Thanks for the thoughtful response — you're absolutely right that students should have access to their academic records, and any archiving solution, including K16’s, must support that. The key distinction here isn’t whether students can access records, but how that access is managed in a compliant, scalable, and low-risk way.
While "Past Enrollments" may seem to meet the spirit of the WCAG archive exceptions, there are a few important gaps:
1. Past Enrollments ≠ True Archival
Although students and faculty can’t edit past courses, the content is still served from the LMS, which is a production environment. WCAG 2.1 guidance — and related legal interpretations — tend to consider anything live in the LMS as "in active use," particularly because it’s hosted on a system designed for active learning. That opens the door to scrutiny over inaccessible materials, even if they're no longer taught.
K16’s Canvas Archiving, by contrast, moves content out of the LMS, clearly separating it from instructional environments. That separation is what makes the “dedicated area” argument bulletproof from a compliance standpoint.
2. Student Access Is Supported — But Securely
K16’s solution allows institutions to respond to student requests for past grades or coursework without putting the institution at compliance risk by keeping inaccessible course content live in the LMS. Access can be granted securely, and at scale, using search and retrieval tools — far more efficient than navigating Canvas manually.
3. Scalability & Risk Reduction
Even if “Past Enrollments” seems to work today, it scales poorly. There's no central admin visibility, no audit trail, and no ability to manage accessibility exceptions or requests across thousands of courses. K16’s archive is built for governance — searchable, reportable, and defensible.
Totally agree that each institution should consult their compliance office, but from what we’ve seen working with dozens of institutions and legal teams, moving content out of the LMS environment is what gives teams confidence they’re truly covered under the WCAG exception.
Happy to connect you with someone at a peer institution who's made this shift — they might share how it changed their posture around accessibility and governance.