ICT Policy Procedures

Intent and Purpose

In accordance with the Information and Communication Technology 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. As technology can rapidly evolve, this information is subject to change and is intended to be a living document.

Any questions regarding this content or IT accessibility may be directed to the IT Accessibility Coordinator at ITAccessibility@uconn.edu.

“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.

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.

References

  1. Americans with Disabilities Act (ADA)
  2. Section 504 of the Rehabilitation Act
  3. Section 508 of the Rehabilitation Act
  4. Connecticut State Law

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.

“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 the Online Learning Center (Saba) or 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.

External-Facing ICT

“External-facing” includes ICT that is not currently password protected.  These resources are available to the UConn community and to the general public. As part of the University’s commitment to accessibility, parties responsible for external-facing ICT must make all material accessible to create a more inclusive environment for all persons, including people with disabilities.

Web Accessibility

University web pages and programs used to conduct University business and activities, including UConn-based web resources used in courses, must be accessible.  Web pages, websites, and web-based software newly published, redesigned, modified, or hosted by the University are to meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG) 2.0 published by the W3C. All web pages are to meet Level AA guidelines.

Instructional Materials

Electronic instructional materials (including but not limited to websites, documents, media, syllabi, textbooks, presentations, and handouts) must be accessible and as effective and usable for persons with disabilities as they are for persons without disabilities.  This includes electronic instructional materials delivered within the University’s electronic instructional activities.  Instructional materials must meet applicable standards and guidelines as outlined in these procedures.  An example of external-facing instructional materials is an online training publicly available on a website.

Document Accessibility

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.  Documents produced prior to the effective date of the Information and Communication Technology (ICT) Accessibility Policy (July 24, 2019)  that are not in current use must be made accessible when used or upon request if the document sought is not accessible. Accessible 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.

Electronic Media and Captioning

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.

Internal-Facing ICT

“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. Nothing in this part is intended to discourage making the electronic instructional materials accessible absent a request. As part of the University’s commitment to accessibility, parties responsible for internal-facing ICT are encouraged to make all material accessible to create a more inclusive environment for all persons, including people with disabilities.

Instructional Materials Accessibility

Electronic instructional materials (syllabi, textbooks, presentations, handouts, etc.) that are internally facing must be accessible upon request.  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.). Such material,  when made accessible upon request, must be as effective and usable for persons with disabilities as they are for persons without disabilities.  Accessible instructional materials must meet applicable standards and guidelines as outlined in these procedures.

Document Accessibility

University-produced, maintained or distributed electronic documents must be accessible upon request.  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.  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.

Electronic Media and Captioning

Media resources used in internal-facing programs and activities must be accessible upon request.  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.

Software, Hardware, and Systems Accessibility

Software, Hardware, and Systems Accessibility

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.  The following standards are to be used to assess accessibility: US Access Board’s Guide 508 Standards - Software Applications and Operating Systems (https://bit.ly/2bMTGto)

Procurement

Procurement

When the University purchases  Information and Communication (ICT) software, hardware and services, such software, hardware and services must be accessible.  This includes required course materials, like iClickers or MatLab.  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."

Exceptions

Exceptions

The University of Connecticut’s ICT Accessibility policy requires that all digital information and digital services developed, acquired, managed, or otherwise be accessible. An exception to the policy and/or the procedures may be considered. The goal of an exception is to document the process by which the University 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. 

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

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)

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.

 

Equally Effective Access Accommodation Plan (EEAAP)

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 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.

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.

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

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.