Policy Procedures

Policy Procedures

In accordance with the Digital Accessibility Policy, the following procedures outline standards and guidelines to ensure digital information, communication, content, and technology is designed, developed, and procured to be accessible to people with disabilities. Digital accessibility is a shared responsibility, and every member of our community plays an essential role in creating inclusive, usable, and accessible digital experiences for all. As technology can rapidly evolve, this information is subject to change and is intended to be a living document.

Any questions regarding this content, IT Accessibility, or to contact the Digital Accessibility Committee, please contact the IT Accessibility Coordinator at itaccessibility@uconn.edu.

The “Digital Accessibility Committee (DAC)” is established to coordinate efforts to improve the accessibility of UConn Information Technology and digital environments. The committee will promote inclusive digital practices, guide campus-wide digital accessibility initiatives, and ensure alignment with federal, state, and institutional accessibility requirements. The DAC will include representatives from marketing and communications, University Communications, website support teams, procurement, instructional design and educational technology, IT and technology management, and staff who support students with disabilities. The IT Accessibility Coordinator will be the Chair of the committee. Additional members or subject-matter experts may be invited to participate as needed.

Table of Contents

Accessibility Standards

The University follows these recognized standards:

The University must meet the requirements of the Title II of the Americans with Disabilities Act by April 26, 2027.

This means the University’s digital content – websites, mobile apps, and social media – must comply with the Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA technical standard. New content created on or after April 24, 2024, must be accessible at launch. Older digital content still in use by the University must be accessible. If older content is not in use but needs to remain on websites, it must be placed on a page or a section of a page with the word “Archive” so end users know the content may not be accessible. The site for UConn’s Office of the President provides an example of older digital content properly marked as “archived.”

Available Assistance

There may be times that departments or individuals need assistance to ensure compliance. The following resources are available:

IT Accessibility Coordinator (ITS)

  • Website accessibility review.
  • Document remediation (PDF, Word, PowerPoint, etc.).
  • Strategizing website and/or document remediation.
  • Consulting during Procurement to ensure technology procured is accessible.

ADA Coordinator and Deputy ADA Coordinator with the Office for Inclusion and Civil Rights

  • The Office for Inclusion and Civil Rights monitors UConn’s compliance with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act to support equal access for people with disabilities.
  • OICR works to ensure the ability for all to participate in university-sponsored, non-course related programs or activities, in collaboration with the university community.

Instructor-Led Workshops & Self-Paced Learning

  • Instructor-led and self-paced opportunities available to employees, graduate students, and others.

University Websites

All University websites, whether public-facing, internal, or used in academic or administrative settings, must comply with accessibility standards. Website owners are responsible for ensuring the content on their website is accessible to everyone. In addition, a link to the Accessibility at UConn is provided on the website, typically in the footer where it is replicated on each webpage.

  • School, department, program, labs, research.
  • Faculty websites.
  • Student organizations.

If the website is on UConn’s WordPress Platform (Aurora), use the Site Admin Search to determine the website owner(s).

  1. Automatic Scanning: All University websites are scanned for accessibility using either Siteimprove or Blackboard Ally. Website owners can request access to either platform for their websites by sending an email to itaccessibility@uconn.edu. Please specify the websites and email address of person who needs access.
  2. Manual Testing: IT Accessibility will manually test all Go Live requests as well as any other University sites as needed. Please contact itaccessibility@uconn.edu if you would like your site manually scanned. Site owners can use a variety of tools to manually test their websites.

In limited situations, some kinds of web content and content in mobile apps do not have to meet WCAG 2.1, Level AA.

  • It is important that UConn prioritizes the content so we can choose the most important content—like current or commonly used information—to make accessible to people with disabilities quickly.
  • There are limited exceptions for some kinds of content that are not as frequently used or that may be particularly hard for UConn to address right away.
  • If an exception applies to certain content, it means that content would not have to meet WCAG 2.1, Level AA.

Archived web content: State and local governments’ websites often include a lot of content that is not currently used. This information may be outdated, not needed, or repeated somewhere else. Web content that meet all four of the following points would not need to meet WCAG 2.1, Level AA:

  • The content was created before April 2024, or reproduces paper documents or the contents of other physical media (audiotapes, film negatives, and CD-ROMs for example) that were created before the government must comply with this rule, AND
  • The content is kept only for reference, research, or recordkeeping, AND
  • The content is kept in a special area for archived content, AND
  • The content has not been changed since it was archived.

Preexisting conventional electronic documents: Some departments have a lot of old documents, like PDFs, on their website. It can sometimes be hard to make these documents meet WCAG 2.1, Level AA. Documents that meet both of the following points usually do not need to meet WCAG 2.1, Level AA, except in some situations:

  • The documents are word processing, presentation, PDF, or spreadsheet files; AND
  • They were available on the website or mobile app before April 2024.

Content posted by a third party where the third party is not posting due to contractual, licensing, or other arrangements with a public entity: Third parties sometimes post content on our websites or mobile apps. Third parties are members of the public or others who are not controlled by UConn. We may not be able to change the content third parties post.

Individualized documents that are password-protected: UConn sometimes use password-protected websites to share documents that are for specific individuals, like a patient statement. It might be hard to make all of these documents accessible right away for everyone, and there might not be a person with a disability who needs access to these documents. Documents that meet all three of the following points do not need to meet WCAG 2.1, Level AA:

  • The documents are word processing, presentation, PDF, or spreadsheet files, AND
  • The documents are about a specific person, property, or account, AND
  • The documents are password-protected or otherwise secured.

Preexisting social media posts: making all of our past social media posts accessible may be impossible. There also may be very little use to making these old posts accessible because they were usually intended to provide updates about things happening at the time they were posted in the past.

Documents

University-produced, maintained, or distributed electronic documents must be accessible.  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. Document creators can use available accessibility monitoring tools. Guidance and training are available to help produce accessible documents.

Documents created on or before April 2024 that are publicly accessible but no longer in use, do not need to be made accessible unless there is a request for an accessible version. This content must be appropriately labeled as “Archive” either at the top of the webpage or at the top of the webpage section header. See examples of how to label content as archive.

IT Accessibility can work with departments to help strategize and possibly remediate documents.

Multimedia

External-facing media resources used in University programs and activities must be accessible. This includes, but is not limited to, media that is instructional, informational, marketing, and promotional.  Video media resources must provide captioning that is accurate, synchronous, complete, and properly placed. Audio resources must be transcribed and be accurate. Media resources used in internal-facing programs and activities must be accessible upon request.

The Center for Students with Disabilities collaborates with faculty and staff to coordinate captioning services for students with disabilities in their academic and programmatic requirements. However, for an event, publicly accessed media, or a UConn department sponsored conference, it is the responsibility of the event planner or activity/building owner to ensure media is captioned.

Instructional Materials

Electronic internal-facing (behind a password) instructional materials (including but not limited to documents, media, syllabi, textbooks, presentations, and handouts) as part of University courses should be made as accessible as possible for persons with disabilities as they are for persons without disabilities. This includes electronic instructional materials delivered within the University’s electronic instructional activities. Any external-facing (publicly available) instructional materials must be accessible and as effective and usable for persons with disabilities as they are for persons without disabilities. Please follow the guidelines above for websites and documents for external-facing materials.

Procurement

When the University purchases  Information and Communication (ICT) software, hardware and services, such software, hardware and services must be accessible and produce accessible products. This includes required course materials.  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.  The following standards are to be used to assess accessibility: US Access Board’s Guide 508 Standards – Software Applications and Operating Systems

Purchase orders and contracts for ICT must include the following clause:

“Contractor agrees 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 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.  Pertinent policies can be found at policy.uconn.edu.”

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.

“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.

“Documents not currently in use” includes University Program and Department resources that are not currently posted to any website or learning management system, that are not in use in any course or related activities, and that are not distributed in any way.

“Electronic media” includes, but is not limited to, media that is instructional, informational, marketing, and promotional in a digital environment.

“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.

“External-facing” includes ICT that is not currently password protected.  These resources are available to the UConn community and to the general public.

“Instructional Materials” includes but is not limited to websites, documents, media, syllabi, textbooks, presentations, and handouts.  This includes electronic instructional materials delivered within the University’s electronic instructional activities, such as a module delivered through the University online learning management system (HuskyCT).

“Internal-facing” includes ICT that is currently password protected or is intended for University employees or students.  These resources require a login before the user can view or interact with them and/or are not available to the general public, such as videos used during a class lecture.

“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.

“University websites” includes any website or web page hosted by or for university units, organizations, faculty, students or staff that provides content related to University business or academic activities.

Temporary Exceptions

The University of Connecticut’s Digital Accessibility policy requires that all digital information and digital services developed, acquired, managed, or otherwise be accessible. A temporary exception to the policy and/or the procedures may be considered. If additional time is required to identify an accessible solution or to bring third‑party content into compliance, the unit responsible for the product or service must provide equally effective alternative access until full compliance with this policy is achieved. Interim measures must be replaced with permanent, accessibility‑compliant solutions, and a long‑term resolution must be reached within a reasonable timeframe appropriate to the complexity of the issue. Equally effective alternative access must be shared with the DAC and include the following:

  • Date of Temporary Exception
  • UConn Product Owner(s)
  • Product Description: Describe the product/service. Who is using it (Faculty, students, staff, visitors, etc.) and how many total UConn users? List the primary tasks these users need to accomplish (e.g., log in, submit a form, create content).
  • Reason for Temporary Exception: Please provide a reason for the Temporary Exception
  • Equally Effective Access Accommodation Plan (EEAAP) (details below)

This plan should address how access barriers in the digital information or digital service will be mitigated, and any benefits or opportunities afforded by the digital information or digital service will be provided, in a timely manner for eligible individuals who are unable to effectively use or interact with the digital information or digital service. Depending on the nature of the digital information or digital service, examples of an EEAAP might include:

  • Providing an alternative that effectively provides an equivalent result, e.g. an alternative software that performs the same or similar function.
  • Providing assistance to the eligible individual either in-person or over the phone.
  • Providing the digital information in a format that meets our accessibility standards.

This plan should take into account the criticality and timeliness of the digital information or digital service and address a method to ensure that the eligible individual can access the accommodation without any adverse consequences resulting from the need for the accommodation. This means, for example, that any deadlines imposed by the digital information or digital service that are not met due to the use of an accommodation must be waived, and the unit must have a plan to ensure this occurs.

Timeliness should be considered in light of the nature of the digital information or digital service. The accommodation plan should also address the timeline for delivering the accommodation, and the process by which any benefits or opportunities afforded by the digital information or digital service will be provided to the eligible individual.

The unit must document a plan to ensure that eligible individuals are made aware of the availability of the EEAAP, and the steps they must take to request access, if applicable. These communications should be readily accessible in the same places that any other general communication regarding access to the digital information or digital service are present.

Units should document their plan to bring the digital information into compliance with our accessibility standards. These plans might include:

  • Contract language obligating the vendor of third party digital information or digital services to bring their software or content into compliance within a period of time.
  • For internally developed digital information or digital services, a timeline for making them accessible and compliant with our accessibility standards.
  • Detailed collaboration with the vendor to bring their digital information or digital service into compliance.
  • Advocacy for accessibility by contributing to open source products and services.

The unit must, if the digital information or digital service is not internally developed, have a compliance plan if the third party fails to make their digital information or digital service accessible. Examples include:

  • Contract termination.
  • Financial penalties.
  • Selection of an alternative product.
  • Development of accessible front end.
  • Replacement with internally developed alternative.
  • Contributing to an open source product or service’s accessibility features.