The University of Oregon strives to ensure that people with disabilities have access to its programs, services, or activities, including those delivered using information and communication technologies (ICT). As the University operates in an increasingly digital environment, equitable access for all is critical for our success. It is essential that accessibility be seamlessly integrated as the university acquires, creates, uses and publishes information and communication technologies. The University’s commitment to equal access to ICT is expressed in its ICT Accessibility Policy and through these ICT Accessibility Procedures and Guidelines.
In May 2019, in furtherance of its efforts to combat discrimination and ensure compliance with state and federal law, the University President approved recurring funding to support additional web accessibility efforts on campus, including but not limited to posting and hiring a 1.0 FTE position (ICT Accessibility Program Manager) to oversee compliance of digital resources; immediate engagement with an external auditor to perform an accessibility audit; purchase of an internal tool allowing the University to proactively scan and remediate its digital environment; and additional web accessibility training support.
All University faculty, staff, and student employees who create new or modify existing University online content must use good faith efforts to ensure compliance with prevailing national standards (e.g., WCAG 2.0) on all UO public web pages used to conduct University programs, services, or activities pursuant to the applicable implementation timeline described below, unless granted an exemption (as described below). All University departments are responsible for ensuring that all their public web pages hosted through the University (https://uoregon.edu/) are in compliance. Depending on the particular circumstances of each case, the standards contained in this policy and procedure may not apply to ICT published by students, employees, or agents that are hosted by the University but are not used to conduct any program, service, or activity of the University business.
The University President or their designee will establish a schedule for audit, assessment, and evaluation of UO websites for compliance and incorporate it into these procedures. Based on the findings of the external audit and input from the ICT Accessibility Program Manager, the implementation schedule will be a rolling implementation with certain ICT prioritized over others, and groups of ICT tiered between immediate implementation (e.g., for new content) up to approximately three years for full compliance for other content (absent an exemption). The Chief Information Officer or their designee will work with the campus community on compliance and provide support, where appropriate.
3. ICT ACCESSIBILITY PROGRAM MANAGER
The ICT Accessibility Program Manager will oversee compliance of ICT resources at the University and develop standards, capabilities, remediation projects, training and support of accessible technologies across campus. This position will also chair the ICT Access Committee discussed in more detail below.
4. ACCESSIBILITY AUDIT
The University will conduct an annual accessibility audit/assessment of existing content and functionality on the University’s public website and identify any online content or functionality that is inaccessible to persons with disabilities. The auditor will have sufficient knowledge and experience in website accessibility to carry out all related tasks. The initial audit will be conducted by an external auditor; recurring annual audits/assessments may be conducted internally.
· Accessibility Webpage: Information about the appropriate standard, who to contact for questions or concerns, who to contact prior to creating new UO ICT, and how to file a complaint/grievance will be located on the UO’s Accessibility webpage.
o Validation process
· UO prohibits discrimination on the basis of race, color, sex, national or ethnic origin, age, religion, marital status, disability, veteran status, sexual orientation, gender identity, and gender expression in all programs, activities and employment practices as required by Title IX, other applicable laws, and policies. Retaliation is prohibited by UO policy. Questions may be referred to the Title IX Coordinator or the Office of Investigations and Civil Rights Compliance. Contact information, related policies, and complaint procedures are listed on the statement of non-discrimination.
· Accessibility Link: The University will include an “Accessibility” link on its home site “https://uoregon.edu/” that will link to an accessibility page which will include notice to persons with disabilities regarding who to contact to report and/or resolve online information or functionality that is currently inaccessible. The Accessibility page will also include information about, or an accessible link to information about, how to file a complaint/ grievance with the university pursuant to the requirements of Section 504 and Title II.
· Requirements for information and communication technology procurement. UO will require vendors who develop online content for functionality of UO public websites to comply with University accessibility standards.
· Human Review of Hardware and Software Products. Purchasing and Contracting Services (PCS) will work with appropriate campus stakeholders to develop a mechanism to evaluate hardware and software products purchased or acquired by UO to meet national accessibility standards to the extent feasible. Furthermore, PCS will initiate a strategic purchasing initiative to establish a pool of approved web development vendors capable of providing products and services that meet University accessibility standards.
7. EXEMPTIONS / ALTERNATIVE PROCESSES
· Archived ICT: The University will take appropriate action to make ICT that are no longer available to a wide audience, but are subject to record retention plans (including but not limited to archived web pages), accessible upon request. Appropriate action may include making specific ICT available in an equally effective accessible format, and in a timely manner, to the individual requesting access.
· Legacy ICT: Units with legacy web pages, e.g. ICT published prior to January 1, 2016 and not significantly modified or edited since that time, do not have to comply with the above described standards, but are encouraged to do so, as well as to identify and improve the accessibility of their pages, and otherwise make such specific ICT available in an equally effective accessible format, and in a timely manner, to any individual requesting access
· Undue burden, fundamental alteration, and non-availability may qualify as exemptions from the policy under the following circumstances:
o Undue burden: 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, in isolation, for any particular college, department, program, or unit of the University would not be considered for an exemption.
o Fundamental alteration: Where compliance would result in a fundamental alteration of the information resource, application, or service, and not satisfy the original intent.
o Non-availability: Where, in the case that information resources, applications and services that are procured through third party vendors or contractors, and no alternative accessible products are available from other third party vendors or contractors, procurement can be made of a non-compliant product.
· Implementation in Progress: Where the product is not currently in compliance, but efforts are underway to fix the defects by a defined date. A process has been set for compliance implementation.
· Making Exemption Requests: Requests for exemptions must be submitted in writing. The conclusion of undue burden, fundamental alteration, or non-availability is an institutional decision to be made by the University President or their designee, in consultation with the affected unit, the ICT Access Committee, and others with relevant perspective or expertise. In the case of undue burden or fundamental alteration exception that is granted, the University must document its plan for providing equally effective alternate access under the circumstances.
8. CONCERNS / COMPLAINTS
· Reporting Concerns. The University has an accessible a secure Web-based reporting system for individuals to report ICT accessibility concerns: https://www.uoregon.edu/accessibility. If a current or prospective student, employee, candidate for employment, or campus community member who is attempting to access University programs, services, or activities, seeks to raise a concern about the accessibility of UO ICT, the person may contact the ICT Accessibility Coordinator.
· Filing a Complaint. Any student, employee, candidate for employment, or campus community member may file a complaint with the Office of Investigations and Civil Rights Compliance. The Office of Investigations and Civil Rights Compliance will work with employees, students and campus community members to ensure that they understand their complaint options, are protected from retaliation and are provided with interim measures as appropriate. The Office of Civil Rights Compliance can be contacted at:
o By telephone at (541) 346-3123
o By email at firstname.lastname@example.org.
o In-person at 677 East 12th Ave., Suite 452, 5221 Univ. of Oregon, Eugene, OR 97403
The University will make, on no less than an annual basis, website accessibility training available to all appropriate personnel, including, but not limited to: content developers (whether faculty or staff), webmasters, communications officials, procurement officials, and appropriate IT personnel. The training will include information to help the abovementioned persons understand and meet accessibility standards and comply with the University’s ICT Accessibility Policy and Procedure. The web-based training for 2019 can be accessed at https://odt.skillport.com.
10. ICT ACCESS COMMITTEE
ICT Access Committee. The ICT Access Committee is responsible for implementing, maintaining and enforcing these procedures, procurement processes, and accessibility guidelines covering the University of Oregon digital environment to ensure that the university is fulfilling its commitment to accessibility for all and complying with applicable law. The ICT Committee is also responsible for monitoring compliance with these procedures, and for periodic review of the procedures, resources, and exemption criteria contained herein. Such review shall occur on an annual basis.