Oogvereniging Nederland
De Oogvereniging is de patiënten- en belangenorganisatie voor iedereen in Nederland die iets aan zijn ogen heeft.
ID: 721047120591-54
Lobbying Activity
15 Jun 2018
The proposed methodology for monitoring tends to put too much emphasis on measuring accessibility at a technical level, to the detriment of usability and user experience. For that same reason, we disagree with promoting automated testing,
Re. point 2.2.4: we are keen for persons with disabilities to be more involved (according to the CRPD) and we would like their representative organizations to be consulted for the selection of a higher proportion of websites to be monitored, through extending the scope of the “20% of the sample” to all websites, not only those monitored with the simplified method. Moreover, the same rule should apply to mobile apps.
No common monitoring method is recommended. Using a common monitoring method, like WCAG-EM, would make monitoring easier and would allow for better comparison. Furthermore, it would simplify tasks for accessibility experts who work in multiple European Member States.
There is no monitoring included for documents. Documents should be compliant, so it would be best to include them.
Read full responseResponse to Commission implementing decision on establishing a model accessibility statement under the WAD
14 Jun 2018
The Eye Association of the Netherlands (Oogvereniging Nederland) wants to express that formal endorsement (at administrative or political level) of the accessibility statement should be obligated (mandatory). It ensures the commitment and an enduring approach of accessibility by the management of the organization. Endorsement has a big impact on allocating budgets, involvement of key players other than the web team and ensuring accessibility in processes. It will actually help organizations moving from an ad hoc approach to a mature and pro-active approach. And after all, accessibility will be a legal obligation. Management should know and endorse the statement.
An Accessibility Statement isn’t written for people with disabilities. As stated before an accessibility statement is written for the management. In a recent study one of the main conclusions of UK's Gov made with People with Disabilities was: "Users had never, or rarely used an accessibility statement." The Accessibility Statement is written for the management so that they where they stand in making the website accessible and what the next steps of the process are on what they have to do.
For transparency and quality assurance we think that the link to an evaluation report should be mandatory. The evaluation report should be public.
Furthermore we want to recommend strongly that the accessibility statement should contain a timeline of planned improvements (mandatory).
Member states should be required to ensure that Public Sector Bodies review and update their accessibility statements regularly, and at least annually. An outdated accessibility statement is of no value. There is a lot of experience with accessibility statements in the Netherlands. Our experience is that organizations deliver a statement once, but don't update them at all. A statement should be accurate and up to date.
The Eye Association of the Netherlands (Oogvereniging Nederland) wants to recommend that there is an extra optional content requirements: measures an organization has taken. Adding this option can help member states understand that accessibility is not just a technical challenge, but also an organizational challenge.
Add also a note in the section feedback and contact information that the feedback mechanism should be accessible and easy to use. Also provide multiple contact options: e.g. not only a phone number.
Read full response