Digital Accessibility

Policy 909

Purpose

1.1 This policy seeks to provide direction on creating an accessible experience that enhances usability for everyone. Implementation of this policy ensures all individuals have access to Digital Content, Resources, and Technology (“Digital Material”) provided by or on behalf of the University.

Scope

2.1 This policy applies to all University Constituents and third parties, under circumstances within the University’s control, who distribute, host, otherwise make available, or obtain Digital Material when conducting University Business. This policy applies to all University Digital Material regardless of audience or authentication required, including but not limited to:

1. Web: All websites, Web pages and Web-based software published or hosted by the University or used to conduct University business (including remotely hosted sites and software).
2. Instructional Materials: All electronic instructional materials, optional and required, must be Accessible. This includes, but is not limited to, syllabi, textbooks, presentations and handouts delivered within the University’s learning management system, via email or via another electronic means for face-to-face classes as well as online courses. It also includes electronic instructional activities such as instructional videos, online collaborative writing, Web conferencing, blogging, etc.
3. Documents: All University produced, maintained or distributed electronic documents must be Accessible. This includes, but is not limited to, word processing documents, PDFs, presentations, publications and spreadsheets that are scanned, uploaded, posted or otherwise published or distributed electronically.
4. Electronic Media: All electronic multimedia resources used by the University for instruction, communication, marketing, promotion or other academic or business purposes must be Accessible.
5. Software, Hardware and IT Systems: All software, hardware and IT systems used for academic and research purposes, administrative and business purposes, and customer service must be Accessible and produce Accessible products or content, which includes compatibility with assistive technology. Software, hardware and IT systems include, but are not limited to, learning management, content management, library systems, email, human resources administration, financial systems, course or event registration, freeware, shareware, enterprise systems and online or remotely hosted software.
6. Procurement/Purchases: The University will purchase electronic products and solutions, including, but not limited to, software, operating systems, Web-based applications, video and multimedia, that meet or exceed the above Accessibility standards. The University recommends that all requests for proposals from and contracts with vendors include language that outlines this requirement and provides stipulations for how the vendor is expected to demonstrate compliance.

Definitions

Accessible

When an individual with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use.

Digital Content, Resources, and/or Technology

(also referred to as “Digital Material”) Information, products, and services available for download or distribution in an electronic format or presented on a web page or through a web or other computer application.

Equally Effective Alternative

Alternative access to electronic content that, while not required to produce the identical result or level of achievement, affords an individual with a disability equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement in the most integrated setting appropriate to the individual’s needs.

Existing Digital Material

Includes all Digital Content, Resources, and Technology developed or procured prior to the effective date of this Standard, including Digital Content, Resources, or Technology that is archived.

Fundamental Alteration

A change so significant that it affects the essential nature of the instruction, program or activity provided.

New Digital Material

Includes all Digital Content, Resources, and Technology developed or procured after the effective date of this Standard.

Timely

as it relates to equally effective alternative access to electronic content, timely means that the individual with a disability receives access to electronic content in a reasonable time frame that meets the needs of the individual based on the circumstances.

Undue Burden

A significant disruption, expense, or difficulty that may result by the provision of accessible Digital Content, Resources, or Technology.

University Business

Activities carried out on behalf of Appalachian State University. University Business does not include activities organized or conducted by students when not designated to act on behalf of the University or by student organizations.

University Constituents

Appalachian State University faculty, staff, students, retirees, and other affiliates, contractors, distance learners, visiting scholars, and others who use or access Appalachian State University resources.

Policy Statements

Federal and State Requirement

4.1.1 The University will abide by Federal and state law requirements for Accessibility. Minimum requirements are described in this policy.

Minimum Standards

4.2.1 New Digital Material provided by Appalachian State University must meet minimum Accessibility requirements, except where doing so would impose a Fundamental Alteration or Undue Burden.

4.2.2 The following requirements apply to specific types of content, resources, and technology:

• Web Content Accessibility Guidelines (WCAG) 2.1 Level A or Level AA
• Authoring Tool Accessibility Guidelines (ATAG) 2.0 for tools that support web content authoring (e.g. HTML editors, software for generating websites, multimedia authoring tools, wikis and blogs, etc.)

These requirements serve as the basis for “Universal Design” principles. Use of these principles and compliance with the above requirements is intended to result in a welcoming and equitable digital experience for a wide range of people regardless of ability, disability, or use of assistive technology.

Responsibility of University Constituents

4.3.1 Digital accessibility compliance oversight is shared by the Office of Disability Resources, University Communications and Electronic Student Services, and Information Technology Services. These units provide resources and guidance to University Constituents in their responsibilities for Accessible Digital Media.

4.3.2 Oversight of this policy is delegated to the head of the University unit such as a Dean, Department Chair, Director, etc. This individual will serve as the Digital Accessibility Liaison and is responsible for compliance with all University policies relating to Digital Materials owned or used within their department by University Constituents.

The lead may designate another University employee to serve as a Digital Accessibility Liaison and address the accessibility of Digital Materials for the department.

The Digital Accessibility Liaison will take appropriate actions to uphold the accessibility of Digital Materials; communicate this policy, and other applicable accessibility information and practices; collaborate with the offices listed in Section 4.3.1, above, to respond to and resolve accessibility issues resulting from the development, use, maintenance, or purchase of Digital Materials within the department.

4.3.3 University Constituents are required to identify and prioritize Existing Digital Material that is not Accessible and develop an action plan to make that Existing Digital Material Accessible. In addition, upon request, University units must make any Existing Digital Material Accessible in a timely manner. In the event Existing Digital Material cannot be made Accessible, the University unit must provide an Equally Effective Alternative.

4.3.4 Digital Material compliance activities may be prioritized based on available resources, audience scope, and amount or size of the request or content. When a request for accessible digital content is received, the timeline for making the existing or archived Digital Material accessible must be expedited.

Ongoing Accessibility Evaluation

4.4.1 University Constituents are responsible for evaluating their Digital Material to ensure ongoing compliance with this Policy. Resources must be allocated to this ongoing evaluation, including designation of an appropriate number of Digital Accessibility Liaisons. Upon request, the Office of Disability Resources, University Communications, Electronic Student Services, or Information Technology Services may provide consultation and training assistance as needed.

Exceptions

4.5.1 The following are exceptions to this policy:

1. Minimal Use
   If Digital Material will be used by one individual or a small number of identified individual(s) (such as a small office or a research lab), and the responsible University Constituent confirms that the Digital Material is Accessible to the identified individuals, a de minimis exception applies to the procurement or development of such Digital Material. The Digital Material is not subject to the evaluation or remediation requirements of this Standard, and there is no requirement to provide an Equally Effective Alternative.This exception no longer applies when the Digital Material is used by individuals other than those originally identified when the Digital Material was developed or procured. Therefore, this exception shall not be used when Digital Material is intended for long-term use or by unknown future users. This exception also no longer applies when an individual notifies the University unit of an accessibility need related to the Digital Material. Once the exception no longer applies, the Digital Material is subject to all requirements of this Standard, including those related to identification and remediation of accessibility issues and to availability of an Equally Effective Alternative.
2. Fundamental Alteration or Undue Burden
   If an Equally Effective Alternative cannot be provided because doing so would impose a Fundamental Alteration or an Undue Burden, or if another requirement of this Standard cannot be met, the University Constituent responsible for the Digital Material must request an exception to this Standard through the Office of Disability Resources.

4.5.2 If the exception request is not approved, the Office of Disability Resources may assist the University Constituent in creating an action plan including researching other vendors with similar products or identifying alternative methods to achieve the same functional goals.

4.5.3 A written explanation for an exception must be tracked and made available upon request. All decisions are final.

Related Requirements

Appalachian State University shall also adhere to the following External Regulations and Consequences:

1. Section 508 of the Rehabilitation Act of 1973
2. Title II of the Americans with Disabilities Act of 1990 and its implementing regulations at 28 C.F.R. Part 35.
3. Section 504 of the Rehabilitation Act of 1973 and its implementing regulations at 34 C.F.R. Part 104.
4. North Carolina General Statute § 168A-7 - Discrimination in Public Service
5. Voluntary Product Accessibility Template (VPAT 2.0)
6. W3C’s Web Content Accessibility Guidelines (WCAG) 2.0, Level AA
7. Information and Communication Technology (ICT) Standards and Guidelines
8. Authoring Tool Accessibility Guidelines (ATAG) 2.0

Additional References

• Section 508 of the Rehabilitation Act of 1973, as amended
• Web Content Accessibility Guidelines (WCAG) 2.0 Level AA
• Authoring Tool Accessibility Guidelines (ATAG) 2.0 for tools that support web content authoring (e.g. HTML editors, software for generating websites, multimedia authoring tools, wikis and blogs, etc.)

Administrative Unit Contact

Office of Disability Resources - (828)262-3056 - Office Disability Resources