AD69 Accessibility of Electronic and Information Technology

Contents:

• Purpose
• Scope
• Definitions
• Standards
• Policy
  • Active EIT
  • Legacy EIT
  • Archived Information Resources
  • Statement of Accessibility on all Web Pages and Web-based Applications
  • Exemptions from the Policy
  • Training and Resources
• Requesting Exemption From Policy
• Further Information
• Cross References

PURPOSE:

The Pennsylvania State University is committed to ensuring equal access to information, programs, and activities through its information technologies, web pages, web-based applications, operating system-based applications, online instructional content, services, and resources (“electronic information technology” or “EIT”) for all its constituencies.  This policy establishes standards for the accessibility of EIT 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 electronic and information technology (EIT) 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 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; recorded audio and DAISY format; HTML, MathML and other digital formats; video captioning; and Braille.



Electronic and information technology (EIT) - Includes, but is not limited to, information resources such as web pages, websites and databases; web- and computer-based applications allowing for interaction between software and users; services employing information technology and telecommunications equipment.



Information resources – includes web pages, videos, images, and other digital materials. Information resources differs from EIT in that it does not include technology components such as software applications and hardware devices

Active EIT – EIT that is regularly accessed by people greater than or equal to 5 times per year is considered active.

Legacy EIT – EIT that is accessed less than 5 times per year.



Archived information resources – EIT 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 Web page. 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.

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.

Those standards to which AD69 requires conformance are the following:

• W3C WAI Web Content Accessibility Guidelines version 2.0 (or current version)
• WCAG2ICT Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (or current version)
• AIM-HEA Accessible Instructional Materials in Higher Education Act (in development and pending legislative approval)

In the event that a person makes a request to make non-active EIT accessible, the unit responsible for its maintenance must make it compliant with the applicable standard, or provide an equally effective accommodation.

POLICY:

Active EIT:

EIT considered to be active must be in compliance with the applicable standards and guidelines described in the STANDARDS section of this policy.

Legacy EIT:

Legacy EIT must be updated to be in compliance with the applicable standards and guidelines described in the STANDARDS section of this policy, or the content must otherwise be made available in an equally effective accessible format, and in a timely manner, to any individual requesting access. The unit responsible for its maintenance must make it compliant with the applicable standards, or provide an equally effective accommodation.

Each University college, department, program, or unit must establish its own priorities and timetables for updating legacy EIT; or plan for its transition to archival status, or its removal. Priority must be given to creating accessible EIT for core institutional information such as course work, registration, advising, admission, and catalogs; and student, faculty, and staff information.

Archived Information Resources:

Information 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 information resource in an accessible format.

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:

The Pennsylvania State University is committed to making its websites accessible to all users, and welcomes comments or suggestions on access improvements. Please send comments or suggestions on accessibility to helpdesk@psu.edu.

OR:

“The [name of department or unit] is committed to making its websites accessible to all users, and welcomes comments or suggestions on access improvements.  Please send comments or suggestions on accessibility to the [position to contact].”

Exemptions from the Policy:

The following circumstances may qualify as exemptions from this policy:

1. Where compliance is not technically possible or may require extraordinary measures due to the nature or intent of the information resource, application or service, a request for exemption must be made.  Lack of sufficient funding for any particular 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.
3. Where, in the case that information resources, applications and services that are procured through third party vendors or contractors; and that no alternative accessible products are available from other third party vendors or contractors, procurement can be made of a non-compliant product.
4. Where the product is not currently in compliance, but efforts are underway to fix the defects by a defined date.

Training and Resources:

Penn State has identified considerations and helpful hints for faculty, staff, and students that will assist in ensuring the accessibility of EIT maintained by University colleges, departments, programs, and units. Information is centrally located at http://accessibility.psu.edu/

REQUESTING EXEMPTION FROM POLICY:

Purchasers and developers of EIT may request exemption from meeting the requirements of this policy by completing the Policy AD69 Accessibility Exception Request, then submitting it to the ADA Compliance Office for review and approval (if determined to be a justifiable reason for exception).

FURTHER INFORMATION:

For questions, additional detail, or to request changes to this policy, please contact the Office of the Vice President for Information Technology.

CROSS REFERENCES:

AD54 - Web Page Design and Image

Most recent changes:

• September 26, 2016 - Major updates have been made to the policy to reflect current standards and best practices.

Revision History (and effective dates):

• August 2, 2011 - New policy.