Electronic and Information Technology Accessibility Policy

Sponsor:	Information Technology Services
Contact:	EIT Accessibility Officer
Category:	Information Security and Technology
Number:	1000.012
Effective Date:	11/2021
Implementation History:	First draft 3/2021
Keywords:	Accessibility, Information Technology, Electronic Information Technology, Procurement, Compliance, marketing and communications, training
Background Information:	This policy applies to all Electronic Information Technology (EIT) acquired, developed, distributed, used, purchased, or implemented by or for SUNY Empire and used to provide SUNY Empire programs, services, or activities. This includes, but is not limited to, all EIT related to College business, academic and outreach, including web pages that represent SUNY Empire, electronic documents and any multimedia created or obtained.

Purpose

This policy establishes standards for EIT accessibility in compliance with applicable local, state and federal regulations and laws. SUNY Empire is committed to providing equal access to its services, programs, and activities for all users. An accessible EIT environment enhances usability for everyone.

Definitions

Accessible EIT that can be equally accessed and independently used by individuals with
disabilities. Accessible EIT enables individuals with disabilities to acquire the same information,
engage in the same interactions, and enjoy the same services as individuals without disabilities,
with substantially equivalent ease of use, using reasonable accommodations when necessary.

Archived A web page or electronic resource that is no longer available online but is still subject
to the applicable records retention requirement under University policy.

Electronic information and technology (EIT) EIT includes, but is not limited to, any equipment or
interconnected system or subsystem of equipment that is used in the creation, conversion or
duplication of electronic or digital data or information, such as: web sites, course and
instructional materials (Word documents, PDF documents, Power Point presentations, video, podcasts,
etc.), courseware, software, other classroom technologies, content management systems, search
engines and databases, registration and grades, financial and human resource management systems,
telecommunications, and emerging technologies.

Employee Any person employed by SUNY Empire, including (but not limited to) faculty, administrative
professionals, state classified, student employees and temporary employees. Volunteers are not
employees but are responsible to adhere to the SUNY Empire policies and procedures.

Equally Effective An alternative format or medium that communicates the same information in as
timely a fashion as does the original format or medium. Attempts will be made to reduce the excess
effort to create a similar experience for all users. For interactive or service pages, equally effective
means the end result (e.g., registration) is accomplished in a reasonable time and with comparable effort on the part of the requestor.

Password-protected or Internal Content Content that is not public‐facing and authentication or
authorization is required for access.

Public Facing Content Any content that is intended for access by the general public without
restrictions.

Redesigned Webpage A web page where significant alteration or update is made to the visual design
of a page or a major revision of the content of a page takes place.

Software, Hardware, Systems and Applications Examples of software, hardware, systems and
applications include, but are not limited to, learning and content management systems, library and
email systems, and administrative management systems such as finance, registration and human
resources, and all software, hardware and software services used for student services. Software
includes freeware, shareware, desktop, enterprise, subscription and remotely hosted options.
Software that is accessed through a web‐browser must also be accessible.

Substantial Change Updates, design or architectural changes to a website that goes beyond simple
text changes.

College Webpage A web page created and published by SUNY Empire in the scope of college‐related
business. It does not include web pages published by employees for personal purposes, and not
published on SUNY Empire sites.

College Legacy Webpage A college web page created and published by SUNY Empire prior to the
effective date of the EIT Accessibility Policy.

VPAT A Voluntary Product Accessibility Template published by the Information Technology Industry
Council used to describe the accessibility of a vendor’s products and services.

Content Editors Those individuals that create/edit/update electronic content either through web,
Learning Management System (LMS), or other communication technologies.

System Administrators Those individuals with oversight of technology platforms that house
electronic communication.

Web Content Authors Those individuals with access to create and post content on any of the
college’s web domains, including but not limited to the college’s public facing website and content
management systems.

System Administrators Those individuals with system level or administrative access to enterprise
information and communication technologies.

Approved Purchasers Those individuals with permission to acquire information and communication
technologies utilizing college funds.

Statements

SUNY Empire adopts the World Wide Web Consortium’s standard: Web Content Accessibility Guidelines (WCAG). In addition, all EIT shall comply with federal and state laws including the Americans with
Disabilities Act of 1990 (ADA), as amended, and Sections 504 and 508 of the 1973 Rehabilitation Act, as amended.

Policy applicable for: All members of the Empire State College community

Applicable Legislation and Regulations

Section 504 and 508 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990

Related References, Policies, Procedures, Forms and Appendices

Authority & Accountability Structure

EIT Accessibility Officer (EAO)

As the policy owner, the EAO creates and receives appropriate approval for policy implementation;
ensures timely and necessary communication of policy to college constituents; represents and
advocates for policy implementation at the institution level. The EAO is responsible for
coordination and facilitation of the compliance efforts pertaining to the EIT Accessibility Policy
and its supporting documentation. The EAO may select a designee to serve as the EIT accessibility
committee chair.

EIT Accessibility Committee (EAC) Chair

The EAO may designate an EAC Chair, whose duties include, but are not limited to:

• Handling inquiries or concerns regarding the accessibility of EIT.
• Compiling and maintaining data to track compliance with the policy and related procedures.
• Coordinating training efforts for EIT.
• Chairing the EIT Accessibility Committee to ensure that university processes, policies and
standards comply with applicable laws.
• The Chair stands in for the EAO during meetings in which the EAO cannot participate.

All Departments, Programs, Staff and Faculty

All agents of the college will comply with the standards set forth in this policy. All agents of
the college, including faculty and staff, who create or contribute to the creation, distribution,
or procurement of websites, software, applications, electronic course content, electronic
recruitment materials including presentations and digital collateral, or the content provided in
any of these, must complete the EIT Accessibility training course and other training as prescribed.
This includes but is not limited to accessibility training for all web content authors prior to
their access to create web content; accessibility training for all approved purchasers prior to their access to make purchases; and all faculty who post content in the learning management system. The EAC chair will maintain institutional training records.

Deans, Directors, and Chairs

All deans, directors and chairs will ensure compliance of the EIT Accessibility Policy and its supporting documentation within their units. This includes, but is not limited to oversight of a process designed to:

• Ensure that all electronic content created, procured, provided or utilized by their units is in compliance with the EIT Accessibility Policy and its supporting documentation.
• Ensure that all web and digital content created within their unit is done so in an accessible format that supports the standards outlined in this policy.
• Include reporting to the EIT Officer or Chair on updates, response to issues and other relevant information.

Web Services

Web Services will advise and collaborate on an auditing schedule for EIT to monitor and support compliance of web sites, systems and LMS content.

Purchasing Office

The Purchasing Office creates processes and procedures for all purchasers to support compliance at the point of procurement of any third-party systems or software. Will incorporate accessibility requirement language into the procurement processes and contract requirements.

Communications and Marketing

Communications and Marketing ensure that policy standards are incorporated into the SUNY Empire Brand Guide and Strategy, to support a consistent and accessible public web and digital presence.

Web Services

Web Services will advise and collaborate on an auditing schedule for EIT to monitor and support compliance of web sites, systems and LMS content.

Chief Information Officer (CIO)

The CIO ensures that EIT Accessibility Governance is incorporated into an overarching IT strategic plan and operating procedures.

Director of Accessibility Resources and Services

The Director of Accessibility Resources and Services collaborates to ensure that all EIT that serves prospective, current and former students is in alignment with this policy.

Human Resources

Human resources works with the EAO/EIT chair to ensure compliance in accessibility training related to job functions and assists with the maintenance of training records, and collaborates to ensure that all EIT accessibility that serves faculty and staff in completing their work functions is in alignment with this policy.

Awareness Raising

Awareness of accessibility requirements is critical. Awareness takes place in several key ways: internal communication, internal training and external training.

Faculty and staff who publish digital content are required to make any documents accessible; therefore, they are required to be educated on accessibility.

SUNY Empire’s accessibility communication plan involves communication directly to faculty and staff and continually reinforces education on topics such as balancing accessibility compliance with copyright compliance and making documents, web pages, video, and other resources accessible.

Design

Information Technology Services’ Web Services area provides support, training, documentation and oversight to ensure accessibility of web content at the point of creation and subsequent maintenance.

All assets such as PDF and doc files must be made accessible at the point of creation. Creators of content are responsible for ensuring that all documents are accessible according to established standards listed in the process documents.

All business processes, software and applications created or obtained shall comply with the standards or have as high level of compliance as feasible. All current systems shall be evaluated for compliance.

Accessibility of Online Courses, Studies and Materials

A process shall be in place to monitor and remediate accessibility of all courses regardless of modality according to established standards listed in the process documents.

Procurement

SUNY Empire will assess each applicable purchase based on its potential impact regarding accessibility and will follow steps to first determine what the required proof of accessibility is needed in a new product, and then incorporate those specific requirements into the solicitation. Standard and uniform language will be included in the solicitation instrument and specific requirements, based on the original assessment will be included as part of the specifications of the procurement needs.

Monitoring Compliance

SUNY Empire monitors the main public and internal websites with a quality assurance tool which identifies accessibility issues. Course content and digital media is manually monitored and remediated for accessibility compliance.

Upon the procurement of new products that have an EIT component, or the renewal of an existing product, an evaluation will be conducted to determine that all applicable operations meet the standards determined to be required. The determination of compliance will be made by the EIT officer or designee based on pre-approved tools and resources already put into place through the oversight of the EIT Committee. Procurement of such products will only continue upon the approval of this assessment.

Communications and Marketing

Marketing designs web pages, landing pages, and digital content to the guidelines set forth in Web Content Accessibility Guidelines and uses the quality assurance tools to test and remediate errors prior to new or updated content being published.

Training

All personnel of SUNY Empire will comply with the standards set forth in this policy. All personnel of the college, including faculty and staff, who create or contribute to the creation or procurement of websites, software, applications, electronic course content, or the content provided in any of these, must complete accessibility training per the master training calendar.
This includes but is not limited to:

• Accessibility training for all web content authors prior to their access to create web content.
• Accessibility training for all EIT system administrators as a component to onboarding.
• Accessibility training for all approved purchasers prior to their access to make purchases.
• Accessibility and universal design training as a component to onboarding for all faculty and professional staff who create instructional and digital content.

The EIT Accessibility Officer or EIT Committee Chair will coordinate trainings, create the master training calendar and maintain institutional training records in conjunction with Human Resources.

Quality Assurance Standards

Quality assurance is ensured by the standards outlined in the EIT process documents. SUNY System Administration makes recommendations on industry accessibility standards. These standards are included in the process documents. Wherever possible SUNY Empire will attempt to exceed the required benchmarks outlined in these standards.