ICT Accessibility Policy: Procedures Draft 1

Note

Please note that these procedures are still under development.  If you have questions about the procedures or would like assistance creating accessible solutions, please contact the IT Accessibility Coordinator at itaccessibility@uconn.edu or at 860-486-9193.

Definitions

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.

“ICT Accessibility Committee (ICTAC)” The ICTAC will be established to coordinate efforts to improve the accessibility of UConn Information Technology. The ICTAC will be made up of IT and Technology Managers from departments and schools across the University. The IT Accessibility Coordinator will be the Chair of the ICTAC.

“Information and Communication Technology” or “ICT” includes digital information, technology, content, 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 information and communication 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.

“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 SABA or HuskyCT.

“Internal-facing” includes ICT that is currently password protected.  These resources require a login before the user can view or interact with them.

“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 all websites in the uconn.edu domain.

1.External-Facing ICT

1.1 Web Accessibility

1.1.1 Scope

These procedures apply to all University Web pages and programs used to conduct University business and activities, including UConn-based web resources used in courses.

1.1.2 Standards

Web pages, websites and web-based software published or hosted by the University are to 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. All web pages are to meet Level AA guidelines.

1.1.3 Roles

All Departments and programs:

  • Comply with the web accessibility standards outlined in 1.1.2 when creating web content, sites, and programs.

1.1.4 Resources

ITS:

  • Provide instruction and support for campus community members creating University websites and content so that individuals who author web content can be trained according to these standards.
  • Recommend that any Content Management System and other web production or web object creation software proposed and supported by central IT be accessible.
  • Provide support for non-central IT staff for creating accessible University websites and content.

Additional Resources:

1.2 Instructional Materials Accessibility

1.2.1 Scope

These procedures apply to electronic instructional materials (including but 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 slides provided for a livestreamed lecture.

1.2.2 Standards

All electronic instructional materials, optional and required, will be accessible and as effective and useable for persons with disabilities as they are for persons without disabilities. Instructional materials and activities will be made available to all students at the same time.

All instructional materials must meet all applicable standards and guidelines outlined below.

1.2.3 Roles

All Departments and programs:

  • Provide instructional materials that comply with all requirements outlined in these procedures.
  • Maintain departmentally owned classrooms that use and deliver accessible electronic and information technology.
  • Include assistive technologies including but not limited to screen reading software and screen magnification in departmental computer labs provided for student use.
  • Assess instructional applications developed on campus (web, desktop, etc.) for accessibility 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:

  • Create and present accessible instructional material.

ITS:

  • Facilitate hosting of online activities in an accessible learning management system and related hosted systems (such as web conferencing) that are accessible.
  • Use accessible electronic and information technology in IT-designed and supported Technology Classrooms.
  • Monitor informational IT web pages and implement recommended accessible software and procedures found on those pages.

Library:

  • Maintain an accessible website.
  • 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.

1.2.4 Resources

CSD:

  • Serve as a clearing house for information about assistive technology and modifications.

ITS:

  • Provide instruction and support for campus community members creating online courses and online instructional content.
  • Coordinate support for non-central IT and campus units needing assistance with accessibility in departmentally supported technology classrooms.

Additional Resources:

1.3 Document Accessibility

1.3.1 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.  Documents not currently in use must be made accessible when used or upon request if the document sought is not currently accessible.  For assistance, contact at ITAccessibility@uconn.edu.

1.3.2 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 Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies, published by the W3C.

1.3.3 Roles

All Departments and programs/University employees:

  • Implement procedures for ensuring that electronic document produced, maintained or distributed by the department are accessible to individuals with disabilities.

Library:

  • Implement procedures for ensuring that materials digitized or hosted by the library for research purposes are accessible to individuals with disabilities.

1.3.4 Resources

ITS:

  • Provide accessible document instruction and support for campus community members.

Additional Resources:

1.4. Electronic Media Accessibility and Captioning

1.4.1 Scope

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.

1.4.2 Standards

Video media resources must provide captioning that is accurate, synchronous, complete, and properly placed.  Audio resources must be transcribed and be accurate.

1.4.3 Roles

All departments, programs, instructors and employees:

  • Purchase only captioned versions of audiovisual media whenever possible.  Caption all other media that will be used on the web or in instruction.
  • Purchase only transcribed versions of audio media whenever possible.
  • Update any non-transcribed audio and any non-captioned video that is in current use.

Library:

  • Maintain a library of transcribed audio and captioned video resources that are available for faculty, staff, and student use.
  • Maintain a record of commercial availability of copyrighted media resources.
  • Provide transcribed audio and captioned video resources upon request for existing non-transcribed audio and non-captioned.

ITS

  • Continuously assess classroom and presentation equipment to ensure caption-compatibility.

University Communications:

  • Produce only new communications and promotional materials that are captioned or transcribed.
  • Assess and update existing inaccessible communications and promotional materials upon use.

1.4.4 Resources

Library:

  • Assist faculty in identifying materials that are captioned prior to purchase.

CETL:

  • Incorporate captioning and media accessibility information into training.
  • Provide assistance in creating videos and coordinating captioning services.

CSD:

  • Coordinate captioning services on behalf of students registered with the Center for Students with Disabilities.

ITS:

  • Maintain and continue to provide instructions on media accessibility (such as captioning media and transcribing audio) as well as how to show captioned media in classrooms.
  • Incorporate accessibility into faculty training on AV equipment information about accessibility.

Additional Resources:

 

2. Internal-Facing ICT

2.1 Instructional Materials Accessibility

2.1.1 Scope

These procedures apply to electronic instructional materials (syllabi, textbooks, presentations, handouts, etc.) that are internally facing.  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.).

2.1.2 Standards

Internally facing electronic instructional materials, optional and required, will be accessible and as effective and useable upon request for persons with disabilities as they are for persons without disabilities.

Instructional materials must meet all applicable standards and guidelines outlined below.

2.1.3 Roles

All Departments and programs:

  • Provide instructional materials that comply with all requirements outlined in these procedures.
  • Maintain departmentally owned classrooms that use and deliver accessible information and communication technology.
  • Include assistive technologies including but not limited to screen reading software and screen magnification in departmental computer labs provided for student use.
  • Assess instructional applications developed on campus (web, desktop, etc.) for accessibility 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:

  • Create and present courses and instructional material that can be readily made accessible, upon request.

ITS:

  • Facilitate hosting of online activities in an accessible learning management system and related hosted systems (such as web conferencing) that are accessible.
  • Use accessible information and communication technology in ITS-designed and supported Technology Classrooms.
  • Monitor informational ITS web pages and implement the ITS-recommended lab software and procedures found on those pages.

Library:

  • Implement an accessible search engine that can search across all library collections, including, but not limited to, e-journals, databases, and e-books.
  • Make all content in library collections, including, but not limited to, e-journals, databases, and e-books, accessible upon request.
  • 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.

2.1.4 Resources

ITS:

  • Coordinate support for non-central IT and campus units needing assistance with accessibility in departmentally supported technology classrooms.

CSD:

  • Serve as a clearing house for information about assistive technology and modifications recommended.

CETL:

  • Provide instruction and support for campus community members creating online courses and online instructional content.

Additional Resources:

2.2 Document Accessibility

2.2.1 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. Documents not currently in use must be made accessible upon request if the document sought is not currently accessible.  For assistance, contact at ITAccessibility@uconn.edu.

2.2.2 Standards

Electronic documents must be made accessible upon request.

Electronic documents must meet the standards and guidelines outlined in the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies, published by the W3C.

2.2.3 Roles

All Departments and programs/University employees:

  • Implement procedures for ensuring that electronic document produced, maintained or distributed by the department are accessible to individuals with disabilities upon request.

Library:

  • Implement procedures for ensuring that materials digitized or hosted by the library for research purposes are made accessible to individuals with disabilities upon request.

2.1.4 Resources

ITS:

  • Provide accessible document instruction and support for campus community members.

Additional Resources:

2.3 Electronic Media Accessibility and Captioning

2.3.1 Scope

Media resources used in internal-facing programs and activities are to be made accessible upon request.

2.3.2 Standards

Video media resources must provide captioning that is accurate, synchronous, complete, and properly placed upon request.  Audio resources must be transcribed and be accurate upon request.

2.3.3 Roles

All departments, programs, instructors and employees:

  • Purchase only captioned versions of audiovisual media whenever possible.  Caption all other media that will be used on the web or in instruction upon request.
  • Purchase only transcribed versions of audiovisual media whenever possible.
  • Upon request, update any non-transcribed audio and any non-captioned/non-described video that is in current use.

Library:

  • Maintain a library of transcribed audio and captioned video resources that are available for faculty, staff, and student use.
  • Maintain a record of commercial availability of copyrighted media resources.

ITS:

  • Continuously assess classroom and presentation equipment to ensure caption-compatibility.

University Communications:

  • Produce only new communications and promotional materials that are captioned or transcribed.

2.1.4 Resources

ITS:

  • 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 accessibility into faculty training on AV equipment information about accessibility.

CETL:

  • Incorporate captioning and media accessibility information into training.
  • Provide assistance in creating videos and captioning services.

CSD:

  • Provide assistance to faculty with Center for Students with Disabilities-registered students in their classes.

Library:

  • Assist faculty in identifying materials that are captioned prior to purchase.

Additional Resources:

 

3. Software, Hardware and Systems Accessibility

Software, Hardware and Systems Accessibility

3.1 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.

3.2 Standards

The University of Connecticut will use the following standards to determine accessibility:

US Access Board’s Guide 508 Standards - Software Applications and Operating Systems (https://bit.ly/2bMTGto)

3.3 Roles

All Departments and programs/University employees:

  • Assess software, hardware, local interfaces and modifications and electronic systems for accessibility.
  • Assess applications developed on campus (web, desktop, etc.) for accessibility 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.

Center for Students with Disabilities:

  • Make assistive technologies immediately available to students working in campus labs or on publically-accessed campus computers.

Human Resources:

  • Make assistive technologies available in a timely manner for campus employees including student employees.

IT Accessibility Coordinator and Working Group:

  • Coordinate campus processes for ensuring campus software, hardware and software system accessibility.

4. Procurement

Procurement

4.1 Scope

This process applies to all University purchases of Information and Communication (ICT) software, hardware and services.

4.2 Standards

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

“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.”

4.3 Roles

All Departments and programs/University employees:

  • Purchase or otherwise acquire accessible ICT, in accordance with these procedures.
  • Provide written justification for all provisional use waivers and post such waivers on the accessibility website.

4.4 Resources

IT Accessibility Coordinator and ICTAC:

  • Serve as a resource for ICT purchases and other acquisitions for compliance with accessibility requirements.

5. Exceptions

Exceptions

5.1 Scope

The University of Connecticut’s ICT Accessibility policy requires that all digital information and digital services developed, acquired, managed, or otherwise under UConn’s responsibility meet the university’s accessibility standards. The goal of an exception is to document the process by which we will ensure that the university provides effective access, with substantially equivalent ease of use, to digital information and digital services for eligible individuals in a timely manner.

5.2 Required Information

Exception requests must contain the following elements in order to be considered.

5.2.1 Requesting Unit Contacts

Contact information for the below parties:

  • The individual making the request
  • The requesting unit
  • The staff responsible for oversight and administration of the Equally Effective Access Accommodation Plan (EEAP)

5.2.2 Rationale

The requesting unit must document how this request fits into one or more of the following categories:

  • Compliance is not technically possible or feasible given current technology
  • The digital information or digital service is used by a limited audience, when the audience is known, and whose needs can be accounted for in advance
  • For third party, vendor delivered products, no accessible alternative for the digital information or digital service exists
  • Making the Digital Information or Digital Service accessible would require extraordinary measures that constitute an undue burden to the university
    • The industry standard is non-compliant
    • The ICT that best meets the University’s needs is not the most accessible option, when other more accessible options have been considered

Note that for the purposes of determining if an undue burden exists, the University of Connecticut is considered to be a single entity, and thus a burden would be analyzed according to the impact to the institution as a whole and not to the unit requesting the exception.

5.2.3 Equally Effective Access Accommodation Plan (EEAP)

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 EEAP 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 waved, and the requesting 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.

5.2.4 Communication Plan

The requesting 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.

5.2.5 Compliance Plan

Requesting 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 requesting 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

5.2.6 Accessible Alternative Justification

The requesting unit must document if their purchasing process evaluated other alternatives that were more accessible. If so, the requesting unit must explain what business reasons necessitate the selection of the less accessible option. If more accessible alternatives were not evaluated, or did not exist, the unit must document their plan to ensure that a search for a more accessible alternative is conducted when the contract or exception expires.


Last modified August 8th, 2019