Closed mitchellevan closed 3 years ago
Thank you for your comments. It seems you assume that the model accessibility statement must be used verbatim, which may not be the case. We will look into some aspects more closely.
I agree @nitedog, discussion is warranted. Any particular jurisdiction might be fine with the current sequence and wording from the generator.
Data point: the UK Digital Service seems to expect their public sector bodies to include some "legally required" phrases. https://www.gov.uk/government/publications/sample-accessibility-statement/sample-accessibility-statement-for-a-fictional-public-sector-website
Agree. That wasn't the case when we created the tool. I added issues #133, #134, and #135 that could help address most of the issues you raised.
In addition to the changes proposed above, the guidance also states:
Note that in some situations you may be required to provide particular content in your accessibility statements. For example, there are specific requirements for accessibility statements in relation to the EU Web Accessibility Directive.
This statements generator is not designed exclusively for the EU Directive but also for other uses. Tweaks may be needed but the generated statements should be mostly compatible.
Expected behavior
Public sector bodies may be required to follow this model accessibility statement.
COMMISSION IMPLEMENTING DECISION (EU) 2018/1523 ... establishing a model accessibility statement
Annex, Section 1 "Mandatory Content Requirements":
Article 4(1):
Actual behavior
Headings do not match the EU boilerplate
Annex Section 1 specifies these headings for a report:
However, the report generator inserts these headings in the report:
The introduction does not match the EU boilerplate
Annex Section 1 specifies boilerplate phrases in the introduction.
However, the report generator only allows the following text in the introduction.
Text does not match the EU boilerplate in "Compliance status" and "Non-accessible content" sections
Annex Section 1 specifies a sequence of boilerplate phrases in the "Compliance status" and "Non-accessible content" sections. See above in "Expected behavior".
However, the report generator does not allow these boilerplate phrases.
Text does not match the EU boilerplate for "prepared on" and "reviewed on" dates
Annex Section 1 specifies two dates.
However, the report generator only allows insertion of one date.
Links are not allowed for "feedback" and "enforcement"
Annex Section 1 specifies two links.
However, the report generator does not allow insertion of these links.
Note
This issue only addresses English. Note that the EU specifies a model accessibility statement in 23 languages. https://eur-lex.europa.eu/eli/dec_impl/2018/1523/oj