Vagueness of the 12.2.2 evaluation methodology
@lannero and @puskar arranged a survey from March 18 to April 9, 2024, about EN 301 549 in the Wadex group. Here are comments from respondents about the vagueness of the 12.2.2 evaluation methodology:
- We are not sure yet how to test this clause. We have not encountered the case in our monitoring up to now because our interpretation of the clause is rather narrow (see also 12.1.1 above): We test this clause, if a “technical support” is available. A general contact address or the contact option in the accessibility statement are not considered “technical support”. But it is enough if it is implicitly clear that there is a “technical support”.
Our ideas for testing go like this: We send a standardized question about the accessibility and compatibility features to the technical support provided. We are not sure yet, if we should send the question in the name of a user or openly as the monitoring body. There is no information how this inquiry should look like. It is very likely that the responses could be different if the request came from the monitoring body and not from an individual user. - ICT support services shall provide information on the accessibility and compatibility features that are mentioned in the product documentation." While the intent is good, this is practically impossible to test. What method should be used - direction inspection of the service, a questionnaire provided to the public body. Does the tester need to contact the call center and quiz the person on the other end of the phone? What does that person need to know about the "accessibility and compatibility features that are mentioned in the product documentation" - that they exist, how the facilitate accessibility? Again , very ambiguous and while well intentioned impossible to test without an agreed methodology.
- Requirement 12.2.2 or clause C.12.2.2: In this requirement, you must contact technical support (if available) and ask them verbally (or in writing) about the contents of the documentation (if available) with regard to accessibility. Checking this request is very time-consuming and also depends heavily on who is processing the support request. You may also have to wait for the service times. This requirement is not impossible to check and is also justified, but at the same time it is difficult to obtain an objective result and, as I said, it is very time-consuming. Proof could also prove difficult and be problematic for individual technical support staff.