Improvement of clause 12.1.1

There was a lengthy discussion in the STF mailing list about improving clause 12.1.1 to address issues regarding the term “compatibility features”, metadata, and concerns about accessibility statements (the latter being highlighted in issues #114 (closed) and #273 ).

This discussion led to a proposal, which is suggested to be included in the EN:

12.1.1      Accessibility and compatibility features

Where ICT includes product documentation, whether provided separately or integrated within the ICT,

the documentation shall list and explain how to use the accessibility features of the ICT and its compatibility features with assistive technology.

NOTE 1:     Accessibility and compatibility features include accessibility features and AT that are built-in and accessibility features that provide compatibility with 3rd party assistive technology.

NOTE 2:     It is best practice to not only offer this information directly to users but also to use standardized vocabularies to provide metadata on the accessibility of the ICT, such as "Schema.org Accessibility Properties for Discoverability Vocabulary" [i.40], or "Service and discovery metadata - DVB" [i.X].

NOTE 3:     It is best practice to present ICT accessibility metadata in a manner that is understandable to users. There exists guidance in this respect, such as the "User Experience Guide for Displaying Accessibility Metadata 1.0" [i.Y].

NOTE 4:     Help pages are examples of the provision of product information.

NOTE 5:      Product documentation could include an accessibility statement. One option for creating accessibility statements is using the W3C Accessibility Statement Generator Tool [i.Z]. ICT that has to meet the essential requirements of Directive (EU) 2016/2102 [i.28] is also required by that directive to provide an accessibility statement that meets the requirements established by Implementing Decision (EU) 2018/1523 [i.ZA].

[i.X]

DVB Service and discovery metadata

https://dvb.org/solutions/service-discovery-metadata/

[i.Y]

W3C Final Community Group Report (September 2021)

User Experience Guide for Displaying Accessibility Metadata 1.0

https://www.w3.org/2021/09/UX-Guide-metadata-1.0/principles/

[i.Z]

W3C Accessibility Statement Generator Tool

https://www.w3.org/WAI/planning/statements/generator/#create

[i.ZA]

Implementing Decision (EU) 2018/1523 of 11 October 2018 establishing a model accessibility statement in accordance with Directive (EU) 2016/2102 of the European Parliament and of the Council on the accessibility of the websites and mobile applications of public sector bodies

added Proposed for approval label

Mostly positive, but a few comments:

• In one place, the term "meta data" is used, while in most places it is called "metadata". I think there should be no space in the middle.
• While I fully agree that accessibility metadata is a great thing and I definitely support including the informative notes saying the provision of metadata is best practice, I also think the two notes could cause some confusion:

Metadata sometimes is presented directly to users but sometimes it is not. For example, in a Word document, much of the metadata is only displayed to users if they open a special dialogue containing document properties. For web pages, metadata can be visually hidden in meta elements in the html code. Other times, metadata is presented on the page but enhanced with encoding that makes the data more accessible to software (eg. using itemprop attributes in combination with schema.org vocabulary terms).

I think that the notes about metadata could be misinterpreted as meaning that the ICT can pass clause 12.1.1 if accessibility features are described in metadata - whether or not this metadata is actually presented to the user.

The requirement should be that the information can be presented to the user without any need to extract hidden content from code.

Therefore I suggest changing Note 2 to the following (except for the highlighting of changed text, that I only added for clarity):

NOTE 2: It is best practice to not only offer this information directly to users but also to use standardized vocabularies to provide metadata on the accessibility of the ICT, such as "Schema.org Accessibility Properties for Discoverability Vocabulary" [i.40], or "Service and discovery metadata - DVB" [i.X].

Metadata is an extremely imprecise term and can cause some confusion unless used with precision.

This is made worse by the way the term is used very specifically in some industries. For example, in telecom, metadata is generally assumed to refer to call or connection logs, since actual user data traditionally was not stored in the network. Some telecom regulations make this assumption, which causes problems for newer services such as my own specialist field of cloud computing.

Camera settings embedded in an image file are metadata.

Information stored about a file, such as the date/time it was originally created, or last updated, are also metadata.

Logs of who has opened or downloaded a file are also metadata.

Metadata can be stored within a file, or in some separate record that is associated with the file.

Programme information in a digital EPG can be metadata.

As such, we always have to be very careful of exactly what metadata we are talking about. The term is far too vague to be used indiscriminately.

changed the description

removed Proposed for approval label

added Included in EN label

The above proposed changes to 12.1.1 were agreed at the 5th March 2025 STF614 meeting and have been incorporated into the editors draft of EN 301 549.

closed

marked this issue as related to #114 (closed)

marked this issue as related to #141 (closed)

mentioned in issue #114 (closed)

mentioned in issue #141 (closed)

mentioned in issue #485