Purpose
The Internet is quickly becoming a primary distribution system for all sorts
of information on our campus. Collectively, faculty members invest considerable
time in the construction of class Web sites and expect students to access them
extensively. Administration, IT and the library invest heavily in Web-based
systems, such as online registration, courseware management (D2L), and
electronic journal databases. Both faculty and students would like these
resources to be easy to navigate and use. This policy and its associated
implementation components are intended to promote educationally effective online
resources that will be readily accessible to all current and prospective members
of the academic community, including those with disabilities.
This policy will ensure UWSP’s compliance with a number of policies enacted
at the UW-System level that acknowledge the need for an accessible Web
environment.1 At the state level, a recently passed policy requires agencies to
develop pages accessible to users of adaptive technology by conforming to
Section 508, included in the 1998 amendments to the US federal Rehabilitation
Act of 1973 (State
of Wisconsin Enterprise Standards for Information Technology 605; effective June
1, 2003 (http://enterprise.state.wi.us/home/standards/std605r.htm).
While the ultimate goal of this policy is to ensure a fully accessible
online infrastructure, practical considerations suggest that priorities be
given to (a) campus-wide Web resources, (b) department Web sites intended
to provide information on department mission, programs and activities, (c) most frequently used course-related web
sites, and (d) with certain exceptions, all
online resources,
including
Web pages, that are newly
procured or created, or that are undergoing a major overhaul. Ensuring
that accessibility is built into these resources is not only a major step
towards satisfying UWSP’s obligations under the American
with Disabilities Act (ADA), but it also helps avoid tedious and
costly “fixes” when the institution faces legitimate requests for access
to online content.
Policy
This policy is concerned with the accessibility of
all online resources supporting UWSP’s mission, including
Web pages,
Web-based
information resources (such as journal databases), Web-based
instructional applications (such as courseware and simulations) and online
services (such as public folders, e-mail, Web-based administrative
functions and forms). For Web pages, compliance
criteria are particularly stringent.
At a minimum, and subject to the limitations stated in the following
two paragraphs, Web pages hosted on UWSP servers
and tied, either directly or indirectly, to the campus’ mission must
comply with the relevant subsection of the Rehabilitation Act of 1973, as
amended (Section 508--especially Subsection
1194.22, a. through p.). In addition, Web designers are strongly
encouraged to apply the latest
Web
Content Accessibility Guidelines (WCAG) developed by the Web
Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C).
Users should be able to access the content of
Web
pages with text-only browsers. Although accessibility evaluation
tools, such as Bobby and
AccVerify/AccMonitor, are helpful in identifying some of the major
barriers, designers are also encouraged to verify functionality with an
audio browser or
screen reader.
Essentially, all Web pages hosted on UWSP
servers fall under the purview of this policy—except for those personal
student and faculty Web pages that do not support
instructional or research-related activities.
All new Web pages, as well as those undergoing
a major revision, will be made compliant with this policy. The following
implementation schedule, which goes into effect on July 1, 2005,
identifies some priorities and the sequence of events to take place:
Year 1: All sites specifically designed to provide disability related
services; sites that provide essential academic and administrative
functions, such as the library, records and registration, etc.;
top-level pages to the campus,
administrative offices, academic colleges and departments. It is
strongly recommended that all Web authors examine and bring into
compliance the top level pages for all
sites for which they have responsibility.
Year 2: The introductory page for all faculty sites and existing
course sites taught by the faculty member that academic year. As course
assignments change, existing course sites will be updated in that
academic year. Documentation of accessibility efforts is required in
exceptional cases involving materials that are very specialized and/or
too expensive to make accessible (see
Exceptions and Responsibilities
Section).
Year 3: Top-level pages of those sites
related to UWSP research and educational activities will be made
compliant by this time.
Year 5: All linked pages related to UWSP’s mission.
All parties involved in the creation, modification, replacement or
procurement of online resources must strive for compliance with relevant
Section 508 standards (especially, but not
exclusively, Subsections 1194.2, 1194.21 and 1194.22). Where applicable,
measures in the pursuit of accessible solutions must include, but are not
limited to:
- gaining familiarity with, and implementing, state-of-the art
accessible design practices for the product in question.
- considering alternatives to applications that do not lend themselves
to barrier-free design.
- taking into account the accessibility of products considered for
purchase.
- requiring
vendors to provide documentation
pertaining to the accessibility of their
products.
- including accessibility in RFPs (Request for Proposals).
This policy acknowledges that full
accessibility of online resources may not always be feasible—because
of the essence of the program, because of the nature of the application,
because of the lack of viable accessible alternatives, because of a
limited market situation or because of the imposition of an undue burden
in terms of time or cost. When a not fully accessible product is developed or
procured,
efforts in pursuit of a
barrier-free
solution must be well documented. Units failing to
consider accessibility and to document their
efforts must be prepared to promptly render inaccessible products,
services or programs in an accessible format whenever there is a
legitimate request—by either re-designing, or “fixing,” the
online resources in question or by providing their content in a suitable
alternative format. The Disability Services Office or the
ADA Coordinator may be called upon to determine the legitimacy of a
person’s request, and to assist in determining appropriate means to
deliver the inaccessible information.
Implementation
Implementation, training, education, technical support and the
monitoring of compliance according to the standards and recommendations
set forth in this policy will be handled by the UWSP Internet/Intranet
Information Resources Unit (I3RU) and the Assistive Technology Program.
Funding for additional staff will be provided for at least the first two
years of the implementation to be able to assist the campus in the
implementation process. Each UWSP unit with a presence
on the UWSP Web, such as a department, division, organization, or program
must be in compliance with accessibility standards according to the
timelines established in this policy. Each
unit is
also responsible for insuring that adequate staff and financial resources
are allocated to enable such compliance. Site authors are ultimately
responsible for insuring that their Web content is current, correct,
functional, and standards-compliant.
Training and Support
Ongoing training and support will be provided to ensure Web
accessibility. I3RU, Assistive Technology, and the Teaching & Learning
Resources Network (TLRN) will partner to offer or sponsor training classes
and public awareness campaigns, provide support documentation and
resources, and consultation to Web developers. The following resources
will be provided:
- “Accessibility-friendly” authoring tools will be made available and
supported.
- A comprehensive guide with links to accessible design resources and
major accessibility policies, laws, and guidelines (including resources
related to Section 508 of the Federal
Rehabilitation Act and the W3C Web Content Accessibility Guidelines)
will be provided by Assistive Technology.
- Templates for accessible
Web pages,
including Cascading Style Sheets (CSS), based on campus design standards
will be offered to units for use in their
Web pages.
- Technical resources for monitoring, checking, and repairing
Web pages will be provided. The primary tool,
AccVerify/AccMonitor, will be implemented through UW-System funding and
licensing. This software will be made available to Web authors.
Maintenance of the license and software will be provided by I3RU
technical staff. Awareness sessions and training in the use of
verification software will be provided both by UW-System staff and UWSP.
Monitoring Accessibility Compliance
Each UWSP unit has the responsibility to monitor
the accessibility compliance of its Web sites, and to designate an
individual to serve as a contact person for
non-conforming pages. Monitoring resources will be provided and supported
for this purpose (see above under Training and Support). I3RU and
Assistive Technology will conduct periodic reviews of Web sites based on
the implementation timeline. Units having non-conforming pages will be
notified of the policy and the resources available to assist them with
meeting its requirements.
UWSP unit
Web pages must
contain a link to the following accessibility information. It is
recommended that other UWSP Web pages also include a link to the following
text:
"If you have trouble accessing a Web site, require information in an
alternative format or wish to request a reasonable accommodation because
of a disability, please contact the Assistive Technology Coordinator at
715-346-4980 or assisttech@uwsp.edu.”
Procurement Procedures for Online Resources
UWSP units that create, modify, replace or
procure
online resources (other than
Web pages) must act in accordance with the section
of this policy entitled, “UWSP
Online Resources Other Than Web Pages.” In the case of the procurement
of commercial resources, units must require
vendors to provide information pertaining to the
accessibility of their products.
Accessibility
considerations must also be included in the development of Requests for
Proposals (RFPs). Where applicable,
units and UWSP
Purchasing will work together in the pursuit of accessible products.
Policy Review
This policy and its implementation will be reviewed every year—or
earlier if deemed necessary by either the University Technology Committee
(UTC), the Disability Services Office, or the TLRN. At a minimum, the
review committee shall include one representative each of the UTC, the
faculty, the Disability Services Office, the Library, the UWSP Extension,
and the TLRN , as well as a student and, if available, a person with a
disability who is affected by this policy. The UTC shall be responsible
for forming the review committee. The review shall be a public process,
open to comments and suggestions from other persons or units on campus.
Definitions of Policy Terms
- Accessibility
- In the context of the Web, accessibility refers to the ability of a
Web page to be viewed by everyone, including people with disabilities
who use various assistive technologies. Accessible Web pages take into
account the special needs of visitors with auditory, visual, mobility
and cognitive impairments and give those users an equivalent browsing
experience to that of non-disabled visitors.
- Accessibility Compliance
- Compliance with widely
accepted methods of creating Web resources according to principles of
accessible (or barrier-free) design, i.e. a design that seeks to
accommodate the needs of a wide spectrum of people, including those with
sensory, mobility and cognitive disabilities.
- AccVerify/AccMonitor
- A suite of tools developed by
HiSoftware
that assists with the creation and maintenance of accessible web pages.
AccVerify, which can be downloaded on individual workstations, allows web
authors to check their pages for compliance with section 508 and, if
necessary, helps them make repairs. AccMonitor, which is run on a server,
provides for the periodic accessibility checking of specified sets of web
pages. The reports it generates can be disseminated through email or
postings to a web site.
- Americans with Disabilities Act (ADA)
- Bill passed in 1990 to provide equal protection and access to public
accommodations to people with a variety of disabilities including
visual, auditory, mobility, and other mental and physical health-related
conditions. Title II of the ADA, which applies to state and local
government agencies (including public universities), requires that “each
service, program, or activity must be operated so that, when viewed in
its entirety, it is readily accessible to and usable by individuals with
disabilities, unless it would result in a fundamental alteration in the
nature of a service, program, or activity or in undue financial and
administrative burdens.” (An Overview of the ADA at
http://www.access-board.gov/about/ADA%20Overview.htm.).
- Audio browser
- An audio browser, or a “talking browser,” is software that
interprets the html code of Web pages and provides speech output for
text-based components, along with information provided by the html
mark-up tags. Typically, it also enables users to navigate the Web page
through alternative keystrokes.
- Barrier-free design
- Here used in the same sense as accessible design or universal
design: design that seeks to accommodate the needs of a wide spectrum of
people, including those with sensory, mobility and cognitive
disabilities. Barrier-free Web design seeks to avoid design components
that make it impossible for a person with a certain disability to
navigate a Web site and to access its information.
- Bobby
- A Software package available for use online or through download that
evaluates Web pages for accessibility mainly to visually impaired users.
Sites that pass are entitled to display the "Bobby Approved" icon.
However, that icon does not mean that those sites also comply with all
of Section 508's accessibility requirements. You can evaluate single Web
pages at the
Bobby
Web site. (
http://bobby.watchfire.com/bobby/html/en/index.jsp)
- Contact person
- An individual identified by each UWSP unit with a Web presence who
is charged with the responsibility of serving as a principle point of
contact for the unit’s Web pages.
- Home page
- The first page or front page of a Web site, which serves as the
starting point for navigation. On the UWSP Web, the home page is the
main campus Web site or the “start” pages for each department, service,
organization, or office. See also
Top-Level
Pages.
- Online Resources
- Electronic resources belonging to any of the following three categories: (1) Web pages. (2)
Complex and often highly dynamic resources which can be accessed via the
Web. Sometimes, these resources originated as Web-independent
applications, such as CD-ROMs or software databases. Examples include
D2L, Online registration, games, simulations, calculators, and Web-based
chat rooms. (3) Larger units of information resources, such as books,
journals, magazines, theses, film, photo and audio collections, archival
materials, etc., that are digitized and made available through the Web.
(4) Other Internet resources that are not, or not exclusively,
web-based, such as Email and public folders.
- Procured
- Purchased, leased, licensed from, or contracted from a company or vendor.
- Screen Reader
- Software that reads the content of a computer screen aloud. Screen
readers can only interpret text content, so all graphic and multimedia
must have alternative text descriptions using ALT text, captions,
transcripts, or other methods.
- Section 508
- Section 508 is a part of the federal Rehabilitation Act originally
enacted in 1973. As amended in 1998, Section 508 requires that
electronic and information technology developed, procured, maintained,
or used by the federal government be accessible to people with
disabilities. Charged with developing corresponding standards, the
federal Architectural and Transportation Barriers Compliance Board
(“Access Board”) authored the
Electronic and Information Technology
Accessibility Standards (often referred to as “Section 508 standards”),
which went into effect in February 2001 (http://www.access-board.gov/sec508/508standards.htm). While Section
508 applies primarily to federal agencies, it has been argued that
states receiving funding under the Assistive Technology Act of 1998
(which includes Wisconsin) must also comply with Section 508 standards
(see, for example,
Legal Opinion M 01-17 expressed by the Ralph Black,
General Counsel of California Community Colleges (http://www.icdri.org/legal/Ccommunity.htm). Regardless of whether
this argument is valid, most state and university web accessibility
policies have recognized Section 508 as the de facto standard (see,
e.g., the State of Wisconsin’s
Enterprise Standards for Information
Technology: 605 - Deployment of Accessible Pages on the World Wide Web
(http://enterprise.state.wi.us/home/standards/std605r.htm). For
additional information on Section 508, see the
Department of Justice
Section 508 Home Page (http://www.usdoj.gov/crt/508/508home.html).
- Top-level pages
- Web sites are typically hierarchically organized. The pages at the
top of this hierarchy are referred to here as “top-level pages.” For a
given site, they include the home page of a campus unit as well as the
next layer of Web pages directly linked to it (excluding external
links). See also Home Page.
- Unit, UWSP unit
- Here used as an abbreviation for a UWSP department, division,
organization, or program with a Web presence.
- Vendor
- Person or company that offers to sell, lease, license or contract
out certain products and services, or access to such products and
services, such as course-management systems (courseware) or journal
literature databases.
- Web pages
- Usually a single HTML file that contains text, visual and sometimes
audio components, is part of a Web site, and has an individual file name
assigned to it. Individual Web pages are typically part of a larger,
hierarchically organized unit, referred to as a Web site.
- Web Content Accessibility
Guidelines
- Guidelines developed by the
Web Accessibility Initiative (WAI) of the World Wide
Web Consortium (W3C), an international standard setting body founded to
develop common protocols for the evolution of the Web. (http://www.w3.org/WAI/GL)
End Notes
1Report
of the Committee on Access to Technology for Individuals with Disabilities
(http://www.uwsa.edu/olit/disacc/finrep.pdf);
Ed
Meachen's Directive to UW institutions on behalf of President Lyall
(http://www.uwsa.edu/olit/access/edmemo.htm);
Standards for Academic and Student Support Services in Distance Education Credit Courses, Degree and Certificate Programs
(http://www.uwsa.edu/acadaff/acis/destandards.pdf);
UW System Policy on Library Support for Distance Education, Extended
Education, Students and Faculty (http://www.uwsa.edu/olit/cuwlweb/depolfb1.htm);
2001- 2003 University of Wisconsin System Information Technology Plan
(http://www.uwsa.edu/olit/it-plnng/2001pln.pdf);
University of Wisconsin Libraries Strategic Directions for 2003-2005
(http://www.uwsa.edu/olit/cuwlweb/Strategic Directions 2003-2005 Web
version.htm).