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During a recent AODA training session that I conducted, it became apparent that most organizations represented at the session had taken steps to meet their obligations under the Customer Service Standard and were now preparing for the next stage of compliance under the Integrated Accessibility Standards (IAS), dealing with employment, information and communication and transportation. As a result, I noted that several of the participants shared similar concerns relating to the standards, specifically the manner in which they are being enforced and the requirement of accessible web content.
Although the AODA relies on self-reporting of compliance with its standards, the Act also outlines a number of tools that are available to ensure compliance, including audits, inspections, orders and fines. One attendee provided some information about the experience of her organization being audited. She indicated that the organization received a letter from the Ministry advising them that they were being audited and asking them to provide documentation that confirmed the language of their policies and the content of their training programs. The request was highly specific, and highlighted the need to ensure that your organization’s policies are sufficiently detailed and address all the requirements of the Standard. The request also reinforced the need to not only develop and deliver an effective training program, but to document that program should your organization be called on to account for the steps that you have taken.
For several people in attendance, the most challenging requirement of the IAS for them to understand and address is the requirement relating to accessible web content because they are not IT specialists and the language can seem quite foreign. The IAS requires that by January 1, 2014, public or private sector organizations with 50 or more employees must ensure that any new website or web content must conform to Web Content Accessibility Guidelines 2.0 Level A, and by January 1, 2021, all content and sites must conform to WCAG 2.0 Level AA. Although the January 1, 2014 deadline applies only to new content and websites, organization may also want to consider whether making their content retroactively accessible is a best practice they wish to implement.
I spoke to Nathan Allen, of NetGain, a specialist in web design & development, who suggested that the first step towards compliance for an organization is to conduct a review of their existing website to determine whether there are portions of their site that are already compliant with the requirements of the AODA. Mr. Allen identified some website features that are necessary to meet the guidelines, such as the ability to change font size or the presence of alt attributes for images on the site. A complete checklist can be found here: http://www.w3.org/WAI/WCAG20/quickref/. Although conducting such a review is likely outside the scope of many HR professionals, an in-house or external specialist should be able to review the content of the website and identify whether the specific features required under WCAG 2.0 Level A are present.
Where a website has compliance gaps, Mr. Allen suggested that a plan be developed by the organization in order to bring their site into compliance. In some instances, this may involve updating an existing website while in other cases it may be necessary, or more cost-effective, to redesign an accessible website from scratch.
If you are tasked with ensuring that your organization is AODA compliant and you are not an IT expert, it is important that you consult with someone who is, whether that’s your IT department or an external consultant. Should your website require a complete rebuild in order to allow new content on the site to be accessible, you will want to ensure you get started right away, as the January 1, 2014 deadline will come sooner than you think.