Accessible Information Policy
Implementation Report (2014-15)
Trinity College Dublin, the University of Dublin
Report prepared by the Disability Service, May 2015
Table of Contents
1. Executive Summary………………………………………………………………………………………………………………………………..3
2. Report4
2.1 Print Communication………………………………………………………………………………………………………………………..4
2.2 Web Accessibility5
2.3 E-Learning…………………………………………………………………………………………………………………………………………6
2.4 Person to Person Communication…………………………………………………………………………………………………….9
2.5 Information Technology Procurement……………………………………………………………………………………………10
2.6 Organised Events……………………………………………………………………………………………………………………………11
2.7 Conclusions…………………………………………………………………………………………………………………………………….13
3. Appendices………………………………………………………………………………………………………………………………………….16
1. Executive Summary
The Trinity Accessible Information Policy highlights Trinity’s requirements in relation to the Disability Act (2005), the Universities Act (1997), the Employment Equality Act (1998, as amended) and the Equal Status Acts (2000, as amended). Trinity’s Disability Service (DS) was delegated responsibility by the Provost when the Disability Act 2005 applied to public bodies such as Trinity in 2007. Trinity’s Accessible Information Policy addresses the following areas:
· Print communication
· College web accessibility
· e-Learning accessibility
· Person to person communication
· Information Technology procurement
· College organised events
The DS is responsible for reporting to the Equality Committee and Board on Trinity’s compliance with this policy and this report details work undertaken in academic year 2014-15. The Trinity Audit Committee via the College Risk Register continues to note non-compliance with this policy, stating:
1247.5.1 Non –compliance with the accessible information policy and legislative requirements and action taken immediately
1247.6.1 Following the poor response to the Trinity Inclusive Curricula evaluation programme and ceasing of funding, a Project sponsor, at a senior academic level, should be considered for future projects to encourage buy in to the project to increase uptake in the initiative.
In addition the recent external Quality Review of the Disability Service raised significant concern in regard to Disability policy and implementation and recommendation two in the review of the Disability Service states:
Senior managers should support the DS by championing relevant disability related policies, including the use of Blackboard VLE in advance of lectures, and where possible to provide notes or video capture of the lectures. The College should ensure that all academic staff follow and abide by the Trinity Inclusive Curriculum (TIC). Robust implementation of disability policy – the reviewers consistently reference the significant legal risks associated with the lack of consistency of application of these policies.
It is recommended that the Trinity Accessible Information Policy is consumed in the revised Trinity Equality Policy along with a clear implementation plan with reporting annually from all areas (academic and administrative) on progress through this key Trinity policy.
In addition this report focusses on the following areas in particular: print communication (2.1), web accessibility (2.2), e-Learning accessibility (2.3), person to person communication (2.4), Information Technology procurement (2.5) and college organised events (2.6). The report outlines the Disability Service’s actions with regard to the Accessibility Information Policy and outlines the areas that require increased college ownership.
2. Trinity Disability Service - Accessible Information Policy
Implementation Report – Year 2014-15
This report highlights work undertaken by the Disability Service in academic year 2014-15 to the Equality Committee with regard to the implementation of the Trinity Accessible Information Policy (www.tcd.ie/about/policies/accessible-info-policy.php). This policy highlights Trinity’s requirements in relation to the Disability Act (2005), the Universities Act (1997), the Employment Equality Act (1998 as amended) and the Equal Status Acts (2000 as amended).
2.1 Print Communication
Section 28 of the Disability Act states:
Access to Information (Section 28 Disability Act)
"As far as practicable", such information is transmitted or published in a format that is compatible with adaptive technologies used by visually impaired people.”
Activities:
a. Accessible Information Training:
In January 2015, the Disability Service ran a series of training events for the staff of Trinity in order to communicate their responsibilities under the accessible information policy (appendix A – list of attendees). The event was open to all staff and academics to attend and was publicized to all school administrators/academic liaison officers and executive officers within administrative areas. The topics covered included:
1. Microsoft Word 2010 & 2013
2. Microsoft PowerPoint 2010 & 2013
3. Adobe Acrobat Reader & Adobe Acrobat Professional
4. Web accessibility via Dreamweaver
5. Accessible e-mail formats
6. Use of the TIC tool
7. Use of CAPSL/Disability Service online resources
The session focused on giving a basic understanding to university staff of their responsibilities with regards to the provision of accessible information in both print and electronic format. Good practice was demonstrated through examples, and formatting tools were demonstrated to highlight how quickly information can be made accessible to all users without the need for advanced accessibility training.
In addition, the Trinity Inclusive Curriculum (TIC) self-assessment tool http://www.tcd.ie/CAPSL/TIC/evaluation/ was demonstrated to support staff as an aid to identifying good practice in the creation of print communication. Attendees were advised to engage with the tool and promote it among their staff as a step to implementing the policy guidelines.
Actions: The Disability Service will continue to support end-users with advice and group training sessions to ensure clear understanding on the creation of print communication. The Disability Service to engage with CAPSL on identifying support and training avenues, and communicating to new academic staff their responsibilities in relation to the accessible information policy.
2.2 Web accessibility
The accessible information policy states:
Trinity websites must meet a minimum of W3C Level 2 compliance in line with the Web Accessibility guidelines (WCAG 1.0). (https://www.tcd.ie/about/policies/accessible-info-policy.php)
The Trinity web office own and maintain web accessibility standards across the Trinity domain. This web office provides advice on web design structure and the layout of content to authorised departments/school web authors. The Trinity web accessibility policy sets out a commitment to meet international WCAG standards to level 1, ensuring the below standards are maintained:
a. Clear Navigation to ensure that all menu navigation can be read by screen readers and the first link on a Trinity web page is a hidden link called skip to main content. Heading elements (H1, H2, H3) etc. are used extensively throughout the website along with ‘skip links’ and ‘back to top’ links.
b. Tables’ attributes – Data tables to include summary attributes and are coded using Row and Column titles.
c. Image’s identification - All images to use an ALT attribute or LONGDESC attribute.
d. Forms labelling - All forms to use labels and are explicitly linked to relevant input field
Action: The Disability Service to communicate the need on increasing WCAG standards to level 2 standard.
2.3 E-learning
The accessible information policy states:
All course management products such as WebCT, and course delivery mechanisms such as podcasting and I-Tunes should be accessible to all users. Electronic eLearning materials (mainly presented via the web) conform to the World Wide Web Consortium's W3C Web Content Accessibility Guidelines and adhere to the principles of Universal Design. (https://www.tcd.ie/about/policies/accessible-info-policy.php)
Activities:
In September 2014, Trinity launched their first online course: a postgraduate Diploma in Applied Social Studies from the School of Social work. The course’s content is hosted solely online via Trinity VLE platform – Blackboard. Online courses offer unique opportunities in terms of accessibility, and the Disability Service in consultation with the School of Social Studies, undertook an audit to evaluate the accessibility of the course.
The three users who have a visual impairment evaluated the course with a variety of assistive technology (AT):
· Student A uses assistive technology to invert colours and to perform low level magnification.
· Student B uses assistive technology to magnify the screen to a high level and uses audio feedback to navigate information.
· Student C, a blind user, solely uses assistive technology screen-reading software to navigate the site.
Each student met separately with the Disability Service assistive technology officer Andrew Costello for 1-2 hours and asked to interact with the course to complete the below tasks:
1. Login to blackboard -
2. Find the appropriate module
3. Navigate to the introduction information
4. Navigate each session material
5. Interact with blogs
6. Interact with links
The WCAG 2.0 Checklist (appendix B) was used to mark the level of interaction and accessibility of the course. The students marked the checklist against four major areas:
1. Perceivable - Web content is available to the senses – sight, hearing and/touch.
2. Operability – Interface controls and navigation are operable.
3. Understandable content i.e. readable
4. Robustness - Content can be used reliably by a wide range of agents including assistive technologies.
Overall the feedback from the students on their interaction with the online course was positive. Users with appropriate knowledge of keyboard shortcuts were able to identify the page layout and structure and use the appropriate keystrokes shortcuts to interact in an efficient manner. In the above testing, the Disability Service noted that the student must possess the necessary skill in the use of assistive computer technologies to interact successfully with the container.
Actions:
The following issues were identified by the participating students via the use of the graded WCAG checklist:
1.2.2 Synchronised caption are provided for no-live, web based video - At present there are no captions available for the multimedia content within this course.
Action: Disability Service recommends such content to be made fully accessible with the use of online tools or an external provide at low cost - http://www.3playmedia.com/
1.2.3 The reading and navigation order is logical and intuitive – Student C commented on the difficulty in identifying a clear and usable pathways to the content. With testing, this was achievable but the student questioned whether a user with poor screen-reader (JAWS/NVDA) ability would be able to navigate in a similar manner.
Action: The Disability Service recommends a list of keyboard shortcuts to be made available by the Centre for Academic Practices and eLearning (CAPSL) to the user via the help area
1.4.4 The page is readable and functional when text size is doubled – Student A reported difficulty in visually making out text when it is enlarged. It becomes blurred and difficult to read slowing the user down in their interaction with page.
Action: The Disability Service recommends that CAPSL to investigate with Blackboard.
2.1.2 No keyboard trap – Keyboard focus is never locked in one page element. The user can navigate to all navigable pages elements. Student B was unable to move keyboard focus from the side navigation to the main content in a usable manner. With time and support the user was able to accomplish such tasks but needed assistance to identify the page layout.
Action: The Disability Service recommends a list of keyboard shortcuts to be made available by CAPSL to the user via the help area.
2.4.1 A link is provided to skip navigation and other page elements that are repeated across the web page - Student C was unable to locate a tag element to enable the student to skip to the main content of the page and avoid the unnecessary Document Object Model (DOM) interaction.
Action: The Disability Service recommends a list of keyboard shortcuts to be made available by CAPSL to the user via the help area
2.4.7 It is not visibly apparent which page element has the current keyboard focus (i.e. as you tab through the page) - Students A and C highlighted the issues of been unable to identify keyboard ‘quick links’ and ‘refresh’ functionality. The users were unsure of their location on the course and it caused confusion in the navigation of the site.
Action: The Disability Service recommends a list of keyboard shortcuts to be me made available by CAPSL to the user via the help functionality.
Inaccessible information – All participants emphasised the need to ensure that material uploaded to the course is accessible. They commented on the poor Pdf and word documentation design,
without correct navigation or use of Optical Character Recognition (OCR) the document is inaccessible and unusable to users of AT.
Action: The Disability Service recommends that course designers are made aware by CAPSL accessible information guidelines. The Disability Service to work with CAPSL to improve navigation and awareness of designing documents in universal as per the online resources hosted at - http://www.tcd.ie/CAPSL/TIC/accessible-info/ .
2.4 Person to person Communication
The accessible information policy states:
Trinity will ensure that information will be provided in an accessible manner when speaking to a person with a hearing impairment (https://www.tcd.ie/about/policies/accessible-info-policy.php)
Activities:
In July 2014 all portable loop systems within all administrative areas were serviced and checked for use by the Disability Service. These devices provide a vital link for staff and students who are hard of hearing. Such devices amplify a conversation on a student’s hearing aid. Locations of such devices have been added to the universities online maps at http://www.tcd.ie/Maps/map.php
Guidelines for working with Irish Sign Language Interpreters (ISL) continued to be piloted in 2014-15. These guidelines outline how to support deaf staff, students and visitors when they require an ISL interpreter explain how to book this service, and who will cover the costs of such a service - http://www.tcd.ie/disability/assets/doc/pdf/ISL%20provision%20document%20-%202012-2015.pdf
Action: The Disability Service to monitor and support the use of portable loop system within Trinity.
2.5 Information Technology Procurement
The accessible information policy states:
To ensure Trinity makes technology accessible to all, the Trinity Procurement procedures states ‘Tenderers are expected to be compliant with all statutory requirements, for example, Disability Act 2005. (https://www.tcd.ie/about/policies/accessible-info-policy.php)
Activities:
The universities procurement procedure was amended in 2010-11 to ensure that all procured goods are compliant with the Disability Act 2005 (and the Trinity Accessible Information Policy). The Disability Service communicated with the Procurement Office in academic year 2013-14 on a lack of awareness of staff on their responsibilities to ensure goods and services procured via a request for tender process (RTF) were accessible and compliant with the accessible information policy. Good practice guidelines provided by the Disability Service were posted to the procurement website in the academic year 13-14 to advise staff on their responsibilities in relation to ensuring their product or service required is accessible for all.