 3Play Media, AST or others of that caliber would not then get linked so that all subsequent viewers of that video could have a more accessible experience.

My attempts to have that conversation with 3Play Media got a reply at Accessing Higher Ground along the lines of "YouTube wants to honor the artistic blah, blah, blah of their users integrity, more blah, blah, blah."

So I tried to find a real human associated with YouTube accessibility, which was like finding a unicorn. And again through a few channels suggested this idea of having some means of telling a channel owner, "Hi. Professional closed captions have been created for your video. Would you like to toggle those as the default? There is no charge to you and this will lead to a more accessible experience for your viewers and it will aid search engines in finding your content." The person I reached at YouTube through a computer scientist he knows got no interest in pursuing this.

Instead we in higher education and elsewhere probably pay to caption the same videos on other people's channels again and again and play those through skins to give our users access, the caption firms make more money, and the YouTube accessibility experience is not as good as it could be.

I'll step off of my soapbox for now but haven't given up on this idea.

Doug Hayman
IT Accessibility Coordinator
Information Technology
Olympic College
= EMAIL ADDRESS REMOVED =
(360) 475-7632

From: chagnon
Date: Wed, Mar 30 2022 9:01PM
Subject: Re: - Accessibility a external content
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Doug wrote:
Quote: ... the caption firms make more money ... End Quote.

And so does YouTube and everyone else in the food chain — Except those of us mandated to meet accessibility and education laws.

The crux of the problem: now that most of our industry is owned by private investment firms, their main question is how can I make more money out of this? Doing something good for society or because it helps the majority with little cost, isn't on their radar.

Our little industry is now viewed as a commodity to be exploited.

— — —
Bevi Chagnon | Designer, Accessibility Technician | = EMAIL ADDRESS REMOVED =
— — —
PubCom: Technologists for Accessible Design + Publishing
consulting ' training ' development ' design ' sec. 508 services
Upcoming classes at www.PubCom.com/classes
— — —
Latest blog-newsletter – Simple Guide to Writing Alt-Text

From: Tom Livingston
Date: Thu, Mar 31 2022 6:46AM
Subject: Re: -Accessibility a external content
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I may be way off base here as I am just getting into the weeds with a
lot of this but would requesting a VPAT from the third-party be of
benefit? Either as documentation for you or even prompting the third
party to care more?



>
> Christopher,
>
> I too have had little success with reaching out to the owners of other YouTube channels for the same goals.
>
> In my ideal accessibility world, once professional captions had been made for a video hosted on YouTube there should be a mechanism to get those associated with the video. I can see no good reason why captions done by 3Play Media, AST or others of that caliber would not then get linked so that all subsequent viewers of that video could have a more accessible experience.
>
> My attempts to have that conversation with 3Play Media got a reply at Accessing Higher Ground along the lines of "YouTube wants to honor the artistic blah, blah, blah of their users integrity, more blah, blah, blah."
>
> So I tried to find a real human associated with YouTube accessibility, which was like finding a unicorn. And again through a few channels suggested this idea of having some means of telling a channel owner, "Hi. Professional closed captions have been created for your video. Would you like to toggle those as the default? There is no charge to you and this will lead to a more accessible experience for your viewers and it will aid search engines in finding your content." The person I reached at YouTube through a computer scientist he knows got no interest in pursuing this.
>
> Instead we in higher education and elsewhere probably pay to caption the same videos on other people's channels again and again and play those through skins to give our users access, the caption firms make more money, and the YouTube accessibility experience is not as good as it could be.
>
> I'll step off of my soapbox for now but haven't given up on this idea.
>
> Doug Hayman
> IT Accessibility Coordinator
> Information Technology
> Olympic College
> = EMAIL ADDRESS REMOVED =
> (360) 475-7632


--

Tom Livingston | Senior Front End Developer | Media Logic |
ph: 518.456.3015x231 | fx: 518.456.4279 | medialogic.com


#663399

From: Jerra Strong
Date: Tue, Apr 12 2022 3:42PM
Subject: Re: -Accessibility a external content
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Doug,

Great idea, and making it easier for creators to get their content
captioned would be great, though some are shy after having bad experiences
with the "community captions" on YT. I will say, a third-party vendor,
Amara, does do an interesting job of storing captions for YouTube videos
that can be viewed by subsequent users, and our organization has found
videos we were thinking about captioning professionally already had
captions stored in Amara. So it is bridging this gap somewhat. Figured I
would mention this if you hadn't heard about it.

On Thu, Mar 31, 2022 at 5:47 AM Tom Livingston < = EMAIL ADDRESS REMOVED = > wrote:

> I may be way off base here as I am just getting into the weeds with a
> lot of this but would requesting a VPAT from the third-party be of
> benefit? Either as documentation for you or even prompting the third
> party to care more?
>
>
>
> >
> > Christopher,
> >
> > I too have had little success with reaching out to the owners of other
> YouTube channels for the same goals.
> >
> > In my ideal accessibility world, once professional captions had been
> made for a video hosted on YouTube there should be a mechanism to get those
> associated with the video. I can see no good reason why captions done by
> 3Play Media, AST or others of that caliber would not then get linked so
> that all subsequent viewers of that video could have a more accessible
> experience.
> >
> > My attempts to have that conversation with 3Play Media got a reply at
> Accessing Higher Ground along the lines of "YouTube wants to honor the
> artistic blah, blah, blah of their users integrity, more blah, blah, blah."
> >
> > So I tried to find a real human associated with YouTube accessibility,
> which was like finding a unicorn. And again through a few channels
> suggested this idea of having some means of telling a channel owner, "Hi.
> Professional closed captions have been created for your video. Would you
> like to toggle those as the default? There is no charge to you and this
> will lead to a more accessible experience for your viewers and it will aid
> search engines in finding your content." The person I reached at YouTube
> through a computer scientist he knows got no interest in pursuing this.
> >
> > Instead we in higher education and elsewhere probably pay to caption the
> same videos on other people's channels again and again and play those
> through skins to give our users access, the caption firms make more money,
> and the YouTube accessibility experience is not as good as it could be.
> >
> > I'll step off of my soapbox for now but haven't given up on this idea.
> >
> > Doug Hayman
> > IT Accessibility Coordinator
> > Information Technology
> > Olympic College
> > = EMAIL ADDRESS REMOVED =
> > (360) 475-7632
>
>
> --
>
> Tom Livingston | Senior Front End Developer | Media Logic |
> ph: 518.456.3015x231 | fx: 518.456.4279 | medialogic.com
>
>
> #663399
> > > > >