Starting an organization-wide accessibility program: A guide for government departments
When I present this to audiences they say ‘This is all common sense isn’t it? Surely that’s what we should be doing.’ And ‘yes…’ I say, ‘but you show me an example of doing it.’”
—Professor Ken Eason
This guide provides step-by-step advice on tasks to achieve the goal of implementing a new program to address accessibility across-the-board in local, state or federal government departments to meet the needs of employees and citizens who have disabilities. A six-step process covers (1) A systematic appraisal of the current situation; (2) Considerations of alternatives for technology compliance and organizational culture; (3) Gaining executive support; (4) Establishing stakeholders and goals; (5) Designing, planning and implementing a new system; and (6) Periodic updates based on monitoring of progress. Contingency planning is also covered.
This article was developed as part of
The Accessibility Switchboard Project
National Federation of the Blind Jernigan Institute
June 2018, Version 1.0
Creative Commons License: CC BY-SA 4.0
Note: This guide is for people who are working within (or for) Government Departments who want to start a completely new accessibility program to address accessibility on an organization-wide basis. For those working within (or for) Government Departments that have an existing organization-wide or sub-department-level accessibility program and are seeking to improve upon it with the latest organization-wide methods, see our separate Switchboard guide: Revamping an accessibility program: A guide for Government Departments. For those who are vendors to Government Departments (e.g., software suppliers, technology suppliers), see our separate Switchboard guide: A roadmap for organizational accessibility for large ICT vendors.
Introduction and Background
You’re not alone…
Whatever your reasons are for wanting to start an organization-wide accessibility program in your local, state, or federal government department, this guide provides step-by-step advice on tasks to achieve the goal of having accessibility addressed across-the-board to meet the needs of employees and members of the public. Successes have been achieved elsewhere in this type of endeavor, and this guide represents the collective wisdom of many shared experiences.
Modern societal thinking is inclusive. This is not just about disabilities. Society trends continue toward (but have yet to achieve) gender equality, racial equality, and so forth. However, disability is unique in the inclusion sphere in that addressing accessibility needs requires physical changes to the built environment, coding changes to websites, content changes to electronic documents and paper publications, to video, to training delivery, to forms, etc. While accessibility requires the same attention to diversity training as other inclusion categories, the necessity of physical changes adds an extra layer of complexity. If these aspects are not systematically and proactively tackled, employees will likely find themselves in a situation where they have a combination of inaccessible technology, and non-inclusive policies and practices. Taking a piecemeal approach to this with sporadic, isolated activities is inherently risky.
A denial of government services based on disability is a principle that’s hard to imagine in modern society. It would present a risk of violating the rights of citizens. Not hard to imagine though, are situations where employee communications, training, and services were not accessible to blind government employees. For many government employees and members of the public trying to get services, this situation is sometimes real, not imaginary. Numerous lawsuits have been brought against government departments in North America over the last decades.
Bad Situations / Good news
The most obvious reasons why the absence of an organization-wide accessibility program is a bad situation are (a) it puts you at a greater risk of complaints and legal actions; and (b) it is out of step with the wider inclusivity trends seen elsewhere in the government sector, and in society as a whole.
Before you can fix a bad situation, you should first try to understand what caused it in the first place. Was it simply an oversight? Was there an accessibility program set up but then it died? Were staff protesting that “We don’t have employees with disabilities, so why expend money making staff technology systems accessible?”. Is there something else going on? Some of the questions you have to ask about the history maybe a little awkward, but they do need to be asked in order to avoid repeating any mistakes or blunders of the past.
The good news, though, is that you are working with pretty much a blank slate. If you are introducing something new you have all the available options open to you.
The other good news in your favor is the availability of collected past experiences. What tends to succeed and what tends to fail is readily available knowledge. This knowledge has been combined into this central resource of guidance. (The centralized guidance contained in the Accessibility Switchboard Portal connects to other published resources that have been reviewed by experts working in the accessibility field.)
In at the deep-end?
Jumping in at the deep-end isn’t the best way to learn to swim. Sure, you could splash about and make a scene, but you won’t be able to convince others that you really know what you’re doing. Therefore, we suggest that the most effective way to follow the step-by-step guidance below is to first read the entire guide, second, read other articles and resources that are linked to, and after that circle back to begin Step 1. Consideration of the whole process first will provide a good foundation for subsequent strategic and tactical conversations with team members and other stakeholders .
Step-by-step: Starting an organization-wide accessibility program in a government department
Step 1. Conduct a systematic appraisal of the current situation
You know that there isn’t a current accessibility program, but do you know for sure that there hasn’t been any prior work that could form the basis of components of a program? There may already be an informal network that is ready to grow. Potential allies and supporters may be waiting for something to start, and they are waiting and hoping for someone to take the initiative.
The first step is to appraise the current situation at a level of detail that provides you, your team, and stakeholders, with enough information on what to do first as you start a program. There is no definitive line for what constitutes ‘enough’ information, but once you identify past history, your key stakeholders and any current accessibility challenges, you will quickly get a handle on what information is available, and (just as importantly) what information isn’t available to you.
Something to consider when gathering information early on is to be cognizant of pre-conceived notions and diminishing returns on investment of your time. You could spend a lot of time talking with peers and collectively formulating visions for what an accessibility program could be. You’ll hear a variety of opinions on what people think ‘might work’ and what they ‘instinctively know’ won’t have any chance for success. After you talk to your first five or six people, you’ll get the ‘institutional wisdom’ that has set in, and you’ll be hearing fewer and fewer new opinions with each additional interviewee. (Bear in mind that the people you are talking to are the ones who currently work in a department that has no accessibility program.)
There will be, of course, some key relationships to establish at first. You don’t want to put yourself in the potentially embarrassing predicament of being asked by an executive what your colleagues think of accessibility and having no answer. Plus, there’s a certain safety in numbers:
“It is appealing to think how quickly you or a few people could turn around an institutional self-study or action plan on web accessibility. Harder and slower is including others in your efforts, especially if they don't share your zeal or purpose. However, if you are to accurately paint a picture of your institution's web accessibility, identify the opportunities for change, and prepare for the barriers in front of you, it is crucial that you have the participation of stakeholders from across the institution. It is ultimately in your own interests to hear many different voices, experiences, and perceptions.”
—Cyndi Rowland, ‘The Institution's Web Accessibility Study Team’
So, how many relationships is enough, and what are the long-term implications of creating them? Without any existing formal program in place, you’ll be establishing relationships without a solid foundation or executive backing for the program. In this situation, whatever desires you express to your colleagues might carry less weight than is needed to spur action. This approach has been tried on many occasions by so-called ‘champions’ or ‘evangelists’ of accessibility. They may be amenable to hearing your case, but until their job descriptions are updated to reflect accessibility performance requirements, it’s more than likely that they won’t be able to commit (or promise) resources to support accessibility goals. So, while it is useful to build a small number of relationships in order to collect allies, an important point of note is that this is not the time to assign responsibility and accountability for accessibility. This will come later in the process (Step 3).
Instead of gathering opinions forever on what people think they want to do or don’t want to do, the focus should be on finding out what they can and are doing now. In future steps, you’ll be planning what should be done to achieve organization-wide accessibility. Without finding out everyone’s starting point on what they are doing now, making a plan for how to get to a desirable destination will be inherently difficult. What’s more, without any kind of systematic organizational assessment of current capabilities, it will be hard to make any presentation to decision makers on what current problems need addressing.
The main thing to do in Step 1, therefore, is to conduct an organizational maturity assessment, measuring accessibility progress across departments. A maturity assessment is a tool that you can apply to each department in the organization in order to find out whether accessibility has been addressed at any level, or if accessibility has been non-existent. In the course of such an assessment you can systematically challenge your own underlying assumptions of how accessibility is being addressed, by asking targeted questions to contacts in various sub-departments of the organization, and documenting responses in terms of program maturity measures.
How can I assess organizational maturity with respect to accessibility?
In this initial Stage, we suggest conducting an informal maturity assessment. That is, without any stated authority for your questions, you may be met with reluctance to provide information—“Who is this busy-body asking all these questions?”. A small number of allies can help in conducting the initial assessment. If there are known detractors, we suggest avoiding them at this stage, but take a best guess on their maturity levels based on publicly available information (e.g., How accessible is the website? What policies have been publicly posted?).
In a subsequent Step (#3), you should conduct a formal maturity assessment with executive authority backing it up (i.e., you’re no longer a ‘busy-body’; you’re doing the bidding of the executive in charge). For now though, the informal maturity assessment should provide you with a fairly good idea of where things will be starting from across the entire government department.
Your appraisal exercise will inevitably generate thoughts and ideas on what to do next. You may find that a range of initial alternatives and preferences may be voiced by team members and other stakeholders even without any solicitation. We recommend that any such alternatives be noted, but not acted upon at this time. Instead of taking immediate action steps, we recommend an examination of suggested alternatives based on the collected experiences of others who have already successfully tackled these tasks in other organizations. The various alternatives are explained in the narrative below, as well as in the additional Switchboard articles and guides linked to in each Step of the process.
The next Step is in two parts. We present alternatives to consider for (A) technical compliance; and (B) nontechnical (organizational) aspects of accessibility across your organization. In implementation, it is critical that both aspects be considered and addressed.
Step 2A. Consider compliance alternatives
For ‘compliance’, we are mainly focused on technical aspects of Information and Communications Technology (ICT) accessibility, although there are some aspects of compliance that are non-technical. By ‘compliance’ we mean ensuring that the ICT products and systems that are used in your organization will be operable by people with disabilities. This includes, but is not limited to, such products and systems as:
- Your external facing website, mobile apps, and your social media presence
- Your internal intranet, and the enterprise software systems used by staff
- The software systems and services you develop for use by your customers and your staff
- The telephone system, staff security (door entry) systems, information kiosks etc. used by your staff and customers
- The hardware used (printers, copiers, computers, cellular phones, etc.)
- Teaching and training systems and content
This may seem like a daunting list at first, especially if you are new to or unfamiliar with accessibility considerations on one or more of the products and systems listed above. But, the task can be broken down into bite-sized chunks, and it should certainly be a task that is divided up between team members. (In addition, a step-wise approach could be incorporated into plans later on, whereby certain aspects are prioritized based on immediate needs. Each item can be addressed for accessibility, but not everything will be changed overnight.) For each applicable product, we recommend the following sub-steps:
- CONSUMER RESEARCH: Of the available products on the market, which are already considered to be accessible? Which one(s) are considered to be universally designed for use by all people, including those who have disabilities? Which one(s) don’t seem to address accessibility at all?
Where do I get good / accurate information on ICT (web, software, mobile, electronic document) accessibility?
- USABILITY: How do you know that the products you buy, or the products you are developing and delivering, can actually be used by people with disabilities? You may already have a department or team that addresses usability (/ergonomics / human-factors / user-experience) for certain aspects of your ICT. What additional things could that team do to include people with disabilities as participants in studies?
How do I ensure my products work for people with disabilities?
- TESTING: While usability as a discipline addresses whether people can effectively use a given product, we are separating testing as a discipline to assess whether a product conforms to requirements, standards and guidelines that are already known to enable ICT accessibility. How will you test a product that you are developing? There are available test methods, with procedures and tools for examining the operability of ICT.
What procedures should I use to test my ICT for accessibility?
- PROCUREMENT: If you are buying ICT for use by your staff, and if you are buying the services of developers to make ICT products for you, how do you and the vendor share your accessibility requirements and needs? A vendor may claim that their product is ‘accessible’, but what does this mean in terms of testing? Does it mean that it has gone through an actual test process and a usability evaluation? Or does it mean that the vendor hopes that it is accessible, but they don’t have any hard data to base that on? In procurement language, it is possible to clarify understanding on both sides, to the point where both parties can agree whether something has been demonstrated to be operable and usable by people with disabilities.
How do I tie accessibility procurement language to integrated quality assurance testing?
Step 2B. Consider organizational alternatives
You may ask which departments in your organization should be addressing accessibility in their operations. The answer would be any department that deals with people, or things used by people. (By definition, ‘people’ includes as a subset people with disabilities.) This pretty much turns out to be every department, even though traditionally, accessibility has been something that was addressed by one or just a few individual departments.
The same could be said for ICT. Which departments use ICT for their staff, and for interacting with customers? All of them.
This might be a new idea for an organization, that the ICT used by people should be addressed across the entire organization. The introduction of new ideas by necessity brings the need to update organizational culture. (‘Culture’ is short-hand for what people say combined with what people do.)
So, we have a need to update organizational culture in order to address the needs of people with disabilities in the design, development, procurement and use of ICT. It may sound like a tall order, but as with the compliance aspects, taking things in bite-size chunks, and distributing the workload among a team provides a solution to the perceived size of the tasks ahead.
Again, others have experienced successes in the implementation of accessibility across organizations. The following are suggested categories to examine when considering and needed change in organizational culture:
- ALLOCATION: In an organizational department in which accessibility hasn’t traditionally been a systematically addressed, the question of ‘why not?’ (Step 1) must be followed by ‘what now?’. The first item in the ‘what now’ list should be the question of who is responsible and accountable for the new requirement to systematically address accessibility. Ultimately, there should be someone at the top level of the organization who is responsible and accountable, and they need to have people who are responsible and accountable for their individual departments reporting to them. Those at the department level need to ensure that the sense of accountability for accessibility (and therefore, the associated tasks to do with making products and services accessible) is shared among the department’s staff and the various teams working with it. This is a necessary top-down allocation of accountability and responsibility. It cannot come from the bottom up, and it cannot be applied from peer to peer.
How can I distribute the responsibility and accountability for accessibility?
- CHANGE: One of the most common reactions to having responsibility and accountability formalized by executives is to regard it as something new and additional in terms of duties. While it may be new, it should not be seen as an additional responsibility. Instead, this should be viewed as clarifying that a previously overlooked responsibility is now being addressed. After all, people includes people with disabilities. If the budget was previously being used to serve only the 80% or so of the population that don’t have disabilities, that oversight needs correction. Will everyone see it this way? Some may not. They may see it as change that is not in their best interest. They may resist because they feel it is ‘extra work’. Applying the lessons of change management can help ease transitions to newly apportioned responsibility and accountability assignments.
How can I overcome resistance to change in an organization-wide accessibility project?
- PRACTICE: With some departments going from zero to something, or from piecemeal to regular operation, there is inevitably going to be a transition phase. In addition to the lessons of change management, there are lessons from what people have done to ease the transition and implement successful organization-wide accessibility programs in the past.
How can I ease the accessibility journey from organizational policy to practical implementation?
- HIRING: If you endeavor to make your ICT compliant (Step 2A), but then you don’t take measures to ensure that people with disabilities are hired, promoted, and represented at the various levels of the organization, then there will be a clear deficiency in the organizational culture. It’s one thing to include an inclusivity statement at the footer or each job posting, and it’s another to make sure that the time and reporting system can by used with screen reader technologies. It’s yet another thing to make sure the person making the hiring decision knows about the time and reporting system’s accessibility in advance of the process for hiring anyone. Given that one of the primary purposes of making ICT accessible is so that people with disabilities can get an education and find employment, if you don’t embrace diversity in your hiring processes, then who will? If you want what people say and what people do to be inclusive, then be inclusive in hiring.
I have a job applicant who has notified me they have a disability. What should I do now?
- WORK ENVIRONMENT: It’s a fairly safe bet that a wheelchair using employee could get through your front door with an automatic door opener, along with delivery persons with carts, and anyone who simply has their hands full (universal/inclusive design delivers benefits for everyone). But, can a blind employee use your phone system? The ‘work environment’ includes all ICT that employees use.
How can I provide an accessible work environment?
- GOING BEYOND ‘COMPLAINTS’: A common legacy strategy for many organizations has been to employ a complaints process as their primary means of addressing accessibility. This is the reactive ‘whack-a-mole’ approach that diligently deals with problems as they arise but does little to systematically improve an organization’s operations and culture to create an inclusive environment where there isn’t a need to make a complaint. The reason why we describe this as a legacy strategy is that it’s been shown to not work as primary, secondary, or even tertiary strategy. People generally don’t complain, they just take themselves elsewhere. Experience shows that, for various reasons, people with disabilities complain even less than nondisabled persons. The most effective strategies are proactive; not reactive.
Beyond offering employees a complaint process: proactive measures to tackle accessibility issues
Note: In all aspects of accessibility (Steps 2A and 2B), there are accessibility professionals who can help with making transitions. There are various kinds of accessibility professional, and a plethora of services that can be provided. If the skills you need are not already in-house, then it may be worth investing the time to find the right accessibility professional to provide advice, guidance, training and assessments to help move along the technical and non-technical aspects.
How do I find a knowledgeable consultant?
Step 3. Get executive support
For the most important things that happen in an organization, the boss makes the decisions. The boss also decides to delegate some level of decision making to managers and other subordinates. But ultimately there is always someone at an executive level who delivers the edicts that govern how an organization should be run.
Without the support (the backing) of executives—on how accessibility should be addressed as an organization-wide initiative—the accessibility program will always be struggling. This has been seen time and time again, where accessibility programs have been started up, only for everyone else in the organization to be unaware that they were entered into the program: “Please can we help you make your new website accessible?” doesn’t carry as much weight as “We have a policy and procedure requiring us to create accessible content. And, did you know that when principles of accessible design are applied, a large subset of other users benefit, not just those with disabilities? The accessibility team can help you get started with learning how to achieve greater accessibility for all users while in turn meeting our legal obligations.”
Note: There are other terms for ‘executive’ used, such as ‘leadership’, the ‘board’, and ‘senior management’. In either case, you should be identifying who has the ultimate decision-making authority and the ability to delegate tasks to the various departmental leaders and their subordinates.
How do you get the executives on your side, and to adopt inclusive practices across your organization? If it were as simple as asking nicely, it would be a ubiquitous practice already. It must be in the best interest of the executives, and they are looking out for what is in the best interest of the organization. To be better prepared to persuade, we suggest addressing the following points:
- MOTIVATION: The first question you’ll likely encounter is “Why should we do this?”. You need to be prepared with an answer.
Why would I want to address accessibility in my organization?
- INVESTMENT: The second question you’ll likely encounter is “How much will this cost?” Again, you need an answer.
Does accessibility have to be expensive?
- MAKING THE PITCH: Understanding motivating factors, and understanding cost considerations is a useful grounding, but then you need to make the pitch to the executives. (You may have to make the pitch first to managers, and then up the chain to get to the appropriate decision makers). Think of this as ‘asking nicely’ on steroids.
Introducing organization-wide accessibility approaches: a guide to making a successful pitch
Note: In making the pitch (above), the second of three suggested pitches to executives involves conducting a formal maturity assessment. This follows on from the informal (initial) maturity assessment that was conducted in Step 1. A formal maturity assessment should be conducted only with the authority and backing of executives, which we suggest is best obtained in the first of the three pitches.
Step 4. Establish stakeholders and goals
Once the authority has been established (following Step 3), then it is time to identify stakeholders to include in initial goal-setting. The aim in Step 4 is to get consensus on the strategy and the tactics that will be used in implementing the new program.
The goals should be realistically assessed in terms such as available staff, resources, and expertise. In initial phases of an implementation, setting achievable short-term goals can translate into long-term success: the aspirational must be checked against the attainable. However, setting goals of some progress initially should not be allowed to devolve into allowing no progress from those who do not see it in their best interest to participate.
Note: You may encounter avoidance tactics such as sandbagging (“I don’t have time in my calendar to meet”; “I can’t send a delegate”), and shirking responsibilities (“This isn’t one of our priorities this year”; “We’ll let you come and fix this for us once we’ve finished our roll-out”). The key thing to remember is that, as a leader of an accessibility program, it isn’t your job to counter avoidance tactics. That’s the job of executives (i.e., return to Step 3 if you get negative push-back).
A resource for identifying stakeholders for organizational accessibility initiatives…
Strategic IT Accessibility: Enabling the Organization by Jeff Kline. This book provides background information and guidance for anyone wanting to make a start in organization-wide change. One chapter is devoted to identifying relevant stakeholders across the whole organization.
Step 5. Design, plan and implement the program
It’s as easy as that… Design, plan, and Implement the program.
Okay, so maybe it isn’t as easy as 1, 2, 3. However, the same sort of systematic approach that would be taken for any new program in an organization can and should be taken for introducing organization-wide accessibility improvements. If you have a factory where there is no safety culture, you implement a safety program. If you’re making cars and there is no apparent sense of the importance of quality throughout the workforce, you’ll quickly learn that you can’t compete with other manufacturers. If you have a work culture that isn’t yet inclusive, you can implement a program for achieving inclusion.
People in your organization know how to implement organization-wide programs. Use them.
A resource for implementing organizational accessibility initiatives…
The 8-Step Implementation Model is a web-based article by WebAIM. This model provides a guided example of implementation of web accessibility in a large organization. Although focused on web accessibility, the model can serve as a grounding in the principles of implementation that can be applied in other circumstances.
Step 6. Monitor, and periodically update
Your plans should include periodic (at least annual) maturity assessments (See Step 1) to monitor progress.
Is accessibility still a part of annual reports? Is it still addressed in all hands meetings, staff retreats, professional development events etc.? In other words, is accessibility still considered both a priority and an agenda item in work tasks?
Not everything will go to plan. Just as with any other kind of implementation it may be necessary to go back and adjust plans, include new stakeholders, re-establish executive orders, and so on. Just the same as is done for safety and quality, lapses happen when there is no appropriate monitoring. In some fields this can lead to disasters at worst, and lost customers at best. In the accessibility domain, this can lead, simply, to a reversion to the previous state, i.e., one in which inclusion efforts were either nonexistent or sporadically addressed. And no-one wants that.
Any plans on the scale of a typical government department will encounter hitches along the way. This is the reason why continuous monitoring and periodic updates (Step 6) are essential. But, some hitches go beyond the missed deadline or the procedural oversight. Contingency planning is a must to ensure that a project doesn’t become seriously derailed. When big problems arise, who takes charge, and who can make things right?
One of the most common problems seen in the evolution of government departments is to focus strongly on regulatory compliance while having a weak or non-existent program that examines the day-to-day experiences of people with disabilities (either as members of the public, or as employees). This, of course, exposes the department to additional risks. While you are starting out on your goal to create an organization-wide accessibility program, the opportunity is there to include proactive measures of success for the people who are the intended beneficiaries of having an accessibility program. We have developed a companion Switchboard guide on this topic:
Beyond maturity assessments: Proactive measures to gauge the success of government accessibility programs
There will also be a need to consider legal contingencies. First though, there are proactive things that you can do to reduce the likelihood of getting sued:
What are the steps I can take to reduce the likelihood of getting sued over the accessibility of my ICT?
Even if you do reduce your risk through proactive measures, this won’t eliminate all risk of being on the receiving end of a legal action. You should have a contingency plan in place in case you do need to react:
What should I do when I’m approached with an ICT accessibility complaint or legal action?
A final thought…
The alternate text for our cover image for this guide is “A blank notebook sits on the desk. A cup of coffee might inspire writing.” The accompanying quote is from Professor Ken Eason, one of the foremost authorities on organizational behavior. One of the missives in this field is that ‘common sense is not all that common’. When presented with the concepts in this guide, we would hope to inspire ‘light bulb’ moments of inspiration. However, when the light-bulb dims back down, we urge you to return to the question of why an accessibility program isn’t currently in place? We may all get together and agree that having such a program would be self-evidently common sense, but then what do we do with our blank piece of paper? The current and prospective employees with disabilities—and the citizenry as a whole—deserve your best answers.
A resource providing high-level government implementation strategies…
The Technology Accessibility Playbook is a 2016 guide from the CIO Council of the US Federal Government. The document includes twelve strategies (‘plays’) for establishing a government department accessibility program. Each play contains brief strategy questions and a checklist of elements to consider throughout the process.
A resource website for understanding disability initiatives in government…
Buy ICT 4 All is an information portal from G3ict (the Global Initiative for Inclusive Information and Communication Technologies). The portal is an annotated collection of guides, documents, and resource links on public procurement of accessible technology. The portal’s Resource Center provides information on Public Procurement and Policy, ICT Accessibility Standards, Case Studies, and other resources.
About this article
This article is published as part of The Accessibility Switchboard Project, an initiative of the National Federation of the Blind Jernigan Institute with support from the members of the Accessibility Switchboard Project Community Of Practice, and from the Maryland Department of Disabilities.
The Accessibility Switchboard. Starting an organization-wide accessibility program: A guide for government departments. June 2018, Version 1.0. National Federation of the Blind Jernigan Institute. Available: https://www.accessibilityswitchboard.org/
Feedback, additions and updates
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