CHLAVM-POL-ACC-01 — Accessibility Policy (WCAG 2.1 Level AA)

Organization: Canadian Hispanic Latin American Virtual Museum (CHLAVM)
Document ID: CHLAVM-POL-ACC-01
Applies to: All public-facing digital content created or published by CHLAVM, such as web pages, virtual or 3D experiences, images, PDF documents, audio or video media, and social media.
Status: Final (v1.0)
Owner (role): Collections Manager
Owner name: TBD
Approvals: Executive Director; Board (if required)
Review cycle: Annually and when significant operational or governance changes occur

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1. Purpose

This policy ensures that all CHLAVM digital content is accessible to people with disabilities. CHLAVM is committed to achieving compliance with W3C Web Content Accessibility Guidelines (WCAG) 2.1 Level AA to provide equal access for all visitors, as referenced in the Accessible Canada Act (ACA), S.C. 2019, c.10 ) (federal) and Accessibility Ontarians with Disabilities Act (AODA), S.O. 2005, c. 11 (provincial legislation).

2. Scope

This policy applies to all digital content, created, managed, or published by CHLAVM, including:

• • Website and virtual galleries
  • Images and photographs
  • Audio and video content
  • 3D models and WebXR experiences
  • Documents and PDFs
  • Social media content

3. Policy statement

CHLAVM is committed to making its digital content accessible to people with disabilities and will implement procedures to meet WCAG 2.1 Level AA as the minimum standard for public-facing content. Accessibility requirements are integrated into planning, design, production, and publishing workflows. Where full compliance cannot immediately be achieved due to operational, technical, or financial constraints, the deviation must be documented, include a remediation plan, and receive Executive Director approval.

4. Definitions

• • WCAG 2.1 Level AA: Web Content Accessibility Guidelines — international standards for digital accessibility. Version 2.1, Level AA, is the minimum standard adopted for CHLAVM public-facing content.
  • Accessible document (tagged PDF): A PDF that is structured with appropriate tags, reading order, headings, table markup, link semantics, and document language settings, enabling full use by assistive technologies.
  • Alternative text (alt text): A required text alternative that communicates the meaning or function of an image or graphic for users who are unable to perceive visual content.
  • Captions: Text that is synchronized with video content to represent spoken dialogue and relevant sounds, ensuring accessibility for users who cannot access audio.
  • Transcript: A complete text version of spoken content and relevant sounds for audio or video assets, provided to support accessibility and interpretation.
  • QA (Quality Assurance): The mandatory review process to verify that all accessibility requirements have been met prior to marking content as Approved or Published.
  • Screen reader: Software that converts digital text to speech for users who are blind or have low vision.
  • Colour contrast: The measured difference in luminance between text and background, expressed as a ratio.
  • Accessibility sidecar files: Files that provide accessible alternatives to media content, including captions, transcripts, and audio descriptions.

5. Requirements

5.1 WCAG 2.1 Level AA standards

CHLAVM applies WCAG 2.1 success criteria to Levels A and AA according to the four principles: Perceivable, Operable, Understandable, and Robust (POUR):

5.2 Image accessibility

All public images must include appropriate alternative text (alt text) or be marked decorative, according to the following guidelines:

Good Example: “Ceramic bowl with blue geometric patterns, crafted by Indigenous artisans in Guatemala, circa 1920.”
Bad Example: “Image1.jpg” or “Bowl”

References: 

• • • 1.1.1 Non-Text Content (A)
    • W3C Image Tutorialls - Images
    • W3C Alt Decision Tree

5.3 Video accessibility

The following requirements apply to all public videos.

1. • Captions must be provided for all spoken words and significant sounds.
   • A complete transcript of all audio content must be made available.
   • Audio description must be included when visual information is necessary for comprehension.
   • Videos must not play automatically with sound enabled.

References:

• 1.2.1 Audio-only and Video-only (Prerecorded) (A)
• 1.2.2 Captions (Prerecorded) (A)
• 1.2.3 Audio Description or Media Alternative (Prerecorded) (A)
• 1.2.5 Audio Description (Prerecorded) (AA)
• 1.4.2 Audio Control (A)
• W3C Making Audio and Video Media Accessible

5.4 Audio accessibility

These requirements ensure that audio‑only content meets WCAG 2.1 Level AA for time‑based media. All audio content must include:

• Written transcript of all spoken content
• Speaker identification in the transcript
• Description of significant sounds or music
• Downloadable transcript option

References:

• 1.2.1 Audio-only and Video-only (Prerecorded)(A)
• 1.4.2 Audio Control (A)

5.5 3D and WebXR accessibility

Immersive content must also comply with CHLAVM‑POL‑XR‑01 — WebXR Policy, in addition to the following accessibility requirements:

References:

• W3C XR Accessibility User Requirements

5.6 Document accessibility

Where PDFs are published, they must be exported and remediated as tagged, accessible PDFs suitable for screen readers. All PDFs and documents must:

• Use proper heading structure (Heading 1, 2, 3)
• Include alt text for all images
• Use readable fonts (minimum 12pt)
• Have sufficient colour contrast
• Be tagged for screen readers
• Avoid using colour alone to convey meaning

References:

• W3C WCAG 2.2 PDF Techniques (latest version, no 2.1)

5.7 Colour and contrast

CHLAVM applies the WCAG 2.1 Level AA minimum contrast ratios:

Tip:  Use free tools like WebAIM Contrast Checker and ButtonBuddy.dev.

References: 

• 1.4.3 Contrast (Minimum) (AA)
• 1.4.11 Non-Text Contrast (AA)
• WebAIM Contrast Checker (text and non-text content)
• ButtonBuddy.dev (non-text content only)

5.8 Keyboard navigation

All interactive elements must be usable with keyboard only:

• Tab key moves between links and buttons
• Enter key activates buttons and links
• Arrow keys navigate menus and galleries
• The escape key closes popups and menus
• The focus indicator is visible on the selected element

Tip:  Aim to meet a new success criterion in WCAG 2.2** that also ensures that the visual focus indicator is never obscured or covered.

References:

• 2.1.1 Keyboard (A)
• 2.1.2 No Keyboard Trap (A)
• 2.1.4 Character Key Shortcuts (A)
• 2.4.7 Focus Visible (A)
• 2.4.11 Focus Not Obscured (A) **
• W3C Easy Checks - Keyboard Access and Visual Focus
• W3C Tutorials - Keyboard 

5.9 Multilingual content

CHLAVM serves English, French, and Spanish communities:

• Indicate the language of the content in metadata
• Provide translations where possible
• Captions and transcripts in the original language
• Mark language changes within content

Resources:

• 3.1.1 Language of Page (A)
• 3.1.2 Language of Parts (A)

5.10 Accessibility checklist

Before any new content is published, the Web Publisher and Quality Assurance Reviewer must confirm that the following checklist has been met or documented as an exception:

☐ All images have descriptive alt text
☐ All videos have captions
☐ All audio has transcripts
☐ Colour contrast meets 4.5:1 ratio
☐ Content is keyboard navigable
☐ Headings are properly structured
☐ Links have descriptive text (not “click here”)
☐ 3D/WebXR has a non-VR alternative
☐ No content flashes more than 3 times per second
☐ Forms have visible labels

5.11 Flagging accessibility gaps

CHLAVM may publish content that does not fully meet accessibility standards at the time of release only if all of the following conditions are met:

• The accessibility gap is documented in the relevant accessibility metadata fields, such as Accessibility_Status, Accessibility_Notes, or Priority.
• A remediation plan, including a target timeframe, is documented, and progress is monitored.

5.12 Accessibility operations review schedule

Accessibility compliance must be reviewed annually and when significant changes to the website, galleries, or templates occur:

• ☐ Audit sample of published content
• ☐ Test keyboard navigation on all galleries
• ☐ Review flagged accessibility gaps
• ☐ Update captions and transcripts as needed
• ☐ Check for and adopt new WCAG 2.1 Level AA 2.2 guidelines at Levels A and AA (next and current published version).  Compliance with Level AAA is not currently mandated by law in Canada.
• ☐ Document review date and findings

6. Roles and responsibilities

The following roles share responsibility for implementing this policy and maintaining accessibility over time:

• • Collections Manager: Accountable for accessibility compliance across the published policy set; coordinates reviews, prioritizes remediation, and ensures accessibility requirements are embedded in workflows.
  • Web Publisher: Implements accessible publishing on the website and virtual gallery pages; ensures templates, headings, links, and media embeds meet accessibility requirements; runs pre-publish checks.
  • Quality Assurance Reviewer: Performs accessibility checks prior to release (automated + manual spot checks) and documents pass/fail results.
  • Digital Asset Manager: Ensures accessibility-related metadata fields and flags are populated; stores/links transcripts, captions, and tagged PDFs in the DAMS or agreed repository.
  • Digitization Coordinator: Ensures digitized outputs (images, documents, audio/video derivatives) are produced with accessibility requirements in mind (e.g., transcripts, captions, accessible formats).
  • Executive Director: Approves exception decisions when accessibility requirements cannot be met immediately and ensures risks are acknowledged and tracked.

7. Records and required outputs

An Accessibility Validation Record must be created for each public release and must document the review date, reviewer, scope of testing, tools used, issues identified, remediation status, and final determination.

Accessibility records must be maintained in the designated systems of record. These systems may include the web content management system (CMS), digital asset management system (DAMS), or accessibility logs. Records must include the following information, as applicable:

• • Accessibility Validation Record for each public release (date of review, reviewer, scope of testing, tools used, issues identified, remediation status, final determination).
  • Automated scan output (where used) or a summary of results.
  • Captions files and transcripts for video/audio content (or links to where they are stored).
  • Tagged PDF validation evidence (where PDFs are published), including remediation notes if applicable.
  • Documented accessibility gaps and planned remediation dates (where applicable).

8. Acceptance criteria (pass/fail)

A release passes this policy when all of the following conditions are met or when exceptions are explicitly approved and documented by the Executive Director:

• • Images include descriptive alt text.
  • Buttons and controls have a unique accessible name that matches or includes the visible label (e.g., “Play video” as visible text, “Play video in Spanish” as the accessible name).
  • All interactive elements, such as buttons, controls, and form input elements, have a unique ID.
  • Video includes captions and transcripts; audio includes transcripts.
  • Content is navigable by keyboard (and switch controls and joysticks as a result) and uses a clear heading structure.
  • All interactive elements that receive keyboard focus have a  visual indicator (outline) that has sufficient contrast between both the element and the background to ensure it stands out.
  • Colour contrast meets the minimum contrast requirement as stated in this policy.
  • Links are descriptive (not “click here”).
  • 3D/WebXR experiences provide a non-immersive alternative where applicable.
  • No content flashes more than 3 times per second.
  • Known gaps are explicitly flagged and tracked when immediate remediation is not possible.
  • Downloadable Portable Document Format (PDF) and any other document format comply with all relevant WCAG 2.2 PDF Techniques.
    
    References:
    
  • Use the list of Tasks involved in Accessibility within the W3C Accessibility Roles and Responsibilities Mapping (ARRM) framework to create your checklist. It is a breakdown of 2.1. and 2.2 success criteria into easy tasks and identifies the primary, secondary and  contributor owners.