Information Technology Accessibility

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1. Introduction

East Carolina University provides equal opportunity to its educational and administrative services, programs, and activities in accordance with federal and state law. This regulation extends to the university’s electronic and information technologies and applies to their procurement, development, implementation and ongoing maintenance.

Ensuring equally effective and timely access to electronic information technology (EIT) and communications is the responsibility of all university administrators, faculty, and staff.

This is in accordance with federal laws including the Americans with Disabilities Act of 1990 (ADA), and the Amendments Act of 2008, Section 504 and Section 508 of the 1973 Rehabilitation Act as amended (29 U.S.C. 794d).

1.1. Definitions

Accessibility Standards are the internal standards that clarify the use of Section 508 and Web Content Accessibility Guidelines (WCAG) as it relates to East Carolina’s programs and services.

Accessible "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. Although this might not result in identical ease of use compared to that of persons without disabilities, it still must ensure equal opportunity to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology.

Disability, with respect to an individual, means (A) a physical or mental impairment that substantially limits one or more major life activities of such individual; (B) a record of such an impairment; or (C) being regarded as having such an impairment.

Electronic and Information Technology (EIT) includes e-learning and 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, 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, audience response systems (“clickers”), and 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 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), and related resources.

Equally Effective means that the alternative format or medium communicates the same information in as timely a manner as is feasible.

Reasonable Accommodation is any modification or adjustment to the work or academic environment that will enable a qualified applicant, visitor, student, or employee with a disability to participate in the application process or to perform an essential job function. Reasonable accommodation also includes adjustments to assure that a qualified individual with a disability has rights and privileges in employment equal to those of employees without disabilities.

Section 508 Standards are a comprehensive set of general, technical, and functional standards that apply to Federal agencies to make their electronic and information technology accessible to individuals with disabilities.

Web Content Accessibility Guidelines (WCAG) refer to the World Wide Web Consortium (W3C) guidelines for creating accessible Web content.

2. Purpose

The purpose of this regulation is to establish processes by which university administrators, faculty, and staff will create, obtain and maintain electronic and information technology (EIT) in a manner that ensures that EIT is accessible to individuals with disabilities.Unless doing so would pose an undue burden, the University will make reasonable efforts to ensure that EIT allows, regardless of the type of medium of the technology-- (a) individuals with disabilities to have access to and use of information and data that is comparable to the access to and use of the information and data by those individuals without disabilities; and (b) individuals with disabilities who are members of the public seeking information or services to have access to and use of information and data that is comparable to the access to and use of the information and data by those members of the public without disabilities.

This regulation applies to the following areas:

  • Web Accessibility
  • Instructional Materials Accessibility
  • Software, Hardware and Systems Accessibility
  • Procurement

3. Web Accessibility

3.1. Scope

This regulation applies to all university Web pages and applications, as defined by the ECU Web Regulation.

3.2. Standards

ECU requires web authors of both official and unofficial faculty and staff web sites at "ecu.edu" to comply with accessibility requirements mandated by federal and state law. Accordingly, the university has adopted Web Accessibility Standards based on the Section 508 and W3C Web Content Accessibility Guidelines. By adhering to these guidelines, ECU web resources will be accessible to persons with disabilities or a reasonable accommodation will be offered to qualified persons such as providing alternative formats or auxiliary aids and/or making adjustments. All university websites conducting ECU official business, unless technically impossible, will link to the university’s main Accessibility site which includes a statement of commitment to Web Accessibility.

4. Instructional Materials Accessibility

4.1. Scope

This regulation applies to all electronic instructional materials, optional and required, whether delivered within the university’s learning management system, in face-to-face classes, distance education classes or through electronic instructional activities such as email, blogs, and resources external to the university.

4.2. Standards

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 in a timely manner and through an equally effective means.

5. Software, Hardware and Operating Systems Accessibility

5.1. Scope

This regulation applies to software, hardware and operating systems purchased so that they are accessible with regard to assistive technology and are able to produce accessible products and content.

5.2. Standards

East Carolina University uses the 508 Standards - Software Applications and Operating Systems.To meet the standards, a product must either build in accessibility features as part of the development, or be compatible with assistive technology.These standards provide proven techniques for the design and development of universally accessible software, hardware, and operating systems.The specifications address keyboard access, screen focus, tabbing order, compatibility with assistive technology, visual cues for audio alerts, field and control labeling, documentation, color coding, adjustment of screen colors, and access to menus.

6.Procurement

6.1. Scope

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

6.2. Standards

The university has an established process to ensure accessible technology is procured where feasible.In the event it is not feasible, the university has an exemption and exception process (see link under Additional References) that may require an Equally Effective Alternative Access Plan (EEAAP) that is approved by the University ADA Coordinator or their designee.

    6.2a Purchase orders and contracts for EIT must include one of the following clauses or other language approved by Materials Management and the University ADA Coordinator:

    i. Standard Language in the Hosted Data Materials Management Contract

    “Americans with Disabilities Act (ADA) Compliance: Vendor shall provide its digital technology products in a manner which is accessible and shall comply with rapidly changing accessibility guidelines.Vendor has implemented product guidelines across all of its digital platforms in accordance with the Web Content Accessibility Guidelines 2.0 (WCAG 2) Level AA and with the guidelines under Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C 794d), and Offeror shall provide proof of its compliance as requested by the University.Contractor agrees to promptly respond to and resolve any complaint regarding accessibility of its products or services. Contractor further agrees to indemnify and hold harmless ECU from any claims arising out of its failure to comply with the aforesaid requirements. Failure to comply with these requirements shall constitute a material breach and be grounds for termination of this Contract.”

    ii. Language integrated into Materials Management bid requirements

    “ENTERPRISE-LEVEL IT SYSTEMS OR TECHNOLOGIES: The university is committed to promote and integrate universal IT accessibility in the delivery of its resources and to develop innovative solutions to accessibility challenges for students, faculty and staff.

    Vendors must:

    Assure all features, components and sub-systems of the software of IT System contained on this RFQ fully comply with Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d);

    or

    Detail why any feature, component or sub-system contained in this RFQ/IFB/RFP does not fully comply with Section 508, and the way in which the proposed product is out of compliance; the product offered in response to this RFQ/IFB/RFP is subject to an accessibility evaluation by the university.”

    6.2b Voluntary Product Accessibility Template (VPAT) a United States government standard should be generated by vendors for all products and services.The VPAT provides EIT purchasers with vendor self-disclosed information to determine if there are 508 deficiencies in the product or services.

    6.2c Materials Management will maintain a tracking system and coordinate with the university ADA Coordinator or their designee on exceptions and exemptions to this regulation.

    7.Compliance

    Compliance with this regulation is the responsibility of all staff and faculty of the university.The IT Accessibility Committee will annually review processes, goals, and standards to ensure the use, production and procurement of accessible information technologies.

    7.1. Requirements

    Annually, the IT Accessibility Committee will provide oversight to ECU’s IT Accessibility program plan by,

      a. reviewing the IT Accessibility Committee Charter and Membership for changes and improvements;

      b. reviewing this regulation for content changes;

      c. reviewing progress on program goals and establishing new goals;

      d. reporting and tracking the progress on goals;

      e. communicating regulation guidelines to the ECU community; and

      f. assisting staff and faculty through education and consulting on the standards referenced in this regulation.

    7.2 Reporting Inaccessibility

    The University ADA Coordinator is responsible for overseeing compliance with regard to state and federal regulations that prohibit discrimination on the basis of disability and require reasonable accommodation.To report inaccessible web content, software, hardware or other Information Technology Accessibility issues, contact the University ADA Coordinator or report an issue at the Accessibility website linked on every ECU webpage.

    Members of the University community who have concerns about the adequacy of accommodations or wish to file a complaint, should refer to the University’s Notice of Nondiscrimination and Affirmative Action policy. Information about filing a complaint may be obtained from the Office for Equity and Diversity.

    7.3 ADA Coordinator Authority

    The ADA Coordinator, or designee, may waive any requirements of this regulation in any instance for which waiver is permissible by law including, when applicable, situations in which compliance creates an undue burden on the University as determined by the ADA Coordinator.

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