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The Region has decided recently that websites developed by those employed at the Region should, generally, be created using their CMS (content management system) and through their dedicated web editor team. They said that on individual cases they can grant exemptions to this decision. We aim to request for an exemption for a few reasons:
The Region's interpretation and communication of the law and their decision (internal documents) is not completely clear nor precise with regard to why and how researchers make and use websites.
The law, while using the required, generally precise legal language, does not cover all cases, nor does it define all terms, particularly in regard to researchers and websites.
The Region's CMS solution can not fulfill the needs of researchers (see feat: ✨ add posts about why GitHub and Quarto #121), for example, making documentation for software (see below) can't be done through their CMS as it is generated from the source content nor can it auto-generate output of results or analysis for situations like training workshops on data analysis or on sharing results.
The Region's CMS and web editor solution introduces an immense and incredibly burdensome process of communicating and coordinating with their web editor teams. Most researchers will likely decide not to make a website for their specific needs or purposes, thus reducing Steno Aarhus' visibility, productivity, and impact.
It is unclear how easy it is for outside collaborators to contribute to the Region's CMS solution. If it has any administrative steps required, it is already a burden compared to using GitHub. GitHub allows anyone to make a change and submit the change to be merged into the main content through the "pull request" mechanism.
Many cases that occur through regular research activities and outputs are not covered under these definitions and terms found in the law. For example, neither the Region nor the law describe nor define how web accessibility applies in the context of:
Website documentation for research software (e.g. like our osdc package)
Website documentation for a research workflow or procedures (e.g. the ukbAid guide for those working with the UK Biobank)
Websites for regular meetings or sessions that are mainly internal but still open to others (e.g. the Epidemiology and Statistics sessions)
Websites for resources (e.g. the Denmark Statistics DARTER Project)
A strict reading and interpretation of the law shows that section 2 has no precise definition for a number of terms used. For instance, throughout the law there is an emphasize on "meeting the needs of the general public" (e.g. section 2, paragraph 1 and paragraph 2 "at imødekomme almenhedens behov, dog ikke behov af industriel eller kommerciel karakter" or section 2 paragraph 3 "der er udformet og udviklet ... til brug for den brede offentlighed på mobile enheder."), but there is no clear definition of "almenheden" (general public) nor of "industriel" (industrial). Without this clear definition, it is difficult to classify the different use-cases that researchers have for websites with the law. For example, a common interpretation of "general public" is an average person. Under this interpretation, documentation on how to use research software or the schedule for a specific conference or the procedures for doing a specific research workflow is not intended, designed, nor developed to meet the needs of the general public.
Therefore, if we follow this definition of "general public", none of the websites created under the domain steno-aarhus.github.io are developed nor designed for use and consumption by the general public nor would the general public intentionally seek out these websites. By this reasoning, our websites on GitHub do not fall under the constraints and terms of this specific law, and therefore do not apply to us.
Given the content of the websites are aimed at "non-general public" people, for instance, researchers or technical personnel, the language used is thus necessary to be highly technical in nature to effectively communicate to this audience. Since the Danish law adheres to WCAG 2.1, and under guideline 3.1 (readable), it mentions that if the reading level of the material is more advanced than lower secondary that a summary or additional text or link be made to clarify those definitions. We do not aim, designed, nor develop our content at lower secondary readers.
However, even if this is the case and our websites do not fall under the law, we still do believe strongly in adhering to accessibility guidelines as even researchers have various accessibility needs. With this in mind, while we aim to formally request an exemption to the Region's decision, we also aim to follow the spirit of the law as much as possible by:
Generating an accessibility statement at the base URL at steno-aarhus.github.io/, so that all sub-domains can display the same accessibility statement
Incorporating automated and regularly running accessibility checks on websites
Creating more guide documents that walk through the best practices for making websites, so that researchers get trained and educated more on this
Using a common website theme that adheres to accessibility guidelines as much as possible, with our sdca-theme
Include a banner or call-out block on the websites that clearly states the intended audience (e.g. researchers or course participants, etc).
Since none of the websites we host under steno-aarhus.github.io are able to collect any personal data, nor can they create and use any cookies, we do not fall under the related cookie or personal data.
More explanation about how GitHub and Quarto (the tools we use to make and host the websites) is found at #121 (for now, it will be on the website eventually).
The formal request for exemption will be put in an about section of the steno-aarhus.github.io landing page, along with some other links, to make it clear to others and auditors, that we've followed as much as possible the law and to be transparent in our decision making process.
This issue is meant to be a starting point for writing the request for exemption.
The Region has decided recently that websites developed by those employed at the Region should, generally, be created using their CMS (content management system) and through their dedicated web editor team. They said that on individual cases they can grant exemptions to this decision. We aim to request for an exemption for a few reasons:
Many cases that occur through regular research activities and outputs are not covered under these definitions and terms found in the law. For example, neither the Region nor the law describe nor define how web accessibility applies in the context of:
A strict reading and interpretation of the law shows that section 2 has no precise definition for a number of terms used. For instance, throughout the law there is an emphasize on "meeting the needs of the general public" (e.g. section 2, paragraph 1 and paragraph 2 "at imødekomme almenhedens behov, dog ikke behov af industriel eller kommerciel karakter" or section 2 paragraph 3 "der er udformet og udviklet ... til brug for den brede offentlighed på mobile enheder."), but there is no clear definition of "almenheden" (general public) nor of "industriel" (industrial). Without this clear definition, it is difficult to classify the different use-cases that researchers have for websites with the law. For example, a common interpretation of "general public" is an average person. Under this interpretation, documentation on how to use research software or the schedule for a specific conference or the procedures for doing a specific research workflow is not intended, designed, nor developed to meet the needs of the general public.
Therefore, if we follow this definition of "general public", none of the websites created under the domain
steno-aarhus.github.ioare developed nor designed for use and consumption by the general public nor would the general public intentionally seek out these websites. By this reasoning, our websites on GitHub do not fall under the constraints and terms of this specific law, and therefore do not apply to us.Given the content of the websites are aimed at "non-general public" people, for instance, researchers or technical personnel, the language used is thus necessary to be highly technical in nature to effectively communicate to this audience. Since the Danish law adheres to WCAG 2.1, and under guideline 3.1 (readable), it mentions that if the reading level of the material is more advanced than lower secondary that a summary or additional text or link be made to clarify those definitions. We do not aim, designed, nor develop our content at lower secondary readers.
However, even if this is the case and our websites do not fall under the law, we still do believe strongly in adhering to accessibility guidelines as even researchers have various accessibility needs. With this in mind, while we aim to formally request an exemption to the Region's decision, we also aim to follow the spirit of the law as much as possible by:
steno-aarhus.github.io/, so that all sub-domains can display the same accessibility statementsdca-themeSince none of the websites we host under
steno-aarhus.github.ioare able to collect any personal data, nor can they create and use any cookies, we do not fall under the related cookie or personal data.More explanation about how GitHub and Quarto (the tools we use to make and host the websites) is found at #121 (for now, it will be on the website eventually).
The formal request for exemption will be put in an about section of the
steno-aarhus.github.iolanding page, along with some other links, to make it clear to others and auditors, that we've followed as much as possible the law and to be transparent in our decision making process.This issue is meant to be a starting point for writing the request for exemption.