Procedure for Electronic and Information Technology Accessibility Policy 1310
Effective Date: N/A
Purpose
The purpose of these procedures is to provide processes by which University administrators, faculty, and staff will create, obtain and maintain all electronic and information technology (EIT) in a manner that ensures that EIT is accessible to individuals with disabilities.
These procedures apply to the following areas:
- Web Accessibility
- Instructional Materials Accessibility
- Document Accessibility
- Electronic Media Accessibility
- Software, Hardware and Systems Accessibility
- Procurement
Definitions
"Accessible” means that individuals with disabilities are able to independently acquire the same information, engage in the same interactions, and enjoy the same services within the same timeframe as individuals without disabilities, with substantially equivalent ease of use.
“Disability” means a physical or mental impairment that substantially limits one or more major life activities.
“Electronic and information technology" or "EIT" includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, the Internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems ("clickers"), and office equipment such as classroom podiums, copiers and fax machines. It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. This term includes telecommunication products (such as telephones), information kiosks, Automated Teller Machines (ATMs) transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.
"Equally effective” means that the alternative format or medium communicates the same information in as timely a fashion as does the original format or medium.
“Legacy websites” are University Program and Department websites published before July 30, 2013.
1. Web Accessibility
1.1 Scope
These procedures apply to all University Web pages and programs used to conduct University business and activities including web resources used in courses.
1.2 Standards
All web pages, websites and web-based software published, hosted or used (including remotely hosted sites and software) by the University must meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG) 2.0 (http://www.w3.org/TR/wcag2ict/) published by the W3C as follows. All pages will meet Level AA guidelines with limited exceptions outlined at Exhibit A. All University websites, unless technically impossible, must link to the University’s main Accessibility page which includes a statement of commitment to Web accessibility.
1.3 Responsibility
All Departments and programs must:
- Comply with the web accessibility standards when creating web content, sites, and programs.
- Ensure that online activities are hosted in accessible environments and that online content follows standards outlined by this policy.
IT (Central, Distributed & 老虎机攻略Online) must:
- Provide instruction and support for campus community members creating 老虎机攻略 websites and content so that individuals who author web content can be trained according to these standards.
IT (Central) must:
- Ensure that any Content Management System and other web production or web object creation software proposed and supported by central IT will be accessible and will produce accessible Web pages.
IT (Distributed) must:
- Ensure that support is available for distributed IT staff for creating accessible 老虎机攻略 websites and content.
EITA Coordinator and Digital Accessibility Committee must:
- Coordinate instruction and support for campus community members creating 老虎机攻略 websites and content so that individuals who author web content will do so in accordance with WCAG 2 Guidelines AA Standards.
- Compile and maintain data to track compliance with the policy and procedures and make recommendations for addressing problems.
1.4 Implementation Summary[i]
- The University implemented a strategy to ensure that web pages that provide essential student functions are accessible.
- All University Program and Department websites, including legacy pages, unless technically impossible, must contain a clear statement (or a link to a statement) describing the University’s commitment to web accessibility and a method to report barriers and/or to receive an alternative equally effective accessible format.
- All webpages published or hosted by the University must be accessible according to WCAG 2.0 Level AA standard (applicable on or after July 30, 2013).
- Upon a specific request for access by an individual with a disability, the University must update legacy pages to be in compliance with the WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, or the University must otherwise make the content available to the individual in a timely manner and in an equally effective accessible format.
(return to the start of Procedures)
2. Instructional Materials Accessibility
2.1 Scope
These procedures apply to all electronic instructional materials (syllabi, textbooks, presentations, handouts, audio, video, etc.). This includes electronic instructional materials delivered within the University’s learning management system, in face-to-face classes, or in an alternate fashion (email, blogs, etc.) and electronic instructional activities (online collaborative writing, web conferencing, etc.).
2.2 Standards
All electronic instructional materials, optional and required, must be accessible and as effective and useable for persons with disabilities as they are for persons without disabilities. Instructional materials and activities must be made available to all students at the same time.
All instructional materials must meet all applicable standards and guidelines outlined in this policy.
2.3 Responsibility
All Departments and programs must:
- Ensure that instructional materials comply with all requirements outlined in these procedures.
- Ensure that departmentally owned classrooms use and deliver accessible electronic and information technology.
- Ensure that all departmental computer labs and media production studios provided for faculty and student use will have assistive technologies, not limited to, but including accessible computer stations, screen reading software, screen magnification. Studios will include documentation or guidance on how to create accessible media content.
- Ensure that all applications developed on campus (web, desktop, etc.) are accessible according to principles of WCAG 2.0 AA level, WAI-Aria 1.0, and ATAG 2.0 standards (extrapolated as needed for non-web environments).
Faculty and instructional staff must:
- Create and present accessible courses and instructional material.
老虎机攻略Online must:
- Provide instruction and support for campus community members creating online courses and online instructional content.
- Facilitate hosting of online activities in university approved accessible learning management systems and related hosted systems (such as web conferencing) that are accessible.
IT (Central & Distributed) must:
- Use only accessible electronic and information technology in IT-designed and supported Technology Classrooms.
- Monitor informational IT-web pages and implement the EITA-recommended lab software and procedures found on those pages.
IT (Central) must:
- Coordinate support for distributed IT and campus units needing assistance with accessibility in departmentally supported technology classrooms.
- Serve as a clearinghouse for information about assistive technology and modifications recommended for departmental computer labs.
Mansfield Library must:
- Maintain an accessible website and implement an accessible search engine that can search across all library collections, including, but not limited to e-journals, databases, and e-books.
- Conduct monthly accessibility scans to ascertain whether any posted content is inaccessible. The Library will notify content authors if corrections to pages are needed and of reasonable timelines for corrections to be made. The Library will note if corrective action has been taken during the next monthly scan.
EITA Coordinator and Digital Accessibility Committee must:
- Compile and maintain data to track compliance with the policy and procedures and make recommendations for addressing problems.
2.4 Implementation Summary[i]
- Resolved accessibility issues related to the University’s learning management systems cited in the OCR Complaint (chat and forums).
- Identified a University strategy to ensure the ongoing accessibility of its learning management systems.
- Ensured that the University’s library website meets the WCAG 2.0 Level AA standard, as set forth in Appendix A of the Resolution Agreement.
- Ensured that EIT used in classrooms (including, but not limited to, clickers, podiums, blogs, and other software) is accessible.
- Ensured that the Mansfield Library search engine meets the WCAG 2.0 Level AA standard, as set forth in Appendix A to this Agreement, which can search across all library collections, including, but not limited to, e-journals, databases, and e-books.
- Ensured that campus labs meet EITA recommended installations and procedures.
(return to the start of Procedures)
3. Document Accessibility
3.1 Scope
These procedures apply to all University-produced and maintained or distributed electronic documents. Electronic documents include, but are not limited to, word processing documents, PDFs, presentations, publications and spreadsheets which are scanned, uploaded, posted, or otherwise published or distributed electronically. Legacy documents must be made accessible when used.
3.2 Standards
Electronic documents must be accessible. Electronic interaction with University policies, procedures, notifications and other documents must be as effective and useable for persons with disabilities as it is for persons without disabilities.
Electronic documents must meet the standards and guidelines outlined in the , published by the W3C as the Working Draft 13 December 2012.
3.3 Responsibility
All Departments and programs/University employees must:
- Follow the accessibility requirements outlined in these procedures when creating and using electronic documents.
- Provide accessible document instruction and support for campus community members.
IT/老虎机攻略Online/Mansfield Library:
The Mansfield Library must implement procedures for ensuring that materials digitized or hosted by the library for research purposes are accessible to individuals with disabilities.
EITA Coordinator and Digital Accessibility Committee must:
- Compile and maintain data to track compliance with these procedures and make recommendations for addressing problems.
- Work with Central and Distributed IT, DSS, Mansfield Library and 老虎机攻略Online to coordinate campus-wide PDF solutions.
3.4 Implementation Summary[i]
- All straight-text documents (including PDF, Word, Excel and PowerPoint files) must be accessible.
- Created a working group to address: 1) accessible scientific and mathematical documents and 2) accessible documents from campus publications such as the Montanan, Montana Business Quarterly, etc.
- Developed strategies for producing accessible scientific and mathematical documents and accessible documents from publications.
- Created a working group to address EPUB/EDUPUB possibilities, production and purchase.
- Strategy in development for 老虎机攻略’s integration of EPUB/EDUPUB processes.
(return to the start of Procedures)
4. Electronic Media Accessibility
All departments must purchase and produce only accessible multimedia and update existing inaccessible media as it is put into use.
4.1 Scope
All media resources used in University programs and activities must be accessible. For example, this includes, but is not limited to, media that is instructional, informational, marketing, and promotional.
4.2 Standards
Video media resources must be closed captioned and audio-described and audio resources must be transcribed.
4.3 Responsibility
All departments, programs, instructors and employees must:
- Purchase only captioned versions of audiovisual media whenever possible. Will ensure that all other media that will be used on the web or in instruction is captioned.
- Purchase only transcribed audio and audio-described versions of audiovisual media whenever possible.
- Update any non-transcribed audio and any non-captioned/non-described video that is in current use.
- Use only transcribed audio and closed-captioned media with audio-descriptions that are made available in a timely manner to the class and will only assign such media as course material, whether optional or required.
Mansfield Library must:
- Maintain a library of transcribed audio and captioned video resources that are available for faculty, staff, and student use.
- Provide a descriptive (bibliographic) record, including accessibility features, of physical audio and video resources that the library has available for faculty, staff, and student use.
- Assist faculty with identifying materials that are captioned and audio-described prior to purchase.
老虎机攻略Online must:
- Incorporate captioning, audio description, and other media accessibility information into training.
IT (Central) must:
- Ensure all classroom and presentation equipment is caption-compatible and the default on all TVs, etc.
- Maintain and continue to provide instructions on media accessibility (such as captioning and audio-describing media and transcribing audio) as well as how to show captioned media in classrooms.
- Incorporate into faculty training on AV equipment information about accessibility.
University Relations must:
- Produce only new communications and promotional materials that are captioned, audio-described or transcribed.
EITA Coordinator and Digital Accessibility Committee must:
- Coordinate campus-wide captioning and transcribing solutions that:
- Provide assistance with obtaining permission to caption and audio-describe.
- Disseminate information to the University community about university protocols related to accessible electronic media including a list of approved vendors to perform captioning and audio description.
4.4 Implementation Summary[i]
- All videos (professionally or internally produced) used in courses and shared on campus websites or video storage sites (such as YouTube and Vimeo, etc.) must be captioned according to recommended Described and Captioned Media Program (DCMP) standards.
- Students with disabilities may request that recordings of course sessions and presentations created for and during a course, and in use only during that course, be captioned and audio -described as a reasonable modification.
- Assess audio description availability and create a plan toward audio description standards and for use on campus. Audio description videos will be acquired and created when technology permits.
(return to the start of Procedures)
5. Software, Hardware and Systems Accessibility
5.1 Scope
All software, hardware and systems purchased must be accessible and must produce accessible products. Accessible, in this context, means compatible with assistive technology. Examples of software, hardware and systems include, but are not limited to, learning and content management systems, library and email systems, and administrative management systems such as finance, registration and human resources, and all software, hardware and software services used for student services. Software includes freeware, shareware, desktop, enterprise, subscription and remotely-hosted options. Software that is accessed through a web-browser must also be accessible and is discussed under Section 1 of these procedures.
5.2 Standards
The 老虎机攻略 will use the US Access Boards' Guide 508 Standards to determine accessibility.
All Departments and programs/University employees must:
- Ensure that their software, hardware, local interfaces and modifications and electronic systems are accessible.
- Ensure that all applications developed on campus (web, desktop, etc.) are accessible according to principles of WCAG 2.0, WAI-Aria 1.0, and ATAG 2.0 standards (extrapolated as needed for non-web environments).
IT (Central and Distributed) must:
- Ensure that assistive technologies are immediately available to students working in campus labs or on publically-accessed campus computers.
- Ensure that assistive technologies are available in a timely manner for campus employees including student employees.
EITA Coordinator and Digital Accessibility Committee must:
- Coordinate campus processes for ensuring campus software, hardware and software system accessibility.
5.4a Software Implementation Summary[i]
- Institutionalized processes for purchase of only accessible EITs, except when it would fundamentally alter a program or when it is not technically feasible to do so and in such cases the University provides accessible alternate EITs.
5.4b Hardware Implementation Summary[i]
- Reading systems and software that are used for textbook delivery must meet the (DAISY Consortium)
- Campus scanners must have an OCR profile/option.
- Accessible clickers must be selected.
- Developed a strategy for review of academic and other hardware with the intent that only hardware with accessible options should be selected for use in academic courses and campus activities including such things as door swipes and educational technology.
(return to the start of Procedures)
6. Procurement
6.1 Scope
This process applies to all University purchases of Electronic and Information Technology (EIT) software, hardware and services.
6.2 Standards
Purchase orders and contracts for EIT must include the following clause:
“Contractor acknowledges that no University funds may be expended for the purchase of information technology equipment and software for use by employees, program participants, or members of the public unless it provides blind or visually impaired individuals with access, including interactive use of the equipment and services, that is equivalent to that provided to individuals who are not blind or visually impaired. (18-5-603, MCA.) In addition, Contractor acknowledges that such information technology equipment and software will provide equal and effective access to all individuals in accordance with federal and state laws and regulations, including, but not limited to the Americans with Disabilities Act of 1990 (ADA), Section 504 of the Rehabilitation Act of 1973, and Section 508 of the 1973 Rehabilitation Act.”
6.3 Responsibility
All Departments and programs/University employees must:
- Purchase or otherwise acquire accessible EIT, in accordance with these procedures.
EITA Coordinator and Digital Accessibility Committee must:
- Serve as a resource for EIT purchases and other acquisitions for compliance with accessibility requirements.
- Provide written justification for all provisional use waivers and post such waivers on the accessibility website. Will provide requests for exceptions to the University ADA/504 Team for public vetting and will include the written comments from the ADA/504 Team in a written recommendation to the President for consideration on requests for exceptions.
6.4 Implementation Summary[i]
- Developed and instituted procedures requiring the University to purchase or recommend only EITs that provide the same programs, benefits, and services as they do to individuals without disabilities, except when it would fundamentally alter a program or when it is not technically feasible to do so, in which case the procedures require the University to provide accessible alternate EITs.
- Implemented as part of its request for proposal process a requirement that bidders meet the accessibility standards of WCAG 2.0 Level AA for web-based technology (as set forth in Appendix A to this Agreement) and Section 508 of the Rehabilitation Act and the Americans with Disabilities Act for other EITs; and requiring or encouraging, at the University’s discretion, as part of any contract with its vendors, provisions in which the vendor warrants that any technology provided complies with these standards and any applicable current federal and state disability laws.
(return to the start of Procedures)
Appendix A: Required AA Standards
- 1.2 Time-based Media
- Captions are provided for all live audio content in synchronized media.
- Audio description is provided for all prerecorded video content in synchronized media.
- 1.4 – Distinguishable
- The visual presentation of text and images of text has a contrast ratio of at least 4.5:1, except for the following:
- Large Text: Large-scale text and images of large-scale text have a contrast ratio of at least 3:1;
- Incidental: Text or images of text that are part of an inactive user interface component, that are pure decoration, that are not visible to anyone, or that are part of a picture that contains significant other visual content, have no contrast requirement.
- Logotypes: Text that is part of a logo or brand name has no minimum contrast requirement.
- 2.4 – Navigable
- Headings and labels describe topic or purpose.
- Any keyboard operable user interface has a mode of operation where the keyboard focus indicator is visible.
- 3.2 – Predictable
- Navigational mechanisms that are repeated on multiple Web pages within a set of Web pages occur in the same relative order each time they are repeated, unless a change is initiated by the user.
- Components that have the same functionality within a set of Web pages are identified consistently.
- 3.3 – Input Assistance
- For Web pages that cause legal commitments or financial transactions for the user to occur, that modify or delete user-controllable data in data storage systems, or that submit user test responses, at least one of the following is true:
- Reversible: Submissions are reversible.
- Checked: Data entered by the user is checked for input errors and the user is provided an opportunity to correct them.
- Confirmed: A mechanism is available for reviewing, confirming, and correcting information before finalizing the submission.
Appendix B: EITA Software Accessibility & Procurement
(The original Appendix B was removed due to updated 老虎机攻略 processes and procedures. Please read about on the Guide section of the Accessibility.)