AD69 Accessibility of Information and Communications Technology
Contents:
Purpose
The Pennsylvania State University is committed to ensuring equal access to information, programs, and activities in accordance with the Americans with Disabilities Act (ADA), Title II and Section 504 of the Rehabilitation Act of 1973 for all its constituencies. This policy establishes terms, authority, responsibility, standards and procedures for the accessibility of Information and Communications Technology (“ICT”) and is considered necessary to meet this goal and ensure compliance with applicable local, state, and federal regulations and laws.
Scope
This policy applies to all official University ICT used to conduct core University academic and business activities. Individual Web pages published by students, employees or non-university organizations that are hosted by the University and do not conduct University related business are outside the scope of this policy.
Definitions
- Accessible
- Means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services within the same time frame as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally, and independently as a person without a disability. Accessible format –The structure and composition of digital documents and applications that are readable and usable by people with disabilities, using assistive technologies, and/or special configurations for user agents. These may include, but are not limited to, large print, screen reader access, recorded audio and DAISY format, HTML, MathML and other digital formats, video captioning, and Braille.
- Accessible format
- The structure and composition of digital documents and applications that are readable and usable by people with disabilities, using assistive technologies, and/or special configurations for user agents. These may include, but are not limited to, large print, screen reader access, recorded audio and DAISY format, HTML, MathML and other digital formats, video captioning, and Braille.
- Active ICT
- Means ICT that is regularly accessed by people greater than or equal to 5 times per year is considered active.
- Archived ICT
- Means ICT containing core administrative or academic information, official records, and similar information that are no longer available to a wide audience, but are subject to record retention plans. Note that technology components such as software applications and hardware devices are not placed in an archive status.
- Equally effective
- Means that the alternative format communicates the same information in as timely a fashion as does the original ICT. For interactive applications and hardware devices, “equally effective” means that the user action (e.g., registration) is accomplished in a comparable time and with comparable effort on the part of the requester.
- Equally Effective Alternate Access Plan (“EEAAP”)
- Means a plan that describes how to provide alternate access to the same information or services offered by a less-than-accessible technology. Having an EEAAP in place for technologies that are not fully accessible will help ensure that all students, faculty, and staff will have fair and equal access in a timely manner as required by law. An EEAAP is important if it is necessary to buy, develop, or use a technology that is not fully accessible. To provide equally effective alternate access, alternates are not required to produce the identical result or level of achievement for persons with or without disabilities.
- Information and Communication Technology
- Means Information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information, as well as any associated content. ICT includes, but is not limited to, internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, content management systems, classroom technology, instructional materials, student response systems ("clickers"), and equipment such as classroom podiums, copiers, and fax machines. ICT includes telecommunications products (such as telephones), information kiosks, Automated Teller Machines (ATMs), transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), equipment maintained and services operated by third-party vendors, and related resources.
- Legacy ICT
- Means ICT that is accessed less than 5 times per year.
Standards
Penn State has adopted widely accepted international and national accessibility standards and guidelines in order to ensure compliance with federal laws and regulations, particularly Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973. Penn State strives to ensure that all Active ICT comply with the Penn State Accessibility Standards and Procedures, which are incorporated into this policy by reference, including without limitation the then-current version of the W3C WAI Web Content Accessibility Guidelines and related guidance documents and instructional materials (the “Standards”).
Policy
Active ICT
Active ICT should strive to be in compliance with the applicable standards and guidelines described in the STANDARDS section of this policy.
Each University campus, college, department, program, or unit must establish its own priorities and timetables for updating Active ICT that does not meet the Standards or otherwise have an EEAAP, or plan for its transition to archival status or its removal. Priority must be given to creating accessible Active ICT for core institutional information such as coursework, registration, advising, admission, and catalogs; and student, faculty, and staff information.
Legacy ICT
When feasible, Legacy ICT should be updated to be in compliance with the Standards. In the event Legacy ICT does not meet the Standards and a request for equal access to that ICT has been received, the unit responsible for the Legacy ICT must make the Legacy ICT accessible in compliance with the Standards or obtain an EEAP.
Consultation on Legacy ICT update planning is available through your unit’s assigned Accessibility (Web) Liaison or IT Accessibility, accessibility@psu.edu.
Archived ICT
ICT resources in archive status must be made available in an accessible format to any individual eligible for, and needing access to, such content. The unit responsible for its maintenance is responsible for providing the Archived ICT in an accessible format or obtaining an EEAAP.
Equally Effective Alternate Access Plan
If inaccessible ICTs are developed or purchased and an exemption from this policy is granted, prior to introducing the inaccessible ICT into an academic or business environment, an EEAAP must be developed. The EEAAP will serve as a guide to describing the methods in which a person with a disability will be afforded the opportunity to acquire the same information,
engage in the same interactions, and enjoy the same benefits and services within the same timeframe as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. To provide equally effective alternate access, alternates are not required to produce the identical result or level of achievement for persons with and without disabilities.
Information about the EEAAP for ICT that is procured through the Office of Central Procurement can be made available from the Office of Central Procurement employee handling the request. Information about the EEAAP for ICT developed within Penn State is available from the IT Accessibility Team at accessibility@psu.edu or the unit’s Accessibility (Web) Liaison.
Accessibility (Web) Liaisons
The budget executive of each Penn State area will appoint one or more employees (typically an IT, instructional design, communications, or marketing professional) to oversee testing, remediation, and information-seeking activities. Accessibility Liaisons are responsible to help ensure that ICT purchased, developed, and deployed (including, without limitation, online content, software, courseware, digital materials, and IT resources) are monitored and tested for conformance with the Standards. The duties of Accessibility Liaisons are more fully described in the Standards.
Training and Resources
Penn State has identified considerations and helpful hints for faculty, staff, and students that will assist in ensuring the accessibility of ICT maintained by University campuses, colleges, departments, programs, and units. Information is centrally located at http://accessibility.psu.edu/.
Statement of Accessibility on all Web Pages and Web-based Applications
All web pages and web-based applications must display in a consistent location (e.g., menu or text in the banner or footer) a statement, or link to a statement, referring to a commitment to accessibility by the University, college, department, program, or unit. In addition, each page must have a link allowing users to contact the designated responsible position or positions within a college, department, program, or help desk (instead of individuals, who often change positions or duties).
The link may point to Penn States’ accessibility statement: www.psu.edu/accessibilitystatement, or for full statements on web pages, the suggested language is:
“Penn State is committed to ensuring that people with disabilities have an opportunity equal to that of their nondisabled peers to participate in the University's programs, benefits, and services, including those delivered through information and communications technology.
“If you discover a web page or application that is not accessible or does not conform to the University’s Accessibility Policy (AD69), please contact our IT Accessibility Team by email at accessibility@psu.edu. Please describe the problem, including the web address or URL of the web page or application. You may also call the University Help Desk at 814-865-HELP (4357).”
OR FOR UNITS PREFERRING LOCALIZED STATEMENTS:
“The [name of department or unit] is committed to ensuring that people with disabilities have an opportunity equal to that of their nondisabled peers to participate in the University's programs, benefits, and services, including those delivered through information and communications technology.
“If you discover a web page or application that is not accessible or does not conform to the University’s Accessibility Policy (AD69), please contact [the responsible entity] at [email address or phone number]. Please describe the problem, including the web address or URL of the web page or application. You may also call the University Help Desk at 814-865-HELP (4357).”
ICT Procurement and Adoption
Each University campus, college, school, department, program, or unit shall implement the procedures governing the procurement, acquisition, use, or adoption of ICT from third parties (e.g. vendors) found in the Standards.
Policy Exemptions
The following circumstances may qualify as exemptions from this policy:
1. Where compliance is not technically feasible or may require extraordinary measures due to the nature or intent of the ICT used, a request for exemption must be made. Lack of sufficient funding for any particular campus, college, department, program, or unit of the University would not be considered for an exemption.
2. Where compliance would result in a fundamental alteration of the information resource, application, or service, and not satisfy the original intent, an EEAAP must be in place.
3. Where ICT is procured through third party vendors or contractors and no alternative accessible ICTs are available from other third party vendors or contractors, a non-compliant ICT may be procured with an EEAAP in place.
4. Where ICT is not currently in compliance, but efforts are underway to fix the defects by a defined date and an EEAAP is in place.
Requesting Exemption from Policy
Purchasers, adopters, and developers of ICT may request an exemption from this policy’s requirements by contacting the IT Accessibility Team for a consultation at accessibility@psu.edu and then submitting a Policy AD69 Accessibility Exception Request to the ADA Compliance Office.
Further Information
For questions, additional detail, or to request changes to this policy, please contact the IT Accessibility Team at accessibility@psu.edu.
Cross References
AD25 - Video Productions
AD54 - Web Page Design and Image
Most recent changes:
- February 3, 2025 - Updates have been made to the policy to reflect current regulations, standards and best practices.
Revision History (and effective dates):
- September 26, 2016 - Major updates have been made to the policy to reflect current standards and best practices.
- August 2, 2011 - New policy.