I’m going to consider this from three perspectives:

1. a substantial learning provider that is migrating content to the web wholesale (no policy);
2. an e-learning agency that produces modules for learning and design managers (the policy is the policy of each different client)
3. at the Amateur Swimming Association who have a meaningful relationship with disabled swimmers (a policy toward athletes may not be as supportive and accessible when it comes to their own teachers and coaches).

In due course I’ll consider accessibility in relation to content and resources provided by the Open University whom one would expect to be leader in this field – indeed I believe they are and it is apparent as soon as you look at a page of OU e-learning content compared to the kinds of materials  typically produced for corporate clients. Having worked for or in such organisations I can identify differences and suggest reasons for the decisions taken.

If your organisation does not have a policy, why do you think this might be?

I would like to consider this from the point of view of three learning providers –  a substantial institution akin to the OU, a specialist niche trade association and from the perspective of an agency that creates e-learning.

Does your organisation have someone in a senior position whose job it could be to lead accessibility-related policies and initiatives?

The person responsible ought to be senior, ought to carry influence, have personal knowledge or training in relation to access and accessibility and demonstrate the leadership qualities that come from taking on something new and seeing it through.

Are senior management aware of accessibility issues and simply choosing to ignore them?

People are in love with the cutting edge of e-learning – desiring an advanced look and feel and the smart technology behind tracking personal development, e-assessments and accreditation, rather than standing back and favouring instead something cleaner, simpler, perhaps less fashionable, but more accessible – and potentially easier to scale, adjust and for assistive technology – to read. Effectiveness, cost effectiveness and accessible ought to be priorities rather than gamification, virtual worlds and all encompassing solutions where a smorgasbord of choices and decisions is a better reality.

If there are laws in relation to discrimination that have teeth then no person or institution has yet been taken to court.

Has a decision been made that policies are not the right tool to use to try to change practice?

Agencies will do as asked – issues of accessibility might be raised at the briefing stage and the client will say then to what degree accessibility matters and share how accessibility issues have been addressed in the past in their organisation- usually piecemeal and after the event rather than building accessibility in from the start. No one has consider an approach, whether a policy or a design and technical response. The difficulty faced by an agency pitching in a competitive environment for work is that the market too often favours used of the latest gizmos and the most compelling, potentially award winning design. The policy should be for effectiveness and value for money with a close look at cost effectiveness based on old as well as new media.

If so, how is your organisation communicating to staff any desire or intention relating to accessibility?

Will any individual or group of students be significantly disadvantaged if they are required by their programme or institution to use the proposed system? (Seale 2006:128)

This needs to be at the top of the agenda.

Just like a change in management practice or take over of or by a business communication with people should be thorough, timely and authentic. If attitudes have to be changed, developed or refreshed the effort will be all the greater. This requires commitment and resources from the top and engagement of people familiar with such exercises.

How might you improve on accessibility-related policies that exist in your organisation?

1) Find a champion and a leader – if necessary two different people.
2) Get disabled students involved in deciding and advising on policy based on their experiences
3) Know the legal position and comply – tie in with ISO and Plain English policy and compliance (best practice).
4) Organisations have to mean it and be professional about it
5) TEAM WORK
6) Purchasing decisions
7) Benchmark accessibility

CHAMPION

1) There has to be someone to champion the cause, needs, benefits and legal requirements of accessibility. This person needs leadership qualities – informed, persuasive, by example, with authority, credibility and presence. Seale (2006:128) suggests that supportive managers with a positive attitude are need, people with previous experience of supporting students with disabilities. Seale (2006:128)
Accessibility implementation needs to be actively managed (Lamshed et al. 2003) Seale (2006:128)

• ensuring that the accessibility of e-learning material and resources is monitored and audited (see Seale (2006 chapter 7)
• ensuring that there is ‘joined up’ thinking between the different specialist and mainstream learning support services within an institution (see Seale 2006 chapter 8)
• ensuring that staff development opportunities are strategically targeted to raise awareness and that staff are able to respond to accessibility requirements (see Seale 2006 chapter 9)
• developing and implementing procurement procedures to ensure accessibility of future technology purchases;developing and implementing institutional accessibility policies.

USER GROUP ENGAGEMENT

2) Talk to and engage with end users – be proactive, learning to accommodate and work with the broadest church or representative disabled students.

From US. (Oregon) Accommodations in postsecondary education are governed by Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 (ADA).
Students with a documented disability have a right to receive reasonable accommodations. Additionally students have responsibilities which include:

1. Providing the DAS office with appropriate documentation
2. Responding to requests for information
3. Scheduling and completing a required DAS orientation
4. Making requests for accommodations according to the DAS Timeline for Service Requests before and during each term of attendance
5. Following the policies and procedures which are available in the DAS Student Handbook

KNOW THE LEGAL POSITION

3) The legalese must be understood – ignorance of the law is no excuse – ideally a legal advisor will inform the CEO and Board, or trustees should seek advice and exirt pressure – that or responding to demands from society and individual campaigns. People need to believe that an organisation could be taken to court for failure to comply to accessibility legislation. Compliance. Level Double-A Conformance to Web Content Accessibility Guidelines 1.0 http://www.w3.org/WAI/WCAG1AA-Conformance

Comply with the Disability Discrimination Act 1995 Part Four (as amended by Special Educational Needs Disability Act 2001) and the Disability Discrimination Act 2005. All of the Priority 1, 2 and 3 accessibility checkpoints across websites, as established in the World Wide Web Consortium’s (W3C) Web Accessibility Initiative (WAI). The WAI promotes a high degree of usability and accessibility for people with disabilities.

It is possible that some of our older pages (those not within our new visual identity) might not currently conform to these standards. However, we are actively engaging with our website team to ensure that all future web pages are compliant with W3C guidelines for accessibility.

Like compliance to IS0 9000 and 9001

http://www.praxiom.com/iso-intro.htm

And PLAIN ENGLISH CAMPAIGN

http://www.plainenglish.co.uk/awards.html

CLOUT

4). Purchasing decisions need to take accessibility into consideration – so someone with control on budgets needs to have a say. All new purchases of learning management systems, courseware and networked equipment is accessible (Rowland 2000; McCarthy 2001). He who pays the piper, plays the tune.

MISSION STATEMENT

5). Some organisations could or do put issues into their mission statement or reflect specific brand values – just as companies have ‘gone green’, so too they ought to be looking at both accessibility and equality as part of their corporate and social responsibility mix.  Anderson (2004) argues that practice will only change if the policy is actively implemented:Developing campus Web accessibility policies, guidelines or standards is often thought of as a way to meet legal obligation, however, implementing Web accessibility policies can be a means for creating a campus e-culture of inclusion. While developing a policy has numerous challenges – implementing, supporting and updating a Web accessibility policy is where the rubber hits the road and separates those who succeed in Web accessibility efforts and those who have a policy. (Anderson 2004)

• embedding accessibility across all institutional activities and systems, from procurement to student support services;
• addressing whether and how the development of an institutional accessibility policy will encourage such embedment;
• identifying a team of key stakeholders, across the whole institution (and not just specialist disability services) who are willing and able to work towards embedment.

This may or may not be a ‘tall order’ (Wilson et al. 2002: 20), but without leadership from managers the task will not get any ‘smaller’.

TEAM WORK

6). It is a grave error to make access the responsibility of one person – and the cliche is to give the role of ‘Disability Officer’ to the one person in a wheelchair. Rather to be effective an ‘action team’ needs to be created so that from across the organisations there are partnerships with a range of representative stakeholders. it must be both a collaborative and a team effort.

Byrne (2004) suggests that in setting up a ‘Web Accessibility Policy and Planning Group’ the following stakeholders (among others) should be included: management, student representatives, disabled students, administrators, web designers, lecturers and learning support staff.

• involve all stakeholders, including top-level support (Burgstahler 2002a; Smith and Lyman 2005);
• organize an accessibility committee (Smith and Lymann 2005; Hriko 2003; Byrne 2004);
• provide training and technical support (Smith and Lyman 2005; Burgstahler 2002a; Brewer and Horton 2002);
• promote institutional awareness (Burgstahler 2002a; Brewer and Horton 2002);
• evaluate progress towards accessibility (Smith and Lyman 2005; Burgstahler 2002a; Brewer and Horton 2002).

MEAN IT

7). Organisations have to mean it – not pay lip service, but set SMART goals, adhere to plans, be open with failings and strive to make things better. Whilst mission statements and guidelines are a move in the right direction, they will not necessarily ensure or mandate that practice changes. In order to ensure accessibility, policies need to be specific, detailed and directive.

i.e. SMART goals

Specific
Measurable
Attainable
Relevant
Time Bound

Advice from a number of accessibility advocates would suggest that accessibility policies need to:

• define the scope of the policy (Johnson et al. 2003; Brewer 2002);
• delineate a specific and official technical standard (Johnson et al. 2003; Bohman 2003d; Brewer 2002; Smith and Lyman 2005);
• indicate whether compliance is required (Bohman 2003d);
• indicate a timeline or deadline for compliance (Bohman 2003d; Brewer 2002);
• define a system for evaluating or monitoring compliance (Bohman 2003d; Brewer 2002; Smith and Lyman 2005);

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• indicate any consequences for failure to comply with policy (Bohman 2003d).

Seale (2006:131)

BENCHMARK

8). Benchmark accessibility annually and raise the bar each year too, with comparisons tolike institutions – are we doing better or worse – and particular with those those organisations the ‘action team’ admire for what they are doing or have achieved. A useful exercise would be to look at the history of adoption of access in the physical world, the debates, legislation and practices. Change to be done appropriately and to be permanent takes time.

Develop the view that making accommodations for students with disabilities forms part of the institution’s engagement with learning technologies, can provide efficiencies and improve business agility and performance.

REVIEW – Visitors using the centre are taken through a structured questionnaire that enables them to review their learning practices and compare their level of performance against evolving good practice.

COMPARE – Three key performance indicators above.

ACT – Once you have identified where you can improve , the centre contains over 200 resources to help you take action in your business.

TOWARDS MATURITY (2012)
http://www.towardsmaturity.org/static/towards-maturity-benchmark-centre/

If none exist, what might you include in any new accessibility-related policy within an organisation?

It would be an interesting activity to hold a meeting and hand out books pertaining to contain text that are blank, to be handed a laptop on which all the keys have been glued down, a radio that scrambles the audio.

Design with Assistive Technology (AT) in mind. ‘As technology evolves, Assistive Technology (AT) often becomes outdated, leaving developers scrambling to produce new forms of AT to “catch-up” to IT. In the meantime, individuals relying on AT are left with obsolete equipment and consequently, reduced access to information and services. Although AT does catch up, inevitably, the accessibility cycle repeats itself as technology is too often developed with little or no thought to accessibility’. KATSEVA (2004)

‘Typically, technology is designed for functionality from the outset and made accessible only after-the-fact, either with AT or with retrofitting. This process excludes those for whom access to information and services is already difficult, as well as being terribly inefficient and costly. This process is akin to building a house without the electrical infrastructure, only to have each room wired individually, as new appliances are purchased’. KATSEVA (2004)

Does your organisation have other policies that should refer to accessibility?

If so, do they refer to it? If not, in what ways should they refer to it? Kelly et al. (2004) note that IT Service departments usually aim to provide a secure, robust managed environment, which may conflict with the flexibility many end users would like. (Seale 2006:128) The same is likely to occur with the strict adherence to web accessibility policies. There will need to be a compromise. The IT department, as they are used to managing and even policing IT should perhaps become the guardians of accessibility policy too as it would impact on design and programmining choices.

Who are the key people who have a role in managing accessibility in your organisation?

What helps or hinders them working together on accessibility-related issues?

Leading an institution’s response increases the visibility of accessibility as an issue, makes it easier to dedicate the necessary resources to the issue and makes the monitoring of compliance more of a probability (WebAim n.d.b).

At Cranfield University, we try to ensure that our services, products and facilities are available to all – irrespective of any disability. This applies to our website, too. Our website has been built following expert disability advice. (http://www.cranfield.ac.uk/ prospectus/ note.cfm) SEE APPENDIX 6

Oregon State University provides on its website a set of general web accessibility guidelines:

The universal access to information is a part of the University’s ongoing commitment to establishing a barrier free learning community at Oregon State. These guidelines have been established as a part of this commitment, and to meet the ethical and legal obligations that we have under The Americans with Disabilities Act, The Telecommunications Act of 1996, and The Rehabilitation Act of 1973, as amended.

The Oregon State policy has been replaced by Disability Access Services Mission and Goals, http://ds.oregonstate.edu/ about/mission.php (last accessed 24 May 2012).

Integration not segregation

Given that many advocates argue against ‘add-on’ specialist services that segregate people and issues from the mainstream, there would seem to be merit in considering whether accessibility should be integrated into existing policies or whether existing policies can be applied to e-learning accessibility.

Using this argument, perhaps accessibility should be embedded into a range of policies and strategies including: e-learning strategies; teaching and learning strategies; non-discrimination policies; inclusion policies; widening participation policies and learning resources policies.

FURTHER LINKS

Web Accessibility Initiative (WAI) Guidelines
http://www.w3.org/WAI/guid-tech.html

REFERENCE

Anderson, A. (2004) Supporting web accessibility policies: creating a campus e-culture of inclusion at UW-Madison. Paper presented at CSUN ’04. Online. Available HTTP: <http://www.csun.edu/ cod/ conf/ 2004/ proceedings/ 20.htm> (last accessed 23 May 2012).

Burgstahler, S., Corrigan, B. and McCarter, J. (2004) Making distance learning courses accessible to students and instructors with disabilities: a case study. Internet and Higher Education, 7, 233–246.

Byrne, J. (2004) An example: UK university accessible web design plan. Online. Available HTTP: <http://www.mcu.org.uk/show.php?contentid=85&gt; (accessed 5 October 2005 but no longer available).

Katseva, A. (2004) The case for pervasive accessibility. Paper presented at CSUN ’04. Online. Available HTTP: <http://www.csun.edu/ cod/conf/ 2004/ proceedings/ 114.htm> (last accessed 23 May 2012).

Lamshed, R., Berry, M. and Armstrong, L. (2003) Keys to access: accessibility conformance in VET. Online. Available HTTP: <http://www.flexiblelearning.net.au/ projects/ resources/ accessibility-conformance.doc> (last accessed 23 May 2012).

Tinklin, T., Riddell, S. and Wilson, A. (2004) Policy and provision for disabled students in higher education in Scotland and England: the current state of play. Studies in Higher Education, 29, 5, 637–657.

TOWARDS MATURITY (2012) http://www.towardsmaturity.org/static/towards-maturity-benchmark-centre/

WebAIM. (n.d.b) The important of leadership. If not you, who? Online. Available HTTP: . (Now available at http://www.webaim.org/ articles/imp_of_leadership/, last accessed 23 May 2012.)

Wilson, A., Ridell, S. and Tinklin, T. (2002) Disabled students in higher education. Finding from key informant interviews. Online. Available HTTP: (accessed 5 October 2005 but no longer available).