1605 PR.01 Web Accessibility Procedure

Revision Date: 
March 1, 2018

Contents

1.  Overview

2.  Identifying a Site Owner for a University Website

3.  Managing Content on a University Website

4.  Evaluating a University Website for Accessibility

5.  Requesting an Exception

6.  Acquiring Accessible Software and Professional Services

7.  Reporting and Responding to Accessibility Issues

8.  Available Assistance

Policy 1605 Web Accessibility Policy was established to promote an accessible University environment online. This Procedure describes and specifies the steps a Site Owner may be required to take in order to comply with the Web Accessibility Policy. It also details the steps any unit can take to improve the accessibility of its University Website, and the help that is available to support this process.  All capitalized terms in this Procedure shall have the definitions assigned to them in the Web Accessibility Policy, which shall be incorporated into this Procedure by reference.

Per Policy 1605 Web Accessibility Policy, a Site Owner is the designated role or individual responsible for a University Website, as determined by the cognizant Dean, Vice President, Chair and/or Director of a University unit.  Site ownership is best assigned to a role, instead of to individual people whose role can change over time.  Site Owners may not have the knowledge and skills to directly address the accessibility of the University Website they own.  They are, however, responsible for the accessibility of these by holding accountable content creators, developers, Suppliers, and others whose assistance is needed to ensure the accessibility of the site.

ITS maintains a database of Site Owners and requests all changes in ownership to be reported via the Help Desk.

To meet the requirements of Policy 1605 Web Accessibility Policy, University Websites should be in compliance with the Standards.    Information on creating accessible content can be found on the Usability & Web Accessibility website.

Evaluating a University Website for accessibility can be handled in multiple ways.  It is recommended to apply a variety of approaches.  ITS can assist with accessibility testing, including identifying reputable Suppliers.  For more information on accessibility testing, visit the Usability & Web Accessibility website.

Automatic scanning

The use of automatic scanning tools such as WAVE or SiteImprove is recommended as a quick way to determine a rough level of accessibility; however, these tools cannot be relied on as the only means of assessment.

Manual checklist

A variety of manual checklists suited for developers, as well as visual designers and content creators, are available on the Usability & Web Accessibility website.  Checklists can be simple and quick guides to identify the most common accessibility issues, or extensive documents which lead a development team through a full review.

User testing

User testing can identify accessibility challenges that may render a site or web-based service difficult for people with disabilities to use.  Assistive technology should be used as part of user testing.

Expert review

ITS can assist with identifying reputable Suppliers for those wishing to have a third-party expert to validate accessibility.  After review, Suppliers can either remediate or provide guidance to the site’s developers and/or content creators on remediation.

In order to request an exception to Policy 1605 Web Accessibility Policy, the Site Owner may be required to complete an Exception Request which details the use and audience for the University Website and why compliance is not technically feasible or would create an undue hardship (e.g., by fundamentally altering the site).  In addition, an accommodation plan may be required.  An Exception Request template is available.  Email the completed template to the Accessibility Steering Committee via accessibility@yale.edu.

The Supplier Selection Process

It is important to consider accessibility from the beginning of the software or service acquisition process.  This includes software and web-based services that may be free or built in-house or by Suppliers.  Waiting until the later stages of the acquisition or development process may fail to uncover an accessible solution with the desired functionality and features.  When purchasing or otherwise acquiring a website or web application, whether via a software license or professional services, fill out the Web or Technology Procurement Updates Form to inform the ITS Digital Accessibility team, so they can engage with the acquiring unit and Procurement (if applicable) in evaluating the accessibility of applicable deliverables and/or services.

When evaluating proposals submitted by Suppliers, apply proper weighting to accessibility responses during scoring.

Contract Negotiation and Signing

While Procurement is negotiating the contract with the selected Supplier, the Site Owner will be responsible for providing input about the use of the product being purchased, to assist with decisions around accessibility.

When receiving an exception for the purchase of a product which does not fully comply with WCAG 2.0 Level AA, the Site Owner may be required to document an accommodation plan to meet the needs of users with disabilities and/or a roadmap to full compliance.  In addition, the contract for the product may include a roadmap with target dates for the product to achieve full compliance.  Engage the ITS Digital Accessibility team for assistance in assessing the appropriateness of the Supplier’s roadmap.  For more information about this process, visit the Working with Vendors section of the Usability & Web Accessibility website.

Implement Roadmap to Accessibility Compliance

When the contract includes target dates for a Supplier to achieve full compliance with WCAG 2.0 Level AA, it is the Site Owner’s responsibility to contact Suppliers and inquire about adherence to their roadmap.  If a Supplier is not cooperative, engage Procurement for assistance.  If the site is free or based on work done by a Supplier or in-house, the Site Owner is responsible for ensuring the roadmap target dates are met.  When the product is accessible, notify the Accessibility Steering Committee via accessibility@yale.edu.

Accessibility Statement Page 

ITS will make available an Accessibility Statement page on the Usability & Web Accessibility website.  This page can be linked from any University Website to communicate the University’s commitment to accessibility. The Accessibility Statement Page will link to an Accessibility Comments and Suggestions form.  This form can also be linked from any University Website to allow an easy way for the submission of requests, comments and suggestions on technology accessibility.

Site Owner Responsibilities

Site Owners must ensure their University Website complies with Policy 1605 Web Accessibility Policy.

All University Websites must include or link to an Accessibility Statement page and to a form allowing the submission of requests, comments and suggestions on technology accessibility.  These pages must be easy for site visitors to locate.  The preferred approach is a link in the footer of each page with link text of “Accessibility” linking to the Accessibility Statement page on the Usability & Web Accessibility website.

If a Site Owner receives a complaint directly, they should immediately report it via the Accessibility Comments and Suggestions form.

Site Owners shall treat all accessibility issues with a sense of urgency.  Address any time-sensitive need of the user promptly (generally within a period of no greater than two business days), unless technology or work involved requires more effort.  If Site Owners are unable to address the accessibility need of a user promptly, they must contact the Resource Office on Disabilities (for reports from students or visitors) or Office for Equal Opportunity Programs (for reports from others).  In all cases, accessibility issues must be reported centrally via the university Accessibility Comments and Suggestions Form.

How ITS Handles Accessibility Issues

Upon receiving a report of an accessibility issue, the ITS Digital Accessibility team acknowledges receipt of the issue via email to the individual raising the issue, with a copy to the Site Owner.  In addition, the ITS Digital Accessibility team notifies the Resource Office on Disabilities (for reports from students or visitors) or Office for Equal Opportunity Programs (for reports from others).  If the ITS Digital Accessibility team, in consultation with the Site Owner, determines that the information or service provided on the University Website cannot be made accessible, or that doing so would constitute an undue burden, the Resource Office on Disabilities or Office for Equal Opportunity Programs will engage with the user and Site Owner to determine alternative methods for providing the information or service.  In the event that an alternative format or service cannot be provided or the user is not satisfied with the results, the Accessibility Steering Committee may be called upon for assistance.

Procurement

Procurement has templates for all stages of the purchasing process to hold Suppliers accountable for accessibility.  Procurement will coordinate with the ITS Digital Accessibility team to provide expert assistance with the purchase of accessible solutions.  Information on the acquisition of accessible free or custom-built software is available on the Usability & Web Accessibility website.

Training and Support

To assist staff, faculty, and students in meeting the responsibilities described in this document, Yale will make training and support readily available, including a website devoted to providing information regarding web accessibility, the Usability & Web Accessibility website.

The training and support will include specific information for staff, faculty, and students who are responsible for creating, selecting, or maintaining web pages and web-based content in any University program, service or activity.  The training and support will also include instructions on how to make websites accessible, how to both manually check and use automated tools to ensure the accessibility of content therein, and how to get assistance.

Consulting

On-campus consulting will be made available for designing and implementing websites that meet accessibility guidelines and for evaluating the accessibility of existing sites and those under development.  If such assistance is needed, please visit the Usability & Web Accessibility website or email the ITS Digital Accessibility team at accessibility@yale.edu.

Financial Responsibility

The responsibility for assuring that a University Website is accessible, including providing required funds, rests with the cognizant Dean, Vice President, Chair and/or Director of a University unit.  Consideration of the costs related to creating accessible web-based information and services early in the development or procurement process will help Site Owners plan their budgets appropriately.  For help thinking through the financial impact of making your site, information or service accessible, contact the ITS Digital Accessibility team at accessibility@yale.edu.