Electronic Information, Communication and Technology Accessibility (S-5)

Standard: S-5
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Office for Civil Rights
Date Issued: June 1, 2017
Date Last Revised: October 16, 2020

Table of Contents

Individuals and Entities Affected
Contacts
Statement of Standard
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
History and Updates
Appendix

Individuals and Entities Affected

Any University college, school, department, program or unit that utilizes Electronic Information, Communication and Technology that impacts students, employees and the public as it relates to University business and services. This includes individual faculty and staff who publish Web pages, distribute electronic documents (e.g., via email, SharePoint, Blackboard, etc.) and/or sign a contract with a vendor of electronic technology for the purpose of conducting University-related business and services. 

Contacts

Clarification of Standard

Associate Vice President for Civil Rights
765-494-7255 | ocr@purdue.edu

Accessibility Concerns/Requests for Exception

Fort Wayne: Associate Director of Human Resources
260-481-5720 | hr@pfw.edu

Northwest: Associate Director, Office for Civil Rights
219-785-5545 | civilrights@pnw.edu

West Lafayette: Associate Vice President for Civil Rights
765-494-7255 | ocr@purdue.edu

Statement of Standard

The creation and dissemination of knowledge is a defining characteristic of universities and is fundamental to Purdue University’s mission of learning, discovery and engagement. Delivery of information electronically is central to carrying out this mission. Acknowledging this fact, the University is committed to ensuring equal access to information for all its constituencies.

This standard establishes minimum requirements for the accessibility of Electronic Information, Communication and Technology necessary to meet the University’s goals and ensure compliance with applicable law. The University will meet the standards and guidelines outlined in the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA for all Web-based Electronic Information, Communication and Technology. Further, it will follow the Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT).

Specific applications of this standard are as follows:

1. Web: All websites, Web pages and Web-based software published or hosted by the University or used to conduct University business (including remotely hosted sites and software) must meet the above standards and indicate in plain text a method of contact for Persons with Disabilities having trouble accessing content.
   
   
2. Instructional Materials: All electronic instructional materials, optional and required, must be Accessible. This includes, but is not limited to, syllabi, textbooks, presentations and handouts delivered within the University’s learning management system, via email or via another electronic means for face-to-face classes as well as e-learning courses. It also includes electronic instructional activities such as instructional videos, online collaborative writing, Web conferencing, blogging, etc.
   
   
3. Documents: All University produced, maintained or distributed electronic documents must be Accessible. This includes, but is not limited to, word processing documents, PDFs, presentations, publications and spreadsheets that are scanned, uploaded, posted or otherwise published or distributed electronically.
   
   
4. Electronic Media: All electronic multimedia resources used by the University for instruction, communication, marketing, promotion or other academic or business purposes must be Accessible. Video must be closed-captioned and audio-described and audio resources must be transcribed.
   
   
5. Software, Hardware and IT Systems: All software, hardware and IT systems used for academic and research purposes, administrative and business purposes, and customer service must be Accessible and produce Accessible products or content, which includes compatibility with assistive technology. Software, hardware and IT systems include, but are not limited to, learning management, content management, library systems, email, human resources administration, financial systems, course or event registration, freeware, shareware, enterprise systems and online or remotely hosted software.
   
   
6. Procurement/Purchases: The University will purchase electronic products and solutions, including, but not limited to, software, operating systems, Web-based applications, video and multimedia, that meet or exceed the above Accessibility standards. The University recommends that all requests for proposals from and contracts with vendors include language that outlines this requirement and provides stipulations for how the vendor is expected to demonstrate compliance.

As a public university and a federal contractor, Purdue University is required to adhere to Sections 504 and 508 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act. This standard specifies the means by which the University ensures compliance with these laws. If a future federal or state law applicable to the University provides greater protections to Persons with Disabilities than WCAG 2.0 Level AA, this standard will be interpreted as requiring compliance with the provisions set forth in the law.

Accessibility issues may be brought to the attention of the University by submitting an Accessibility Concerns Notification Form or reporting the matter to the campus Equal Opportunity Compliance Officer. Refer to the policy on Equal Opportunity and Equal Access (III.C.2) for procedures for filing complaints of discrimination.

Responsibilities

Associate Vice President for Civil Rights

• Administer and interpret this standard.
• Initiate a review of and make necessary revisions to this standard as necessitated by regulatory and technological changes.
• Provide guidance to Equal Opportunity Compliance Officers on conducting audits and reviewing requests for exceptions.

Equal Opportunity Compliance Officers

• Conduct random audits for compliance with this standard.
• Review requests for exceptions to this standard on a case-by-case basis and document the decision.

IT, Marketing and Any Other Departments Authorized to Select and Provide IT Resources for Business or Academic Purposes

• Ensure that any content management system or other Web production software be Accessible and able to produce Accessible websites.
• Ensure that learning management systems and online conferencing systems are Accessible and compatible with assistive technology.
• Ensure that all software and other applications are Accessible and compatible with assistive technology.
• Ensure that all hardware, video and audio equipment, and other IT resources are compatible with assistive technology, and that assistive technology is made readily available to faculty, staff and students using University IT resources.

Colleges, Schools, Departments, Programs and Units

• Ensure compliance with this standard.
• Purchase and produce only Accessible Electronic Information, Communication and Technology and update existing media, content and systems as they are put into use.
• Ensure that departmentally owned or managed classrooms and labs are equipped with IT resources that are capable of delivering Accessible Electronic Information, Communication and Technology and are compatible with assistive technology.
• Ensure that all hardware, software, applications, systems, video and multimedia purchased or developed by the unit are Accessible and, as applicable, compatible with assistive technology.
• Promptly, upon request by a Person with a Disability, provide Web content published prior to March 15, 2010, or maintained as an archived page in an Accessible format.
• Submit to the campus Equal Opportunity Compliance Officer a written request for an exception in the event it is not technically possible or may require extraordinary measures to make specific Electronic Information, Communication and Technology Accessible.

Procurement/Purchasing Departments

• Purchase only Electronic Information, Communication and Technology that is Accessible and, as applicable, compatible with assistive technology.
• Submit to the campus Equal Opportunity Compliance Officer a written request for an exception to purchase a product that the vendor states will be fundamentally altered if made Accessible or will cause undue financial burden to make Accessible.

Faculty

• Comply with this standard.
• Create and present Accessible instructional materials.
• Use only Accessible Electronic Information, Communication and Technology to create, deliver and present instructional material and to conduct course related work.
• Promptly, upon request by a Person with a Disability, provide in an Accessible format Web content used in conjunction with his or her University duties that was published prior to March 15, 2010, or is maintained as an archived page.
• Submit to the campus Equal Opportunity Compliance Officer a written request for an exception in the event it is not technically possible or may require extraordinary measures to make specific Electronic Information, Communication and Technology Accessible.

Staff

• Comply with this standard.
• Create and use only Accessible Electronic Information, Communication and Technology when conducting University business.
• Submit to the campus Equal Opportunity Compliance Officer a written request for an exception in the event it is not technically possible or may require extraordinary measures to make specific Electronic Information, Communication and Technology Accessible.

Definitions

All defined terms are capitalized throughout the document. Additional defined terms may be found in the central Policy Glossary.

Accessible

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 manner.

Electronic Information, Communication and Technology (EICT)

EICT 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, and personal response systems (e.g., clickers). 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 telecommunication products (such as telephones), information kiosks, Automated Teller Machines (ATMs), computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

Person with a Disability

An individual who has one or more physical or mental impairments that substantially limit one or more major life activities.

Equal Opportunity Compliance Officer
For purposes of this standard, this role is filled for each campus by the following individuals:

• Fort Wayne: Director of Office for Civil Rights Compliance
• Northwest campuses: Associate Director, Office for Civil Rights
• West Lafayette: Associate Vice President for Civil Rights

Equally Effective

Alternative access for Persons with Disabilities to Electronic Information, Communication and Technology that (1) is timely (as soon as possible but within 10 business days), (2) is accurate in translation, (3) is delivered in a manner and medium appropriate to the disability of the person, and (4) affords the Person with a Disability the opportunity to obtain the information as fully, equally and independently as a person without a disability with substantially equivalent ease of use. Such alternative(s), to be Equally Effective, are not required to produce the identical result or level of achievement, but must afford Persons with Disabilities equal opportunity to obtain the same result, to gain the same benefit or to reach the same level of achievement in the most integrated setting appropriate to the person’s needs. For example, Equally Effective means that the end result (e.g., registration) is accomplished in a comparable time and with comparable effort on the part of the requestor.

Related Documents, Forms and Tools

This standard is issued in support of the policy on Equal Opportunity and Equal Access (III.C.2), as amended or superseded.

Additional related policies:

• Nondiscrimination Policy Statement

Tools:

• Accessibility Concerns Notification Form
• Web Content Accessibility Guidelines (WCAG) 2.0 AA
• Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies

Legal/regulatory information:

• Office of Civil Rights overview of Section 504 and Title II
• U.S. Access Board Section 508 Standards
• U.S. General Services Administration Section 508 accessibility program

History and Updates

October 16, 2020: Contacts updated.

June 1, 2017: Standard established in support of the policy on Equal Opportunity, Equal Access and Affirmative Action (III.C.2). This standard updates and supersedes the policy on Web Accessibility (VII.C.1), which was originally issued March 15, 2010. Additional history of that policy is noted in its archived version in the policy e-archive.

Appendix

There are no appendices to this standard.