Purchase College Electronic and Information Technology Accessibility Policy and Procedures

 

(last updated July 31, 2019)

Policy

Purchase College - State University of New York (PC) is committed to ensuring that people with disabilities have an opportunity equal to that of their nondisabled peers to participate in the College’s programs, benefits, and services, including those delivered through electronic and information technology.

This Electronic and Information Technology Accessibility (EITA) policy covers all electronic information used to promote and deliver the college’s programs and services. The policy applies to procurement, development, implementation, training, and ongoing maintenance of all online or electronic materials.

Benchmarks All online and electronic information used to promote and deliver the college’s programs and services must be in compliance with federal and state laws. The accessibility of online materials and functionality will be measured according to the current ratified versions of W3C’s Web Content Accessibility Guidelines (WCAG) Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) for web content, which are incorporated by reference. 

Ensuring equal and effective electronic and information technology access is the responsibility of all College administrators, faculty, and staff.

Procedures

The purpose of these procedures is to provide processes by which College 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.

This policy and procedure applies to the following areas:

1. Web Accessibility
2. Instructional Materials Accessibility
3. Document Accessibility
4. Electronic Media Accessibility
5. Software, Hardware, and Systems Accessibility
6. 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” is defined by the ADA as 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:

1. The internet and intranet websites,
2. Content delivered in digital form,
3. Content management systems,
4. Electronic books and electronic book reading systems,
5. Financial management systems,
6. Databases,
7. Learning management systems,
8. Classroom technology and multimedia,
9. Classroom equipment such as podiums, control systems, computers, etc.

Electronic and information technology 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, access control systems, security systems, 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.

Within the Purchase College governance structure, the Accessibility Committee (AC) is charged with improving awareness and compliance with accessibility requirements, providing training to the campus community, and managing Barrier Reports used by the campus community to report accessibility issues, and assists in developing policies and procedures to improve the College’s accessibility posture. The Accessibility Committee is Chaired by the College’s Chief Diversity Officer, and includes representatives from Campus Technology Services (CTS), Office of Disability Resources (ODR), the Library, and others.

 1. Web Accessibility

• Scope

These procedures apply to all Purchase College - State University of New York (PC) web pages and programs used to conduct PC business and activities including web resources used in courses.

• Standards

All web pages, websites and web-based software published, hosted or used (including remotely hosted sites and software) by the College will meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG)  published by the W3C. All materials will meet Level AA guidelines with limited exceptions allowed where technology does not permit. All College websites will link to the College’s main Accessibility page which includes a statement of commitment to Web accessibility.

• Responsibility

All Administrative Departments and Academic Programs:

• Will comply with the accessibility standards when creating content, web sites, and application programs or services. 
• Will ensure that online activities are hosted in accessible environments and that online content follows standards outlined by this policy.

Campus Technology Services and Communications and Creative Services:

• Will ensure that the CMS and other web production or web object creation software will itself be accessible and will produce accessible Web pages.
• Will coordinate instruction and support for campus community members creating online content so that all individuals who author web content will do so in accordance with required standards.
• Will ensure that support is available for faculty and staff creating accessible content.

Campus Accessibility Committee:

• Will compile and maintain data to track compliance with the policy and procedures and make recommendations to the campus ADA Compliance Officer for addressing problems.
• Implementation
• These procedures will ensure that all new or modified content and services are accessible and meet the WCAG Level AA standard.
• Upon a specific request for access by an individual with a disability, the College will update legacy documents to be in compliance with the WCAG Level AA standard or the College will otherwise make the content available to the individual in a timely manner and in an equally effective accessible format.

 2. Instructional Materials Accessibility

• Scope

These procedures apply to all electronic instructional materials (syllabi, textbooks, presentations, handouts, etc.).  This includes electronic instructional materials delivered within the College’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.).  If the curriculum includes student production of shared media or documents, students should be encouraged to follow these same standards.

• 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 should meet all applicable standards (see 1.2) and guidelines outlined in this policy.

• Responsibility

All Academic and Administrative Departments and Programs:

• Will ensure that instructional materials comply with all requirements outlined in this policy.
• Will ensure that all resources provided for student use will have assistive technologies not limited to but including accessible computer stations, screen reading software, and screen magnification.

Faculty and instructional staff:

• Will create and present accessible courses and instructional material including but not limited to: documents that meet WCAG standards, images with alternative text, media with appropriate captioning, presentations with alternative text for embedded images, etc.
• Reading systems and software that are used for textbook delivery should meet these guidelines “Accessibility Screening Methodology Guidelines and Checklist.”

Teaching, Learning, and Technology Center:

• Will provide instruction and support for campus community members creating accessible online courses and online instructional content.
• Will facilitate hosting of online activities in an accessible learning management system and related hosted systems that are accessible.
• Will ensure that third party plug-ins or add-ons for learning management systems are accessible.

Library:

• Will perform regularly scheduled “accessibility scans” on library collections, including, but not limited to, e-journals, databases, and e-books to ensure that library materials meet accessibility standards. This will include 3^rd party vendors of programs and platforms for information to house and deliver these collections. For internal systems, software and/or resources accessibility scans will be conducted within a reasonable and responsive timeframe, prioritized by the educational activities of the college and the academic calendar. For third party and external vendor systems accessibility scans will be conducted as outlined in their contract.
• Will report to vendors and the Accessibility Subcommittee of the DEIC any issues discovered that impact accessibility of the collections or platforms on which collections reside.

Campus Technology Services:

• Will ensure that all applications developed on campus are accessible and meet the WCAG AA level, WAI-Aria and ATAG standards.
• Will ensure that computer labs have assistive technologies including, but not limited to, accessible workstations, screen reading software, and screen magnification.
• Will collaborate with Capital Facilities Planning to develop classrooms providing accessible electronic and information technology.
• Will support distributed campus units needing assistance with accessibility in departmentally supported technology classrooms.
• Will publish - within existing lists of equipment and software - the accessibility programs, services, and features for each smart classroom and computer lab.
• Will work with the Office of Disability Resources as a clearing house for information about assistive technology and modifications recommended for departmental computer labs.

Capital Facilities Planning / Office of Disability Resources

• Will collaborate with Campus Technology Services, Facilities Maintenance, and other campus offices to ensure that all new and renovated campus spaces use accessible electronic and information technology.

Campus Accessibility Committee:

• Will compile and maintain data to track compliance with the policy and procedures and make recommendations to the ADA Compliance Officer for addressing issues as they arise.

3. Document Accessibility

• Scope

These procedures apply to all College-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 updated and made accessible as needed or when reused.

• Standards

Electronic documents must be accessible.  Electronic interaction with College policies, procedures, notifications, and other documents must be accessible and as effective and useable for persons with disabilities as they are for persons without disabilities.

Electronic documents must meet the standards and guidelines outlined in the Guidance on Applying WCAG to Non-Web Information and Communications Technologies, published by the W3C as the Working Draft 13 December 2012.

• Responsibility

All departments and programs and all College employees:

• Will follow the accessibility requirements outlined in this policy when creating and using electronic documents. 

Library / TLTC:

• The Library will implement procedures for ensuring that documents digitized or hosted by the Library for research purposes are accessible to individuals with disabilities.
• The Library and TLTC will provide training and support for production of accessible instructional materials.

Campus Technology Services / Office of Disability Resources / Communications and Creative Services:

• Will provide accessible document instruction and support for campus community members.
• Implementation Summary
• All new documents (including but not limited to PDF, Word, Excel and PowerPoint files) will be accessible.
• Legacy documents must be updated and remediated as they are used.

4. Electronic Media Accessibility

• Scope

All media resources used in College programs and activities must be accessible. For example, this includes, but is not limited to: instructional, directional/informational, and promotional media.

• Standards

Media resources will be closed captioned and audio-described and audio resources will be transcribed.  Transcripts may be provided as an alternative accommodation for media resources that the College does not have rights to caption.

• Responsibility

All departments, programs, instructors, and employees:

• Will use 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 accurately captioned or transcribed.
• Will update any non-transcribed audio and any non-captioned/non-described video that is in current use whenever possible.
• Will produce or use only communications and promotional materials that are captioned, audio-described or transcribed.
• Will produce live-streamed events that are captioned, audio-described or transcribed.

Library:

• Will collect transcribed audio and captioned video resources that are available for faculty, staff, and student use.
• Will (upon request) assist patrons in identifying materials that are captioned whenever available.

Teaching, Learning, and Technology Center:

• Will incorporate captioning and media accessibility information into any relevant training.
• Will maintain and continue to provide instructions on media accessibility (such as captioning and audio-describing media and transcribing audio).

Campus Technology Services and Production Services:

• Will incorporate information about accessibility into training on equipment.
• Will incorporate captioning and media accessibility information into any relevant training.
• Will produce live-streamed events that are captioned, audio-described, or transcribed.

Communications and Creative Services:

• Will ensure that internal and external electronic promotion of college programs, services and events makes use of accessible channels and materials.
• Will incorporate information about accessibility into all training, such as website content management or customer relation management systems.

Campus Accessibility Committee:

• Will advocate for campus-wide captioning and transcribing solutions that:
  • Provide assistance with obtaining permission to caption and audio-describe.
  • Disseminate information to the College community about college protocols related to accessible electronic media including a list of approved vendors to perform captioning.

• Implementation Summary

• All media (professionally or internally produced) used in courses and shared on campus websites or media storage sites will be captioned or transcribed according to recommended Described and Captioned Media Program (DCMP) standards.
• For publicly facing archives, which contain too many items to remediate at once:
• a note about accessibility must be provided:

Accessibility of Archived Materials:  Purchase College is working to ensure that all materials stored in college archives are fully accessible.  If you encounter materials that you are interested in using that are not accessible please write us a note using the “Report Accessibility Barriers” form. Please be sure to name and list the materials you are interested in, and we will prioritize conversion of those items for you, taking into account the timing of your need for the instructional materials. You will be notified when your requested archive files are converted and your request is completed. 

• Items will be prioritized for remediation based on frequency of use.
• a form will be offered to prioritize captioning upon request

5. Software, Hardware, and Systems Accessibility

• Scope

All software, hardware, and systems used or acquired by the college must be accessible and compatible with assistive technology.   Examples include, but are not limited to:

• learning management systems,
• content management systems,
• library systems,
• email systems,
• kiosk information systems,
• administrative systems including but not limited to recruiting, student information systems, finance, and human resources, procurement, advancement, tutoring, career development, etc.

Software includes:

• 3^rd party software that is hosted or on premise,
• Internally developed software and systems,
• freeware,
• shareware,
• desktop,
• enterprise,
• plug-ins,
• add-ons,
• mobile apps.

Software accessed through a web browser must also be accessible and is discussed under section 1 of these procedures.

• Standards

Purchase College will use the following standards to determine accessibility:

US Access Board’s Guide 508 Standards - Software Applications and Operating Systems

• Responsibilities

All Departments and Units:

• Will ensure that any software, hardware, services, or local interfaces and modifications that they procure or provide are accessible.

Campus Technology Services:

• Will ensure that assistive technologies are immediately available to the campus community working in campus labs or on publicly-accessed campus computers.
• Will install assistive technologies in a timely manner for campus employees including student employees.
• Will develop applications (web, desktop, etc.) that are accessible and meet WCAG, WAI-Aria, and ATAG standards (extrapolated as needed for non-web environments).

Instructional Technology Advisory Committee (ITAC):

• Will consider accessibility when weighing proposals for funding to ensure accessibility where appropriate as per this policy.
• Will assist in communicating accessibility standards and requirements to ensure that existing and new instructional technology services and facilities are accessible.

Campus Accessibility Committee

• Will develop and coordinate campus “best practices” for ensuring campus software, hardware and software systems are accessible.

6. Procurement

• Scope

This process applies to all College purchases of Electronic and Information Technology (EIT) software, hardware and services.

• Standards

Purchase orders and contracts for software, services, and hardware will include the following clause:

“Vendor acknowledges New York State Information Technology Policy: Accessibility of Web-Based Information and Applications (NYS-P08-005), and acknowledges that equipment and software being provided enable equal and effective access to all individuals in accordance with federal and state laws and regulations, including, but not limited to W3C’s Web Content Accessibility Guidelines (WCAG) Level AA and the Web Accessibility Initiative Accessible Rich Internet Applications Suite (WAI-ARIA) for web content, the Americans with Disabilities Act of 1990 (ADA), Section 504 of the Rehabilitation Act of 1973, and Section 508 of the 1973 Rehabilitation Act.”

• Responsibility

All Departments, units and college employees:

• Must purchase or otherwise acquire accessible EIT, in accordance with these procedures, whenever possible.
• Procurement recommendations that are vetted through ITAC should include information on accessibility compliance.

Governance of Administrative Systems and Processes:

• The Governance of Administrative Systems and Processes (GASP) committee that provides oversight and coordination for administrative systems will serve as a resource for guiding purchases of accessible administrative systems, services, and hardware.
• GASP will institute procedures to ensure that all new and modified systems are evaluated to ensure that they meet accessibility requirements.

Library:

• Will institute procedures to ensure that EITs purchased for research support are evaluated for accessibility requirements.

Purchase College Association (Auxiliary Service)s:

• Will institute procedures to ensure that all electronic technology systems and services purchased are evaluated and meet accessibility requirements.

Purchasing Department:

• Will provide written justification for all provisional-use waivers that are granted.
• Will share all provisional-use waivers with the Accessibility Subcommittee for posting on the accessibility website to invite public comment through the barrier report form. 
• Will forward requests for exceptions and provisional-use waivers to the College ADA Compliance Officer for public comment and will include the written comments from all parties in a written recommendation to the President for consideration on requests for exceptions and provisional-use waivers.

7. Adoption

The Purchase College Electronic Information Accessibility Policy and Procedures becomes effective immediately upon the signature of the College President below.