Checklist for Publishing PDF Files

These guidelines apply to creating PDF content and publishing, distributing, or storing this content.

While the ADA requirements are the same for PDF as for any other electronic content, this checklist includes tips forADA compliance as well as reminders regarding protecting private and sensitive information.

ADA Compliance 

All PDF documents must be ADA compliant per state and federal law.

Please note that simply passing the ADA “Full Check” in Acrobat is not enough to ensure compliance.  There are many ADA concerns that require a human being evaluate the content, for example:

1. Alt text – ADA checkers are capable of determining if Alt text exists on images, however they are not capable of determining if the Alt text is appropriate for the image and placement.
2. Color contrast – The ADA checker in Acrobat is not capable of determining sufficient color contrast in text or in images
3. Logical reading order – The PDF content must read out loud in the same order that the printed content is presented
4. Proper use of headings – Acrobat is capable of determining skipped heading levels.  However, the regulation also states that text that is used as a heading must be a heading structurally and that all text marked as a heading must be acting as a heading.

Testing PDFs for ADA Compliance

1. Testing in Acrobat
   1. Complete the document properties (Ctrl+D), including:
      1. Title
      2. Subject
      3. Author (include phone number for assistance)
      4. Language
   2. Run the “Full Check” in the Accessibility Toolset
   3. Respond to all reported issues
      1. Title – once the document properties have been completed, mark this issue as “Fixed”
      2. Issues requiring manual review – once these items have been reviewed and successfully remediated, mark this issue as “Fixed”
      3. Document should be properly tagged
      4. Scanned content should be OCR’d or treated as an image
2. Read out loud
   1. In Acrobat, select Read Out Loud, then Activate Read Out Loud from the View menu
   2. Listen to the document while reading it on your monitor
   3. The goal is to ensure that all content is read out loud as expected, and all content is read out loud in the same order as the written document

Private and Sensitive Information 

The following list combines security and privacy restrictions from various sources: County Policy, State and Federal laws.

Never publish or share documents with unauthorized parties containing the following elements:

1. Safe words or internal procedures for notifying law enforcement when you are endangered by a member of the public
2. Network or application logon information or passwords
3. Livesignatures (e.g. contracts)
4. Personal Health Information (PHI) that would conflict with HIPAA regulations
5. Personal Information belonging to a member of law enforcement, government or judiciary (e.g. address, phone number, etc)

Obtain written permission before publishing the following to the internet containing the following:

1. Personal Information belonging to a member of the public
2. Images containing faces of children or members of the public
3. Copyrighted material

If you are unsure whether your content is deemed private or sensitive, please consult with your manager, Web Team, or Counsel.

Remediation Techniques 

• Text – Redact sensitive text
  • Important: Redactions must be made using the Redact Tool
  • Redacted text should be treated as in image.  The Alt text for the redaction should be “[Redacted]” 
  • Note: when redacting signatures, consider replacing the signature with “Signature on file” or similar
• Images – blur identifying personal features (faces, tattoos, etc), logos on clothing, background features (license plates, home addresses, etc)
• Copyrighted Material – do not use without permission.

Resources

In addition to the ADA resources listed on Making Content Accessible, please see:

Public Safety Privacy: 

• California law: § 6254.21
• California law: § 6254.24

Personal and Private Information: 

• HIPAA: Notice of Privacy Practices
• Policy: 9-2 Information Technology Use and Security Policy
• Photo release forms: General | Minors

Redaction Instructions

• Removing sensitive content from PDFs