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Statement of policy

Summary of contents/major changes

1. Purpose of Policy

   The purpose of this Policy is to facilitate and verify that information provided through the University's websites (Online Content) is accessible to students, prospective students, employees, guests, and visitors with disabilities, particularly those with visual, hearing or manual impairments or who otherwise require the use of assistive technology to access information.

2. Stakeholders Most Impacted by the Policy

   This Policy applies to all staff, faculty and student employees at the University who create, edit, post, or maintain Online Content as part of their official University functions. 

3. Key Definitions

   2. Accessible: the opportunity for a person with a disability 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. 

   3. Disability:  A physical or mental impairment that substantially limits one or more major life activities or bodily functions.

   4. Online Content:  Any information or service that may be accessed via a web browser, including—but not limited to—internet websites, images, audio, video, search engines and locally or remotely hosted (e.g., “cloud”) software systems.

   5. Accessible Technology Committee: A group consisting of representatives from across the University who assist, support, and advise the Accessibility Compliance Specialist.

   6. Accessibility Compliance Specialist:  The 51������ employee(s) charged with primary responsibility for coordinating and implementing this Policy.

   7. Web Accessibility Standards:  The technical standards for web accessibility compliance adopted by the University.

   8. Web Content Accessibility Guidelines (WCAG):  A set of web accessibility guidelines published by the World Wide Web Consortium (W3C). As of the effective date of this Policy, the most current version of these guidelines is WCAG 2.1 These guidelines may change as technology advances.

   9. Web content management system (CMS): A software system that provides tools for creating, modifying and publishing web pages.

   10. World Wide Web Consortium (W3C): The main international standards organization for the web.

4. Full Policy Details

   2. 51������ is committed to ensuring that a person with a disability is able to obtain the information via websites it controls as fully, equally, and independently as a person without a disability. Doing so maintains equal opportunities to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology. 

   3. Web Accessibility Standards

      2. WCAG 2.1Level AA conformance shall be the technical standard for evaluating the accessibility of Online Content 51������ Michigan University.

      3. As technologies advance, the University will continue to consider, and may adopt, additional standards at the recommendation of the Accessible Technology Committee; however, in no case should any additional standards be interpreted as diminishing or negating the existing technical standard.

      4. Web applications developed by third-party vendors also must meet WCAG 2.1 Level AA compliance. For new product purchases, the Accessibility Compliance Specialist, who shall be appropriately trained in web accessibility issues, will evaluate products prior to purchase to ensure that products and services are accessible as part of required, third-party software purchase review.  Requestors whose third-party product or service requests that do not meet WCAG 2.1 standards will be required to create an Equally Effective Alternative Access Plan and have that plan reviewed and approved by the Accessible Technology Committee.

   4. Implementation

      2. The Accessibility Compliance Specialist will:

         2. Have sufficient knowledge, skill and experience to understand and employ the University’s Web Accessibility Standards;

         3. Be housed in 51������x;

         4. Chair the Accessible Technology Committee;

         5. Conduct regular audits to measure the University’s Online Content against the Web Accessibility Standards;

         6. Document and evaluate all problems identified through audits; and

         7. Ensure that all Web Accessibility Standards adopted by the University are documented on 51������’s website.

      3. Accessibility Compliance Specialist contact information:

         51������x
         Attn: Accessibility Compliance Specialist
         Western Michigan University
         Kalamazoo MI 49008-5230
         (269) 387-4200
         51������x-accessibility@wmich.edu

      4. The Accessible Technology Committee will:

         2. Consist of (at a minimum) a participant from each of the following offices or organizations: Office of Information Technology (OIT); Office of the General Counsel (OGC); Office of Marketing and Strategic Communications; Disability Services for Students; Office of Institutional Equity (OIE); 51������x; and Faculty Senate.

         3. Develop and define procedures to ensure that Online Content meets the University’s Web Accessibility Standards;

         4. Develop procedures to ensure that Online Content that does not meet the Web Accessibility Standards is evaluated and, if necessary, remediated within a reasonable period of time; and

         5. Develop procedures for evaluating and responding to exception requests submitted pursuant to Section 4.5, below.

      5. The Office of Information Technology will:

         2. Work with the Accessibility Compliance Specialist and their designee(s) to incorporate Web Accessibility Standards compliance validation into the OIT Technology Compliance Review Process; and

         3. Assist Accessible Technology Committee in developing methods for tracking compliance with training requirement(s).

      6. All units and programs will:

         2. Ensure that Technology Resources and Online Content meets or exceeds the Accessibility Standards;

         3. Complete the Technology Compliance Review Process before acquiring any third-party product or service that provides or hosts Online Content; and

         4. Cooperate with the Coordinator or Assistive Technology to identify and remediate Online Content that does not meet the Web Accessibility Standards.

   5. Training

      2. The Web Accessibility Committee will:

         2. Develop an annual training program to educate staff, faculty and student employees who, as part of their official University functions, create, maintain, post or distribute information with Online Content to students, employees, guests, and visitors with disabilities;

         3. Verify that training is facilitated, in whole or in part, by an individual with sufficient knowledge, skill and experience to understand and employ the University’s Web Accessibility Standards;

         4. Develop a system for verifying that all of the individuals identified above complete the training requirements of this Policy; and

         5. Work with appropriate University entities to develop processes and procedures to make completion of annual training a condition of access to the University’s CMS and web hosting environment.

      3. The training must, at a minimum, explain the Web Accessibility Policy and discuss each individual’s role and responsibility to verify that web design, documents, and multimedia content are accessible.

      4. Prior to conducting or publishing such training, the Accessibility Compliance Specialist and Assistive Technology Committee should work with OGC to facilitate Department of Education, Office of Civil Rights (OCR), review and approval of the proposed training.

      5. All staff, faculty, and student employees who create, maintain, post or distribute Online Content as part of their official University functions will:

         2. Complete the annual training requirements defined by the Web Accessibility Committee; and

         3. Inform the Accessibility Compliance Specialist if/when they come across Online Content that may not be accessible.

         4. Failure to complete annual training will result in loss of CMS privileges until training has been completed.

   6. Exceptions

      2. Units and programs seeking an exception to this Policy must:

         2. Submit a written request to the Accessibility Compliance Specialist explaining in detail why compliance is not feasible and how, if exempted from one or more provisions of this Policy, the Online Content in question will be made accessible to individuals with disabilities in an equally effective manner; and

         3. Recognize that the law requires equally effective access for individuals with disabilities. This includes the ability to access information with the same spontaneity and independence as others. For example, if the content in question is freely available on the web, then it is not sufficient to provide an alternative that restricts the time of day during which the information may be accessed or that requires an individual with a disability to request assistance. Likewise, offering accommodations for inaccessible Online Content on a case-by-case basis does not qualify as providing equally effective access.

      3. The Accessibility Compliance Specialist will:

         2. Review each request for an exception to ensure that the proposed approach provides equal and effective access; and

         3. Submit a recommendation to the Accessible Technology Committee.

      4. The Accessible Technology Committee will consider each request and recommendation referred to it by the Coordinator Assistive Technology and approve or deny the request.

5. Accountability

   2. Failure to follow this Policy and any associated procedures may subject 51������ employees to disciplinary action, up to and including dismissal from employment by the University, consistent with applicable procedures and Collective Bargaining Agreements.

   3. Online content found to be in violation of this Policy should be referred to the Accessibility Compliance Specialist, who will contact the responsible unit to begin remediation procedures. The University reserves the right to remove any non-compliant content if the violation is not addressed in a timely manner.

   4. Individuals found to be repeatedly posting or distributing Online Content in violation of this Policy may, at the discretion of the Accessibility Compliance Specialist, be required to complete additional training or repeat the annual training program described in section 4.3 of this Policy. Violations may also result in suspension of access to create, edit, or publish online content on the University’s web systems and/or other disciplinary action in accordance with University Policy.

6. Related Procedures and Guidelines

   Contract Review Procedures
   
   AAUP Collective Bargaining Agreement

    

7. Additional Information

   N/A

8. FAQs

   2. Whom do I contact if I have a concern about web accessibility or need assistance with making my Online Content accessible?

      Contact the Accessibility Compliance Specialist. See Section 4.2.2.

   3. How do I report inaccessible Online Content?

      Students, prospective students, employees, guests, and visitors may report violations of the University’s technical standard(s) by filing a formal complaint with OIE through its Section 504 and Title II grievance procedures (available at http://wmich.edu/equity/reporting-forms) and/or by contacting the Accessibility Compliance Specialist. See Section 4.2.2.

   4. How do I know if third-party Online Content that I link to through my presentation/course materials complies with this Policy?

      Contact the Accessibility Compliance Specialist to request an evaluation of the content. See Section 4.2.2.

   5. What if the Online Content I want to use is not, and cannot be made, accessible?

      Contact the Accessibility Compliance Specialist for information on requesting an exception to this Policy. See Section 4.4.